UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

SHIRLEY WILLIAMS,

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)

Plaintiff,

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vs.

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SPRINT/UNITED MANAGEMENT COMPANY, )

)

Defendant.

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Case No. 03-2200-JWL

REVISED SECOND AMENDED COMPLAINT COME NOW Plaintiffs Shirley Williams and all Opt-In Plaintiffs, by and through counsel, and file this Second Amended Complaint per court Order of November 1, 2005 (Doc. # 3410). For their causes of action against Defendants Sprint/United Management Company and Sprint Corporation, Plaintiffs and all Opt-Ins allege and aver as follows:
GENERAL ALLEGATIONS 1. Plaintiff Shirley Williams (“Williams”) is a citizen and resident of the State of Kansas. Plaintiff Williams was 59 years of age at the time her employment was terminated by defendants on or about March 13, 2002. 2. The following individuals have filed lawsuits alleging ADEA violations against defendants, and per Court Order and/or on their own all have filed timely Consents opting into this action for purposes of their ADEA claims: John Borel, Steve Constance, Terry Lee Cocherl, Sharon Herren, Carol Kippes, Sharon Miller, David Molz, Carolyn Selberg, Peggy Sturgess, and Yvonne Wood-Olson. 3. Defendants Sprint/United Management Company and Sprint Corporation (hereinafter collectively referred to as “Defendants” or “Sprint”) are corporations which are currently in good standing and which are duly registered to do business in the State of Kansas

and which were doing business in the State of Kansas at all times relevant to this lawsuit. Defendant Sprint Corp. may be served by and through its registered agent, Corporation Service Company, 200 S.W. 30th Street, Topeka, KS 66611, or through its counsel of record.
4. This Court has jurisdiction over this action by virtue of 28 U.S.C. § 1331, in that it arises under the laws of the United States of America, namely, the Age Discrimination in Employment Act, 29 U.S.C. § 621, et seq. and other federal law.
5. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) by virtue of the fact that a substantial part of the events or omissions giving rise to the claims set forth herein occurred in the State of Kansas and that defendant is registered to do and is doing business in the State of Kansas, subjecting it to personal jurisdiction in this action and making it a “resident” of this judicial district pursuant to 28 U.S.C. § 1391(c).
6. Defendants Sprint/United Management Company and Sprint Corp. constitute, and constituted at all times relevant to this action, an “employer” as defined in 29 U.S.C. § 630(b) and 42 U.S.C. §§ 12111.
ALLEGATIONS SUPPORTING COLLECTIVE ACTION (29 U.S.C. §§ 626(b) and 216(b))
7. Beginning in mid-2001 and extending at least through the end of the first quarter of 2003, Sprint planned and implemented several phases of a “reduction in force” (“RIF”) purportedly intended to eliminate job functions and to reduce costs.
8. Sprint engaged in a pattern and practice of age discrimination in connection with the RIF for this time period, including setting up a “sham” process for displaced workers to “reapply” for open positions within Sprint, resulting in situations where applicants 40 years of age and older were not given the same consideration as younger employees and where applicants over 40 years of age were denied even the opportunity to interview for such open positions.
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Sprint also engaged in a pattern and practice of age discrimination in hiring new employees into positions for which recently RIF’d employees were fully qualified.
9. Also in connection with the RIF, Sprint engaged in a pattern or practice of age discrimination and otherwise treated younger employees more favorably than older employees, including (but not limited to) the following specific actions:
a. Transferring younger employees (i.e., those under the age of 40) to “safe” positions before and during the RIF process;
b. Identifying certain younger employees (i.e., those under the age of 40) as “key talent” and making extraordinary efforts to exempt them from the RIF;
c. Transferring older workers (i.e., those 40 years of age and older) to jobs or departments which were to be phased out or eliminated as part of a future reorganization;
d. Consciously deciding not to comply with the “Older Workers Benefit Protection Act” (“OWBPA”) for certain job grades, in order to avoid having to disclose demographic data and its “selection criteria” to those affected by the RIF;
e. Filling “open” positions within departments with younger employees (i.e., under the age of 40) just before the RIF, then terminating older workers (i.e. those 40 years of age and older) in the same or similar positions as part of the RIF;
f. Providing “spreadsheets” or templates” to managers to use in making termination decisions, which spreadsheets or templates included, or were
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designed to include, improper factors such as age, date of birth, and other age-related criteria; g. Providing hidden data links, within such spreadsheets and templates, that allowed managers to access improper criteria, such as age, date of birth, and other age-related data, for use in making RIF decisions; and, h. Failing, on a continuing basis, to rehire Plaintiffs and Opt-In Plaintiffs, post-RIF, for jobs they were qualified to fill. 10. Also in connection with its RIF, Sprint implemented a new “alpha rating” or “forced ranking” performance review system in early 2002 which was secretly intended to provide justification for termination decisions to be made as part of the RIF. With respect to this new performance rating system, Plaintiffs allege the following pertinent facts: a. Through the end of 2001, most Sprint employees were given an overall performance rating on a scale of 1-5, with 1 being the best and 5 being the worst; b. The vast majority of Sprint employees evaluated through the end of 2001 received at least a rating of “3" under this method; a “3" rating signifies performance that “fully met” the employer’s expectations; c. In late 2001, Sprint began discussing a new “alpha-rating” system which, among other features, would utilize the forced ranking method (using a “Bell-shaped curve”) lionized by Jack Welch of GE to rate and compare employees; d. One of Sprint’s intentions in adopting, and/or a result of Sprint adopting the new “alpha rating” system was that more older employees were
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identified as “poor performers” within the organization, while a disproportionate percentage of younger employees improved their ranking under the stack ranking or forced distribution system; e. Despite clear warnings from its own employees studying the new rating system before implementation that such a system “does not pretend to be objective,” and could lead to age discrimination, Sprint decided to move forward with the “alpha rating system” in late 2001 and early 2002; f. Under this new rating system, Sprint managers were directed to give a “shadow rating” to all exempt employees, as their 2001 “numeric” ratings had already been or were being determined; g. Sprint officially announced this new “alpha rating” system on or about December 21, 2001; h. Sprint employees were told in writing that the new 2002 alpha rating system would not be recorded, “would not affect compensation” in 2002, and “would not become a part of any employee’s permanent record”; i. Nevertheless, Sprint managers were expressly directed to use “shadow ratings” as one of the selection criteria for RIF decisions and, contrary to Sprint’s express representations to employees, alpha ratings were recorded in the CMR and possibly other databases and/or appeared in written records; j. Sprint managers made RIF decisions based upon the lower “alpha ratings” given to employees over the age of 40 who had received overall numeric ratings of “3,” or better;
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k. The “shadow ratings” given to employees in 2002 were an important factor used in the selection process for the RIF that occurred in 2002 and 2003;
l. Sprint conducted an “After Action Review” of the new alpha rating system which confirmed earlier warnings that the system would result in claims of age discrimination;
m. Sprint thus added a new, vague and subjective rating criteria without adequate training or communication as to proper usage;
n. Sprint added a “calibration” process to this new rating system which was highly subjective and allowed inherent conflicts of interest to occur; and
o. Sprint thus forced distribution of ratings into pre-determined quotas which increased the pool of employees in poor performer categories from 2% to 30%.
11. Although Sprint professed to determine the “impact” of actual and proposed job cuts upon various discrete groups of employees, including employees over the age of 40, Sprint has shielded and refused to disclose such information from many of its employees, and from others outside the organization, under a claim of “attorney-client” privilege.
12. Nevertheless, data provided through Sprint’s “human resource information system” (HRIS) confirms that, during various time frames relevant to this action:
a. Employees aged 40 and older have been disproportionately more likely to be terminated as part of a RIF at Sprint than employees under the age of 40;
b. Employees aged 40 and older, who had previously been rated higher under
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the numeric rating system were less likely to retain their good ratings under the alpha rating system than were employees under the age of 40; and, c. Employees aged less than 40 were disproportionately more likely to improve their ratings under the alpha rating system and/or to retain the highest categories of ratings under the alpha system. 13. The alpha rating system had a disparate impact on persons age 40 and over, and defendants have no reasonable factor other than age to explain that disparate impact. 14. Furthermore, Sprint’s own “After Action Review” of the new alpha rating system confirmed that: a. the system was subjective, arbitrary, non-substantive, dishonest, and inaccurate; b. The system was biased against older (over age 40) workers; and c. The system was inequitable and inappropriate because of pool size and composition. 15. Shirley Williams and Opt-in Plaintiffs received inconsistent, false, and agediscriminatory alpha reviews which ultimately led to these plaintiffs and many others similarly situated being adversely affected in the RIF. 16. All plaintiffs and opt-in plaintiffs were subjected to defendants’ culture change which occurred at least by 2001 and which stressed and preferred youth. Through use of code words such as “long runway,” “high energy,” and through other means, the message from Defendants’ Corporate Office, Human Resources officials, Executives, and other personnel was that the company was to become more youthful and younger.
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17. Defendant Sprint’s RIF Guidelines were subjective, inadequate and/or were unknown or not followed. Further, they placed subjective performance ratings – not excluding alpha, shadow ratings – at or near the top of the factors to be considered in the order of importance.
18. Defendants’ Human Resources Department inadequately responded to age discriminatory conduct, including that in connection with the RIF.
19. Defendants’ Human Resources Department and/or other personnel failed to adequately train and/or monitor executives and/or management with regard to RIF decisions to assure that age discriminatory conduct did not occur.
20. In addition to the foregoing facts, plaintiffs are “similarly situated” in that: a. All are over 40; b. All were terminated by Sprint as part of a reduction in force that spans the relevant time frame of July 2001 through March 31, 2003; c. All were and/or should have been identified by “Separation Code” 63 in Sprint’s human resource information system database (or some other code that indicates a non-performance-related reason for termination); d. All were satisfactory (or better) performers just before the RIF; e. All have the same or similar retirement benefit plans – with the same age and service formulas; f. All have the same or similar medical (and other) benefits; g. All were purportedly subject to the same “Displacement Guidelines” and standards for deciding during a RIF which employees would stay and which would go when choosing among more than one “incumbent”;
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h. All were subjected to a RIF overseen by Human Resource Sprint personnel, which department inadequately trained decision-makers with regard to avoiding and remedying age discrimination, and ensuring equal employment opportunity;
i. All were subjected to a RIF infected by Sprint management’s culture of bias and/or stereotypes in favor of youth and against age;
j. All exempt salaried employees had the same alpha and numeric performance evaluation systems in place at the particular time they were RIF’d;
k. For all persons over 40 who were RIF’d, younger persons were not RIF’d, despite having the same or similar job duties or classifications;
l. Most are exempt, salaried employees, although some are non-exempt; m. Most are job grade 71-79, although some are E-grade level; and n. All Plaintiffs and Opt-In Plaintiffs were discriminated against based on
their age in connection with Sprint’s RIF. ADDITIONAL ALLEGATIONS REGARDING PLAINTIFF SHIRLEY WILLIAMS
21. Plaintiff Williams began her employment with Sprint in or about November of 1998 as an Associate Analyst.
22. Plaintiff Williams worked for Sprint from November of 1998 to and including March 13, 2002.
23. During her employment with Sprint, Plaintiff Williams performed her job duties satisfactorily, received numerous satisfactory performance appraisals and received periodic raises in pay.
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24. In August of 1999, Plaintiff Williams was promoted to the position of Analyst. 25. In September of 2001, Plaintiff Williams received a satisfactory performance appraisal and was designated to receive a five (5) percent pay increase as a result of her job performance. 26. Shortly after this satisfactory performance appraisal, Plaintiff Williams learned that she had been listed as a potential witness in a disability discrimination lawsuit brought by a former co-worker of Williams against Sprint. 27. On or about November 28, 2001, Plaintiff Williams was interviewed by counsel representing defendants in connection with the disability lawsuit brought by a former co-worker of Williams against Sprint. 28. During this interview, Plaintiff Williams disclosed information that was generally supportive of the former co-worker, and disclosed the existence of a memo she wrote to her supervisor, Lorrie McCurdy (who was also a supervisor of the person bringing the other legal action against Sprint). 29. Shortly after her participation in this interview with counsel for Sprint, Plaintiff Williams began to receive unwarranted negative comments about her work performance. 30. On at least two occasions after her participation in the interview with counsel for Sprint concerning the co-worker’s legal action, Plaintiff Williams applied for Analyst positions, but was denied these promotions (in favor of younger, less-qualified candidates). 31. Plaintiff Williams applied for a Senior Analyst position in the Tables Department and was interviewed for this position on August 13, 2001; Plaintiff Williams later learned that the Senior Analyst position was given to a much younger female, Annette Purdon (born in 1974), who had less experience with the company.
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32. Plaintiff Williams is personally aware of Sprint’s practice of transferring employees to “safe” positions before implementing a reduction in force:
a. During both the Spring and the Fall of 2001, Plaintiff Williams personally observed that several males under the age of 40 were transferred from various positions in her business unit to work on what was called the “Renaissance Billing Platform,” a new billing system that Sprint was developing;
b. Upon information and belief, the employees who were transferred to work on “Renaissance Billing” in the Sprint of 2001 were: Brent Daniel, Jay Thompson, Shelby Brown and Josh Haddad. All were under the age of 40 at the time;
c. Upon information and belief, the employees who were transferred to work on “Renaissance Billing” in the Fall of 2001 were: Scott Rutherford, Chris Pritchard, Rich Brackenhauf, Ryan Gaik and Brett Talcott. All were under the age of 40 at the time.
33. None of these employees who transferred to work on Renaissance Billing in 2001 were included in the reduction in force of March 13, 2002.
34. In February of 2002, a new “subjective” performance rating system was introduced and Plaintiff Williams was improperly given a low rating.
35. Specifically, in February of 2002, Plaintiff Williams was given a rating of “4" on her 2001 LINK, and a “shadow rating” of “S” despite being told in her first interim and second interim reviews that her overall work performance met all expectations.
36. Sprint promoted two males under the age of 30 to the same position and job grade
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that plaintiff held during the two-week period immediately before Plaintiff Williams was terminated.
37. On or about March 1, 2002, two younger employees – Pat Paden (born in 1974) and Darin Collins (born in 1975) – were promoted to Analyst positions (Grade 73) in the Tables Department.
38. On March 13, 2002, Plaintiff Williams was notified (along with another coworker, Dawne Adams, also over the age of 40 and also a grade 73) that she was to be terminated in a “reduction in force.” Ms. Adams and Plaintiff Williams were the oldest Analysts in their department, had the longest tenure in their department, and were the only two Analysts terminated from their immediate work group on March 13, 2002.
39. Pat Paden and Darin Collins, who had been promoted to the same position and same pay grade that plaintiff held just two weeks earlier, were not terminated on March 13, 2002.
40. Defendants discriminated against Plaintiff Williams on the basis of her age with respect to the terms and conditions of her employment, by denying her promotional opportunities, by terminating her employment on March 13, 2002, and by refusing to re-hire and/or re-call Plaintiff Willliams for employment.
41. Upon Plaintiff Williams’ termination, her position was filled by and/or her former job duties were assumed by one or more younger employees.
42. Plaintiff Williams was treated less favorably than similarly situated younger employees in the layoff.
43. Plaintiff Williams’ age was a motivating and/or determining factor in the decision to terminate her employment. Defendants’ stated reasons for Plaintiff Williams’ termination
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were a pretext for discrimination on the basis of her age. 44. Plaintiff Williams has suffered from Defendants’ conduct which constitutes age
discriminatory disparate treatment and from Defendants’ conduct which had a disparate impact based on age.
45. Based upon Defendants’ discrimination against her, Plaintiff Williams filed a timely Charge of age discrimination with the Equal Employment Opportunity Commission (EEOC) on or about May 21, 2002.
46. Plaintiff Williams has received a Notice of Right to Sue from the EEOC. 47. Plaintiff Williams has fulfilled all conditions precedent to the filing of this action.
COUNT I – AGE DISCRIMINATION 48. Plaintiff and Opt-Ins hereby incorporate by reference each and every allegation and averment above as though fully set forth in Count I herein. 49. Defendants discriminated against plaintiffs and opt-ins on the basis of age, in violation of the Age Discrimination in Employment Act, 29 U.S.C. § 623. 50. Defendant, by and through its officers, employees and agents, engaged in a continuing pattern and practice of discrimination against and/or disparate treatment of plaintiffs and opt-ins based upon age, in defendant’s denials of plaintiffs’/opt-ins’ opportunities for promotions, in defendant’s terminations of plaintiffs/opt-ins, and in defendant’s denial of plaintiffs’/opt-ins’ equal opportunities for rehire post-RIF. 51. In addition to and or as part of its pattern and practice of age discrimination, defendant engaged in conduct relating to the “alpha” forced ranking performance review system which had a disparate impact on plaintiffs/opt-ins, and others in the protected age classification under the Age Discrimination in Employment Act.
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52. As a direct and proximate result of the continuing pattern and practice of discrimination directed toward plaintiffs/opt-ins, of the disparate treatment of plaintiffs/opt-ins, and/or of defendant’s conduct which has had a disparate impact on plaintiffs and opt-ins based on age, plaintiffs have each suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, and in other respects, all in amounts yet to be determined.
53. Defendant’s actions were willful, entitling plaintiffs and opt-ins to liquidated damages in an amount equal to the actual damages referred to in the preceding paragraph.
54. Plaintiffs/Opt-Ins have already incurred and will in the future incur substantial attorneys fees and expenses in prosecuting their claims of discrimination to which fees and expenses plaintiffs are entitled pursuant to 29 U.S.C. §§ 626(b) and 216(b).
WHEREFORE, plaintiffs and all Opt-Ins respectfully pray judgment in each’s favor, and in favor of all those similarly situated, against defendants Sprint/United Management Company and Sprint Corporation in the form of the Order of this Court: (1) permanently restraining defendants from ever again discriminating against plaintiffs or any other individual on the basis of that individual’s age; (2) reinstating plaintiffs to their respective positions with any promotions and pay increases each would have received in the interim; (3) awarding plaintiffs back pay in an amount yet to be determined; (4) in the alternative to reinstatement, awarding plaintiffs front pay in an amount yet to be determined; (5) awarding plaintiffs lost fringe benefits in an amount yet to be determined; (6) awarding plaintiffs liquidated damages in an amount equal to their actual damages; (7) awarding plaintiffs their costs and expenses, including attorneys and expert witness fees, incurred in prosecuting their claims of discrimination; (8) awarding plaintiffs damages to offset unfavorable tax consequences of any award, including attorneys fees; and (9) awarding such other and further relief as the Court deems just and proper.
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COUNT II – ADEA COLLECTIVE ACTION 55. Plaintiffs and all Opt-Ins hereby incorporate by reference each and every allegation and averment above as though fully set forth in Count II herein. 56. Cumulatively or in the alternative, defendants engaged in a pattern and practice of discrimination against plaintiffs and others similarly situated in the respects specified in Count I in violation of the Age Discrimination in Employment Act, 29 U.S.C. § 23, et seq. 57. Plaintiffs’ and Opt-In Plaintiffs’ Charges of discrimination filed with the EEOC asserted claims on behalf of themselves and others similarly situated. 58. As a direct and proximate result of the continuing pattern and practice of discrimination and/or disparate treatment of plaintiffs and others similarly situated, and of defendant’s conduct which has had a disparate impact, plaintiffs and others similarly situated have suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, loss of career opportunity, costs of seeking alternate income, expenses incurred in obtaining alternate income, and in other respects, all in an amount yet to be determined. 59. Defendants’ actions were willful, wanton, malicious and in reckless disregard of plaintiffs’ rights and those of others similarly situated. 60. Plaintiffs and Opt-Ins have already incurred and will in the future incur substantial attorneys fees and expenses in prosecuting their claims of discrimination to which fees and expenses plaintiffs are entitled pursuant to 29 U.S.C. §§ 626(b) and 216(b). WHEREFORE, plaintiffs and all Opt-Ins respectfully pray judgment in each’s favor and in favor of all those similarly situated, against defendants Sprint/United Management Company and Sprint Corporation in the form of the Order of this Court: (1) permanently restraining defendants from ever again discriminating against plaintiffs or any other individual on the basis
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of that individual’s age; (2) reinstating plaintiffs to their respective positions with any promotions and pay increases each would have received in the interim; (3) awarding plaintiffs back pay in an amount yet to be determined; (4) in the alternative to reinstatement, awarding plaintiffs front pay in an amount yet to be determined; (5) awarding plaintiffs lost fringe benefits in an amount yet to be determined; (6) awarding plaintiffs liquidated damages in an amount equal to their actual damages; (7) awarding plaintiffs their costs and expenses, including attorneys and expert witness fees, incurred in prosecuting their claims of discrimination; (8) awarding plaintiffs damages to offset unfavorable tax consequences of any award, including attorneys fees; and (9) awarding such other and further relief as the Court deems just and proper.
COUNT III – ADA RETALIATION 61. Plaintiffs hereby incorporate by reference each and every allegation and averment above as though fully set forth in Count III herein. 62. Defendants retaliated against Plaintiff Williams, in violation of 42 U.S.C. § 12203, after she “participated . . . in an investigation” by being interviewed by counsel for defendants in connection with a disability discrimination lawsuit filed by a former co-worker, by (a) denying Williams promotions; (b) giving Williams an unfavorable performance appraisal; (c) targeting Williams for termination and/or layoff; and (d) terminating Williams on March 13, 2002. 63. Defendants’ actions were intended to coerce, intimidate, threaten or interfere with the exercise or enjoyment by Williams of rights granted her and/or protected by the Americans with Disabilities Act, 42 U.S.C. §§ 12101, et seq., in violation fo the provisions of 42 U.S.C. § 12203. 64. As a direct and proximate result of the continuing pattern and practice of
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retaliation directed toward her or disparate treatment of her and of defendants’ termination of her, Plaintiff Williams has suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, loss of career opportunity, costs of seeking alternate income, expenses incurred in obtaining alternate income, pain and suffering, future medical expense, mental anguish, emotional distress, loss of enjoyment of life, and in other respects, all in an amount yet to be determined but not less than Seventy-Five Thousand Dollard ($75,000.00).
65. Defendants’ actions were willful, wanton, malicious and in reckless disregard of Plaintiff Williams’ rights; were motivated by evil motive or reckless indifference to the harm that they might inflict upon Williams or amounted to gross negligence.
66. Plaintiff Williams has already incurred and will incur in the future substantial attorneys fees and expenses incurred in prosecuting this action, which fees and expenses are recoverable by virtue of 42 U.S.C. §§ 12117(a) and 12205, and 42 U.S.C. § 2000e-5(k).
WHEREFORE, plaintiffs respectfully pray judgment in each’s favor and in favor of all those similarly situated, against defendants Sprint/United Management Company and Sprint Corporation in the form of the Order of this Court: (1) permanently restraining defendants from ever again discriminating against plaintiff or any other individual, for engaging in protected activity under the Americans with Disabilities Act; (2) reinstating plaintiff to her former position (3) awarding plaintiff back pay in an amount yet to be determined, but not less than seventy-Five Thousand Dollars ($75,000.00); (4) in the alternative to reinstatement, awarding plaintiff front pay in an amount yet to be determined; (5) awarding plaintiff lost fringe benefits in an amount yet to be determined; (6) awarding plaintiff compensation for physical injury, pain and suffering, future medical, mental anguish, emotional distress, loss of enjoyment of life, and other categories of actual damage, each in an amount yet to be determined but not less than seventy-Five
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Thousand Dollars ($75,000.00); (7) awarding plaintiff punitive damages in the amount of
$1,000,000.00 (One Million Dollars) or such other amount as a jury may deem appropriate;(8)
awarding plaintiff damages to offset unfavorable tax consequences of any award, including
attorneys fees; and (10) awarding such other and further relief as the Court deems just and
proper.
THE POPHAM LAW FIRM, P.C.
By: s/ Dennis E. Egan DENNIS E. EGAN, Bar No. 70672 BERT S. BRAUD, Bar. No. 14223 STEPHEN J. DENNIS, Bar. No. 12453 323 West 8th Street, Suite 200 Kansas City, Missouri 64l05 Telephone: (8l6) 22l-2288 Telecopier: (816) 22l-3999
KLAMANN & HUBBARD, P.A. JOHN KLAMANN, Bar. No. 10190 DIRK L. HUBBARD, Bar. No. 15130 7101 College Blvd., Suite 120 Overland Park, Kansas 66210 Telephone: (913) 327-7600 Telecopier: (913) 327-7800
THE MEYERS LAW FIRM, P.C. MARTIN M. MEYERS, Bar No. 14416 ANDREW J. McCUE 222 West Gregory, Suite 340 Kansas City, Missouri 64114 Telephone: 816-444-8500 Telecopier: 816-444-8508
WHITE, ALLINDER, GRAHAM & BUCKLEY, LLC GENE P. GRAHAM, JR. DEBORAH J. BLAKELY, Bar No. 19010 19049 E. Valley View Pkwy, Ste. C Independence, MO 64055 Telephone: 816-373-9080
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Telecopier: 816-373-9319 19

HUMPHREY, FARRINGTON & McCLAIN KENNETH B. McCLAIN 221 West Lexington, Suite 400 P. O. Box 900 Independence, MO 64051 Telephone: 816-836-5050 Telecopier: 816-836-8966
AARP FOUNDATION LITIGATION DANIEL B. KOHRMAN THOMAS W. OSBORNE LAURIE A. McCANN 601 E. Street, NW Washington, DC 20049 Telephone: 202-434-2060 Telecopier: 202-434-6424
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was filed electronically and notice of such filing was made electronically to defense counsel pursuant to the ECF Rules of the US District Court for the District of Kansas on November 14, 2005:
John J. Yates Philip R. Dupont Husch & Eppenberger 1200 Main St., Suite 1700 P.O. Box 26006 Kansas City, Missouri 64105
Christine F. Miller Harry B. Wilson, Jr. James F. Monafo Tamara M. Spicer Husch & Eppenberger 190 Carondelet Plaza, Suite 600 St. Louis, Missouri 63105-3441
David M. Eisenberg Baker Sterchi Cowden & Rice, L.L.C. 2400 Pershing, Suite 500
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Kansas City, Missouri 64108-2533
Chris R. Pace Stephany Newport Sprint Corporation 6450 Sprint Parkway Overland Park, KS 66251
ATTORNEYS FOR DEFENDANT

s/ Dennis E. Egan Dennis E. Egan

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 Exhibit 1
MASTER FULL AND FINAL SETTLEMENT AGREEMENTOF ALL CLAIMS (Amended) Introduction
This Full and Final Settlement Agreement of All Claims (Amended) ("Settlement Agreement") is entered into on May 25, 2007 on behalf of Named Plaintiffs Shirley Williams, John Borel, Steven Constance, Terry Cocherl, Sharon Herren, Carol Kippes, Bernard Mayse, Sharon Miller, David Molz, Peggy Sturgess, Yvonne Wood-Olson, and all other Opt-In Plaintiffs who have filed a Consent to Join this Action and who have not withdrawn from or been dismissed from the Action as hereinafter defined (collectively "Plaintiffs"), and Defendant Sprint/United Management Company ("Defendant" or "Sprint") in the matter of Shirley Williams v. Sprint/United Management Company, Civil Action File No. 03-2200-JWL, pending in the United States District Court for the District of Kansas (the "Action,,).1
In their April 23, 2003 Complaint, and Amended Complaint filed July 2, 2004, Plaintiffs alleged that Defendant had violated the Age Discrimination in Employment Act,
29 U.S.C. § 621, et seq. (the "ADEA"), by selecting employees for reduction-in-force
based on their age in reduction-in-force terminations that occurred on or after October 1, 2001, and on or before March 31, 2003. Plaintiffs sought a declaratory judgment that Defendant engaged in willful age discrimination, a permanent injunction against such discrimination, reinstatement to the Plaintiffs' former positions with all seniority, pension
1"Named Plaintiffs" in this agreement shall refer to Shirley Williams as well as those persons who have filed the following actions consolidated with the Williams matter: John Borel (Case #042008-JWL); Steve Constance (Case # 03-251 O-JWL), Terry Lee Cocherl (Case #04-2273-JWL), Sharon Herren (Case #04-2163-JWL); Carol Kippes (Case #04-2147-JWL); Bernard Mayse (Case #04-2485-JWL); Sharon Miller (Case #04-2003-JWL); David Molz (Case #04-2137-JWL), Peggy Sturgess (Case #03-2449-JWL); and Yvonne Wood-Olson (Case #03-2384-JWL).

and other benefit rights or front-pay, back-pay and other incidental monetary remedies, interest, liquidated damages, and attorneys' fees and costs. On August 12, 2005, Plaintiffs filed a Second Amended Complaint adding an additional claim that Defendant's Alpha LINK performance management system had a disparate impact upon employees age 40 and older. Defendant completely denied each of Plaintiffs' claims in the Action, denied Plaintiffs were entitled to any relief, and denied that the Action could properly be maintained as a collective action under § 7(b) of the ADEA, 29 U.S.C. § 626(b).
Plaintiffs sought a Court Order to send notice to a class of allegedly similarlysituated present and former employees of Sprint. On July 2, 2004, the Court preliminarily permitted Plaintiffs to proceed as a collective action including all nonexecutive, exempt (Grade 71-79) and non-exempt (Grade 38-41) former employees of Sprint/United Management Company who were (a) terminated between October 1, 2001 and March 31, 2003 as part of a reduction-in-force and (b) were age 40 or older on their last day worked at Sprint. After notice was issued, there were 1697 individuals who filed Consent to Join forms prior to the Court's deadline for pursuing such a claim (or who were granted leave to file after that deadline), and who subsequently neither were dismissed from the Action nor withdrew from the Action.
Plaintiffs recognize that their ability to recover all or part of the relief sought in this Action is subject to numerous risks, including but not limited to the following: (i) the Court may decertify the Collective Action; (ii) the Court may enter summary judgment in Defendant's favor on some or all of Plaintiffs claims; (iii) the Court or jury may determine Plaintiffs are not entitled to recover for their claims; (iv) the Court or jury may determine that some or all of the Plaintiffs are not entitled to damages or are entitled to an amount
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of damages less than the amount sought by Plaintiffs; (v) the Court may determine under 29 U.S.C. § 623(f) that the act or omission giving rise to the Action was lawful; (vi) the Court or jury may determine that any alleged violation of the ADEA was not willful within the meaning of 29 U.S.C. § 626(b); and (vii) the Court of Appeals may determine that the Action could not properly be maintained as a collective action within the meaning of 29 U.S.C. § 626(b) for the claims.
Defendant recognizes that it is also subject to numerous risks in this case, including, but not limited to, the following: (i) a jury could determine that it violated the Plaintiffs' rights regarding their claims and award full relief including liquidated damages; and (ii) the Court of Appeals could affirm this recovery.
Accordingly, in order to avoid the uncertainty, burdens, and expense of further discovery and litigation, and without admission or finding of liability or wrongdoing on the part of Defendant, such being expressly denied by Defendant, Plaintiffs and Defendant have determined that it is in the best interests of the Parties to resolve the claims asserted in the Action on the following terms and conditions:
1. Definitions: a. "Action" refers to the matter of Shirley Williams v. Sprint/United
Management Company, Case No. 03-2200-JWL, pending in the United States District Court for the District of Kansas and those matters consolidated Williams identified in footnote 1 above.
b. "Final Order" means the Order finally confirming this Settlement Agreement, as more fully described in Paragraphs and 6(g) below.
3

c. "Plaintiffs" means collectively those individuals as defined in the first

paragraph of this Agreement, including Named Plaintiffs and Opt-In Plaintiffs who

are included in the lists attached as Exhibit A-2, whether or not they fall within the

definition of the class of allegedly similarly-situated present and former

employees of Sprint.

d. "Named Plaintiff" and "Named Plaintiffs" mean those individuals

defined in footnote 1 above.

e. "Opt-In Plaintiff" and "Opt-In Plaintiffs" mean persons who have filed

a Consent to Join this Action, who have not withdrawn from or been dismissed

from the action as of May 1, 2007.

f.

"Plaintiffs' Counsel" means: Dennis Egan, Bert Braud and Steve

Dennis, and Claudio Molteni of The Popham Law Firm, P.C., John Klamann and

Dirk L. Hubbard of Klamann & Hubbard, P.A., Marty Meyers, Andy McCue, and

Brian DeFrain of The Meyers Law Firm, P.C., Gene Graham and Debbie Blakely

of White, Allinder, Graham & Buckley LLC, Ken McClain, J'Nan Kimak, and

Danny Thomas of Humphrey, Farrington & McClain, P.C., Thomas William

Osborne, Daniel B. Kohrman and Laurie A. McCann of the AARP Foundation

Litigation, and any other lawyers or firms associated with them and their

respective firm in the representation of Plaintiffs in this Action.

g. "Release" means the release of claims in the forms annexed hereto

as Exhibits B-1 (Named Plaintiffs) and B-2 (Opt-In Plaintiffs).

h. "Settlement Administrator" means Settlement Services, Inc., P. O.

Box 1657, 2032-D Thomasville Road, Tallahassee, Florida 30302.

4

i.

"Sprint" or "Defendant" means Sprint/United Management

Company, and any of its affiliated or related companies and Embarq.

j.

"Sprint's Counsel" means John J. Yates, Christine Miller, Phil

Dupont, James Monafo and Patrick Gavin of the firm of Husch & Eppenberger,

LLC, and Hunter R. Hughes, J. Timothy McDonald and Ashley R. Hurst of Rogers

& Hardin LLP, and any other lawyers or firms associated with Husch &

Eppenberger, LLC or Rogers & Hardin LLP in the representation of Defendant in

this Action.

2. Notice to Potential Opt-Ins: Notice of this Action was mailed by Plaintiffs'

Counsel in July and August 2004 to the persons on the list attached hereto as Exhibit

A-1 and of those the 1697 who filed Consent to Join Forms and who have not

subsequently withdrawn or been dismissed from the Action are attached as Exhibit

A-2.

3. Release of Claims and the Final Order as a Judgment of Dismissal with

Prejudice by the Court: The Final Order shall include a judgment of dismissal with

prejudice of (a) the Williams complaint, the complaints of each of the Named Plaintiffs

identified in footnote 1 above and the complaint of Carolyn Selberg (Case # 04-2238-

JWL); (b) any and all pattern-or-practice or disparate impact claims of all Named

Plaintiffs and anyone who opted-in to this action or his or her estates, (c) any individual

disparate treatment claims of any of the Named Plaintiffs and any non-withdrawing Opt-

In Plaintiff, or his or her estate, which related to terminations by Defendant in a

reduction-in-force (i) within the period of October 1, 2001 through March 31, 2003, or (ii)

with respect to Opt-In Plaintiffs Carl T. Alexander, Bonnie B. Balliet, Janette H. (Darmer)

5

Blackmon, Christie B. Carrico, Debra R. Davis, A. Ron Evangelista, Emily H. Fong, Earlene Gillesie, Ronald Keith Harper, Husain A. Hasham, Edward F. Hassman, Ronald D. Havens, Kristine M. Lehane, Donna S. Mackey, Terri Morrow-Tansey, Molly R. Parker, Douglas Wayne Simerly, Juliette A. Stevens, Thea I. Straite, Yuk-Wa Suen, John Scott Turik, and Eddi Wu, irrespective of the date of their termination by Sprint so long as that termination took place before the effective date of this Agreement. Defendant is also released from these claims by Plaintiffs and Plaintiffs' counsel, and Defendant is also released from any other claims included within the Releases pursuant to Paragraph 5(d).
4. Settlement Payment: In full and final settlement of all claims that were or could have been asserted in the Action, as well as those other claims released according to the Releases attached hereto as Exhibits B-1 and B-2 and as executed by a Plaintiff pursuant to Paragraph 5(d), and subject to the terms and conditions set forth in this Agreement, Defendant shall pay the total sum of Fifty Seven Million Dollars ("Settlement Payment"), less any amounts as specified in Paragraphs 6(d) and 10, plus the administrative costs of the Settlement Administrator designated in this Agreement. In no event will Defendant be obligated to make any additional paymentto or for Plaintiffs and/or Plaintiffs' Counsel other than the Fifty Seven Million Dollars less any amounts as specified in Paragraphs 6(d) and 10 and the administrative costs of the Settlement Administrator as designated in this Agreement. The Settlement Payment shall be allocated as follows:
a. Payments to Plaintiffs: At or before the time of the distribution of payments under Paragraph 9, and approval of the Court in the Final Order of the
6

escrow fund as a Qualified Settlement Fund under !.R.C. Reg. § 1.468.B, the total gross sum of $35,977,500.00, less any amounts as specified in Paragraphs 6(d) and 10, will be deposited in the Qualified Settlement Fund administered by the Settlement Administrator. This sum shall be available to be allocated to Plaintiffs who have either executed a Release or negotiated a check with the Release attached as provided for in Paragraph 5(d) in the manner set forth in Paragraph 5(a) of this Agreement, less required with holdings. This sum shall be paid in the manner set forth in Paragraph 9 of this Agreement and the Settlement Administrator shall prepare and distribute the 1099 and W-2 forms and any applicable state or local law forms to plaintiffs with copies to Defendant.
b. Payment of Attorneys' Fees. Costs. and Expenses: The total gross sum of $21,022,500.00, which includes $1,650,000.00 as costs and expenses and $19,372,500.00 (or such amount as otherwise approved by the Court) as attorneys' fees, less any amounts as specified in Paragraph 6(d), shall be paid to Plaintiffs' Counsel as attorneys' fees, costs and expenses. Sprint will issue the appropriate Form 1099 (and any applicable State law forms) to Plaintiffs' Counsel's law firms in this amount for this payment, and Forms 1099 (and any applicable State law forms) to the non-withdrawing plaintiffs for their proportionate shares of the attorneys' fees paid. Defendant agrees that it will not oppose Plaintiffs' Counsels' right to attorneys' fees, costs, and expenses from the Settlement Payment up to the amount set forth in this Paragraph 4(b). Plaintiffs and Plaintiffs' Counsel represent and warrant that they will seek no more than $21,022,500.00 in attorneys' fees, costs or other expenses less any amounts
7

specified in Paragraph 6(d) and that they have no other claims for attorneys' fees, costs, or expenses. 5. Distributions to Plaintiffs:
a. Distribution to Non-Withdrawing Plaintiffs: Defendant shall distribute $1,700,000.00 (One Million Seven Hundred Thousand Dollars) to the Named Plaintiffs, and $34,277,500.00 to the Opt-In Plaintiffs, less any deductions called for in Paragraph 6(d), to those Plaintiffs and Opt-In Plaintiffs who do not withdraw from this Action in lieu of accepting this settlement and who execute and return (or are deemed to have executed and returned) a Release pursuant to Paragraph 5(d) in accordance with the amounts reflected on the list of payments provided pursuant to Paragraph 5(b). The amount on the list provided pursuant to Paragraph 5(b), along with the portion of attorneys' fees and costs allocable to each Plaintiff, shall be the total consideration a Plaintiff shall receive for the dismissal of his or her claim in this action and the execution of his or her individual release.
b. Provision of Information Regarding Payments to Plaintiffs: Plaintiffs' Counsel will provide Defendant and the Settlement Administrator with an electronic file reflecting the amount of payment each Plaintiff and Opt-In Plaintiffs is eligible to receive as reflected in Paragraphs 5(a) above and will provide a copy of this file to the Court upon request.
c. Payment of Taxes, Filing of IRS Forms: The Settlement Administrator shall make all required deductions and tax payments on 50% of the sums paid to the Named Plaintiffs and Opt-In Plaintiffs and shall make all
8

required filings on all sums paid to the Named Plaintiffs and Opt-In Plaintiffs with the Internal Revenue Service and any state or local tax authorities. The Settlement Administrator will send all applicable tax reporting forms (e.g., W-2, W-9, 1099 and any applicable State or local forms) to the addresses provided on the Release to all Named Plaintiffs and Opt-In Plaintiffs who timely execute and return a Release. Fifty percent of the payment to each Plaintiff shall be paid as wages and reported on a federal W-2 form and any applicable state or local form, with the remaining 50% being reported on federal Form 1099 and any applicable state form. The employer portion of payroll taxes (FICA, FUTA, and applicable state or local payroll taxes) shall be paid by Defendant. Beyond payment of its share of such payroll taxes, Defendant shall have no liability or reporting obligation and is hereby fully indemnified by each Plaintiff to the extent Defendant bears any expense whatsoever related to the failure of that particular Plaintiff to timely and properly pay his/her portion of the applicable taxes. Nothing in this paragraph 5(c) shall act to limit Defendant's right or obligation to issue such other tax reporting documentation as may be necessary to insure that Defendant complies with state and federal tax law.
d. Releases: No Named Plaintiffs and Opt-In Plaintiffs shall receive a payment pursuant to this Agreement unless he or she has executed and returned the appropriate Release in the form annexed hereto as Exhibit B-1 or B-2 or negotiated a check with a Release attached thereto in the form attached hereto as Exhibit B-1 or B-2, which check shall reflect that negotiating that check shall act as and constitute the execution of the Release attached thereto.
9

6. Notification Procedure a. Preliminary Approval of Notice: On the date this Agreement is
executed by the Parties, the Parties shall confer with the Court and file a Joint Motion or Stipulation for an Order Preliminarily Approving Settlement and Authorizing Issuance of Notice of Settlement (a copy of the Proposed Order is attached hereto as Exhibit C) thereby advising the Court of the gross sum payable to Named Plaintiffs and Opt-In Plaintiffs and Plaintiffs' Counsel which sum shall be subject to deductions provided for herein and the Court's approval. The submission will also seek approval of Settlement Services, Inc. as the "Settlement Administrator." The Joint Motion will also seek the Court's entry of an Order, inter alia, preliminarily confirming this Settlement Agreement, establishing a date not less than 90 days after the date of entry of the Order for a confirmation hearing (if the Court deems such hearing necessary), and authorizing the distribution of a Notice of Settlement (in the proposed form attached as Exhibit D), consistent with the terms of this Agreement.
b. Mailing of Notice: The Settlement Administrator shall use its best efforts to mail the Court-approved Notice, along with a Release, a W-9 Form and a Notice regarding this settlement to each Named Plaintiff and Opt-In Plaintiff at his or her last address known by Plaintiffs' Counsel, by first class mail, within fourteen (14) days after entry of an Order by the Court approving the Notice of Settlement. In the event that any Notice mailed by the Settlement Administrator is returned to the Settlement Administrator as undeliverable, the Settlement Administrator will perform a computer database search to locate an accurate
10

address for each Named Plaintiff or Opt-In Plaintiffs whose Notice is returned as undeliverable and where a new reliable address is found, shall within seven days of receipt of the return of the undeliverable first mailing re-send that mailing to the new address. These persons shall hereinafter be referred to as "Second Mailing Plaintiffs."
c. Presumption of Receipt: Except for any mailing that is returned to the Settlement Administrator as undeliverable within fifteen (15) days of its being mailed, the Court will apply a rebuttable presumption that the Notice and Release were received on or before the fifth day of mail delivery of United States first-class mail following mailing.
d. Withdrawal: A Named Plaintiff or Opt-In Plaintiff may withdraw from this Agreement and pursue individual disparate treatment discrimination claims relating to that Plaintiff's termination from Defendant on or after a date October 1, 2001 and on or before March 31, 2003 or a termination outside this period that the Court has permitted to the extent that claim is not released by a waiver signed by that plaintiff. To do so, the Settlement Administrator must receive in writing within thirty (30) days of the postmark date of the Preliminary Order and Notice which the Withdrawing Plaintiff received, notice that the Withdrawing Plaintiff wishes to withdraw from the settlement, except that Second Mailing Plaintiffs' withdrawals must be received no later than thirty (30) days from the postmark date of their second mailing of the Preliminary Order and Notice.
11

A notice of withdrawal must state at a minimum:
I understand that when I consented to join this lawsuit, I executed an agreement in which I expressly agreed to be bound by any settlement of this action. Specifically, I signed a _Consent to Join_ form which contains the following language:
I understand this suit is being brought under the federal Age Discrimination in Employment Act. I have read and I understand the notice accompanying this Consent. As a former employee of Sprint, I hereby consent, agree and opt-in to become a party plaintiff herein and agree to be bound by any settlement of this action or adjudication of the Court.
I hereby further authorize the named Plaintiff herein to retain her counsel of record or select new counsel, as she shall determine in her discretion, and I hereby authorize such counsel to make such further decisions with respect to the conduct and handling of this action including the settlement thereof, as they deem appropriate or necessary.
Nonetheless, I also understand that the parties, as part of their settlement, have agreed to permit me to withdraw from the settlement with certain restrictions and, if I choose to do so, to continue to pursue (at my own expense) a new and separate individual action against defendant in the United States District Court for the District of Kansas. Pursuant to this agreement by the parties, I will not be permitted to pursue against defendant claims alleging pattern-or-practice discrimination or claims alleging disparate impact discrimination or to be a part of a collective action with others who have withdrawn from this settlement. However, I will be permitted to pursue against defendant (unless I have signed a separate waiver releasing such claim) an individual claim alleging disparate treatment discrimination on the basis of my age in which I will be able to seek damages relating to the termination of my employment if that termination occurred between October 1, 2001 and March 31, 2003. I understand that if I withdraw the Court will assign a new case number for my claim to proceed as a separate action and will immediately enter a Scheduling Order and set a trial date.
I understand that by withdrawing from the settlement, I will receive no money from the settlement approved by the Court or the Settlement
12

Agreement entered into by the parties.

I further understand that by withdrawing from the settlement and electing to pursue an individual claim of age discrimination, I may ultimately receive less in terms of a monetary settlement than what I would be entitled to receive if I filed a claim under the class monetary settlement procedure in this case. I also understand that by withdrawing from the settlement and electing to pursue an individual claim of age discrimination, I may ultimately receive nothing at all.

I understand that by withdrawing from the settlement, I will not be

permitted to challenge, contest or otherwise dispute in any court at

any time the fairness, validity or enforceability of the settlement,

including the court's approval of the settlement, and that I must

appear in person, or through counsel of my choosing, at the hearing

to be held on

at _ _.M. in the United States

District Court for the District of Kansas, 500 State Avenue, Kansas

City Kansas 66101, for the purpose of establishing the procedures

and schedule that should be followed in my individual action against

defendant.

Finally, I understand that in order to be effective, my Withdrawal Statement must be received by the Settlement Administrator, Settlement Services, Inc., P.O. Box 10583, Tallahassee, FL 30302-2483, no later than thirty (30) days after the postmark date on the envelope in which I received the Notice of Preliminary Confirmation of Settlement Agreement and Dismissal of Collective Action.

Fully aware of the foregoing, I am electing to withdraw from the collective action settlement and pursue my individual separate action against Sprint.

Signature

Printed or Typed Name

Address 13

Date:_ _ _ _ _ _ _ _ _--'--_
The payment amount allocated to any withdrawing Plaintiff pursuant to the Courtapproved distribution shall be subtracted from the obligation of Defendant as specified in Paragraph 4(a) and Defendant's payment obligation to Plaintiffs' Counsel as set forth in Paragraph 4(b) shall be reduced by the percentage equal to the amount allocated to withdrawing Plaintiffs divided by $57 Million. Without regard to the withdrawal of any Named Plaintiff or Opt-In Plaintiff, this Agreement and the Final Order of the Court shall act to dismiss with prejudice the pattern-orpractice claims and the disparate impact claims of Named Plaintiffs or Opt-In Plaintiffs who ever opted into this Action such that no charge of any Named Plaintiff or Opt-In Plaintiff who ever opted into this Action shall be sufficient as a predicate to piggybacking. A withdrawing Plaintiff may void his/her Notice of Withdrawal up to 8 days prior to the Court's Confirmation Hearing by a written signed statement to the Settlement Administrator clearly stating the desire to void his or her Notice of Withdrawal.
e. Objection Procedure: To object to any term of this Agreement, a Plaintiff ("Objecting Plaintiff), (except as to any dispute as to an alleged miscalculation of the amount to be paid) must not withdraw and must submit a written Objection under oath to the Settlement Administrator at the address stated in the Notice postmarked within thirty (30) days of the postmark date of the Preliminary Order and Notice sent to said Objecting Plaintiff, except that a Second Mailing Plaintiff shall submit his or her Objection to the Settlement Administrator postmarked within thirty (30) days from the postmark date of his or
14

her second mailing of the Preliminary Order. An Objecting Plaintiff must also

appear in person and/or through counsel at the final approval hearing (or such

other date as set by the Court in order to present his/her Objection(s) to the

Court). The Settlement Administrator shall promptly after receipt provide

Plaintiffs' and Defendant's counsel by electronic and United States mail a copy of

such Objection. Plaintiffs' counsel shall file such written Objection with the Court

within five (5) business days of their receipt of such objection from the Settlement

Administrator unless such objection is withdrawn prior thereto. Plaintiffs' Counsel

and/or Defendant's Counsel may submit to the Court any documents and/or

information concerning any Objecting Plaintiff, which they deem appropriate as

admissible and competent evidence of the facts stated therein. Plaintiffs' Counsel

and/or Defendant's Counsel may also seek to depose or take other discovery

from an Objecting Plaintiff concerning the matters set forth in the Objection or any

other matter related in any way to this Settlement. An Objection may be

withdrawn by written, signed notice from the Objecting Plaintiff to the Settlement

Administrator clearly stating the desire to void his or her Objection. The

determination of the Court with respect to any Objections shall be final.

f.

Miscalculation Resolution: Any dispute as to the proper calculation

of a payment allocation pursuant to Paragraph 5(a) shall be made to the

Settlement Administrator who shall then undertake and employ such reasonable

procedures for resolution of the dispute as it may deem proper. The Settlement

Administrator may consider any information provided by the Plaintiff raising an

issue as to proper calculation of payment as well as any information provided by

15

Plaintiffs' Counselor Defendant's Counsel. The decision of the Settlement Administrator as to the appropriateness of the calculation shall be final.
g. Confirmation Hearing: At the final approval hearing, the Court may hear any Objections of Plaintiffs and determine whether to finalize the settlement of the Action. At this hearing, or by written filing if the Court finds no hearing is necessary, the parties shall provide the Court with a status of the number of written releases received, and any other information required by the Court. If the Court thereafter confirms the Settlement Agreement, and if Defendant does not void the Agreement pursuant to Paragraph 8 within three (3) business days following the Confirmation hearing, Plaintiffs' and Defendant's Counsel shall prepare and file with the Court not earlier than three (3) days after, but no later than ten (10) business days of its approval, a Proposed Final Order.
h. No Modification of Terms: Neither the Court nor any reviewing court on direct appeal and/or on writ of certiorari to the Supreme Court of the United States shall have authority to modify the terms of the proposed Settlement without the written consent of the Parties through their counsel. Should any such modification be required by any court, unless the Parties through their counsel consent to such modification in writing, this Agreement shall become null and void. If this Agreement is rendered null and void, it shall be inadmissible and unusable in any court or proceeding regarding any issues whatsoever and shall not be considered a binding settlement and the Parties shall return to their respective positions as of May 1, 2007.
16

i.

Obligation of the Plaintiffs: It shall be the obligation of a Plaintiff

alone to notify the Settlement Administrator if the Plaintiff changes his or her

address. Failure of a Plaintiff to keep the Settlement Administrator informed of

his or her address may result in his or her claim being denied or forfeited.

7. Duties of the Settlement Administrator: The duties of the Settlement

Administrator shall include:

a. Establishing a Post Office box to be used for purposes of

communications to be received by Named Plaintiffs and Opt-In Plaintiffs with

respect to the Settlement Agreement and/or any related Court Order or Notice.

b. Responding to any written requests seeking procedural information

with respect to this Settlement.

c. Regularly communicating to Plaintiffs' Counsel and Defendant's

counsel any issues it believes may impact the Settlement process.

d. Sending out Notices and Addenda provided for by this Agreement

or the Order(s) of the Court, which shall include, but not be limited to, any

Releases or W-9 Forms to any address (including a second address of any

Plaintiff identified as possibly not having a current address by either Plaintiffs or

Defendant).

e. Sending a Second Notice (and attachments) within three (3)

business days of receipt of a new address for those Plaintiffs whose initial Notices

are returned as undeliverable. In the event the Administrator is unable to obtain a

new address for those Plaintiffs whose First or Second Notices were returned, the

Administrator shall forward a list of such persons to Plaintiffs' Counsel, with a

17

copy to Defendant's Counsel. If Plaintiffs' Counsel are able to locate another

address for any of the Plaintiffs on such list prior to the distribution of checks

pursuant to Paragraph 9 of the Agreement, they will provide those addresses to

the Administrator which will send the checks for those individuals, together with

an attached release, in the manner described, and with the same effect, in

Paragraph 9(a).

f. Sending Plaintiffs' Counsel and Defendant's counsel all Withdrawal

Notices and/or Objections by .pdf file and United States mail on the day they are

received by the Settlement Administrator.

g. Preparing checks for each Named Plaintiff and Opt-In Plaintiff who

should be paid pursuant to the terms of the Settlement Agreement, receiving W-9

Forms from Plaintiffs and providing that information to Defendant, and preparing

1099 and W-2 Forms to provide to the Federal government (along with any

applicable State or local law forms to any applicable State) as provided for in this

Agreement and to provide copies of those forms to Defendant.

h. Reviewing and deciding upon the correctness of the calculation of the

actual payment to a Plaintiff when such Plaintiff asserts such amount has been

miscalculated and to report that to Plaintiffs' Counsel and Defendant's counsel

upon the Settlement Administrator's decision which is intended by the Parties to

be the final and binding calculation.

i.

Providing updates to Plaintiffs' Counsel and Defendant's counsel on

at least a bi-weekly basis concerning those Plaintiffs who have been sent

settlement checks but have not cashed those checks.

18

j.

Immediately notifying Plaintiffs' Counsel and Defendant's counsel of

anything unusual as well as all objections or withdrawals.

k. Reviewing the Releases for full signatures and no alterations upon

their receipt from Plaintiffs and to provide a copy of each by .pdf and United

States mail to Plaintiffs' Counsel and Defendant's Counsel.

I.

Other duties as are reasonably called for in order to perform its

enumerated obligations hereunder and/or as directed jointly by Plaintiffs and

Defendant.

m. Other duties not inconsistent with the terms hereof as directed by the

Court.

8. Defendant's Conditional Right to Void the Agreement: If more than 75 of

the Plaintiffs timely withdraw pursuant to Paragraph 6(d), Defendant shall have the

unilateral right to declare this Agreement void up until three (3) business days after the

Confirmation Hearing, but in any event prior to entry of the Final Order. Any Court

orders related to this Agreement would then be vacated by the Court, which would return

the parties to their respective positions as of May 1, 2007, and this Agreement and any

documents associated with it shall be inadmissible and unusable in any court or

proceeding regarding any issues whatsoever and shall not be considered a binding

settlement and the parties shall return to their respective positions as of May 1, 2007.

9. Distribution of Payments: Upon expiration of the time for appeal of the

Final Order:

a. If no appeal has been timely filed: Within ten (10) business days

after the Final Order becomes final and non-appealable Defendant shall pay to

19

Plaintiffs' Counsel the attorneys' fees, costs and expenses as set forth herein in Paragraph 4(b) minus any amounts calculated as set forth in Paragraph 6(d). Within ten (10) business days after the time period referred to in the prior sentence, the Settlement Administrator shall mail checks to Plaintiffs who timely submitted executed Releases, for the payment amount specified in Paragraph5(a) via first class mail to the addresses provided on their Releases. For all Plaintiffs who did not withdraw (and where at least one such mailing was not returned to the Settlement Administrator as undelivered) but also did not timely submit an Executed Release, the Settlement Administrator shall mail checks for the payment amount specified in Paragraph 5(a) via first class mail to the addresses provided on the Releases to Plaintiffs with a Release attached to the check, which Release shall be deemed executed by virtue of the negotiation of the check sent to the Plaintiff, on a date no later than six (6) months after entry of the Final Order. Defendant agrees to honor payments mailed to Plaintiffs for a period of six (6) months from the date on the check.
b. If an appeal is filed: Upon expiration of the appeal process, if the Final Order is upheld without modification, within ten (10) business days after entry of the mandate of the appellate court or the final disposition of any petition for writ of certiorari, the Settlement Administrator shall perform the acts detailed in Paragraph 9(a). If the Final Order is not upheld in any respect, this Agreement shall be null and void and Defendant shall pay no amounts to Plaintiffs or Plaintiffs' counsel, but shall pay the expenses of the Settlement Administrator
20

subject to its right to seek reimbursement for these as costs should Defendant prevail in any proceedings in the Action. 10. Untimely Filed Releases or Unclaimed Funds: Any funds allocated in Paragraph 5(a) above that are not paid due to any Plaintiff's failure to cash a settlement check within six (6) months of its issuance or because the mailing of such a check was returned as undeliverable (hereinafter "Unclaimed Funds") shall be utilized to reimburse Defendant for the fees of the Administrator, and if any funds remain thereafter, to contribute those funds to the March of Dimes. 11. Confidential Information and Its Return. Plaintiffs and their counsel will not permit any other person to review any documents designated Confidential or any deposition testimony/exhibits taken in this Action even if that person secures an Order permitting them to modify the protective order entered in this action to permit such person to see such documents, except as such disclosure may hereafter be compelled by a final order of a court of competent jurisdiction following the exhaustion of any appeals, rehearings and petitions for writ of certiorari. Nor will Plaintiffs' Counsel disclose or use any information relating in any way to or about those documents except in the representation of the Plaintiffs listed in Exhibit 8-2 in this Action. Within 30 days after the date requiring distribution of payments under paragraphs 9(a) or 9(b), Plaintiffs and their counsel, and other individuals to whom the information was provided under the terms of the Protective Order entered here, will return to Defendant's counsel all copies of inadvertently produced privileged documents, all original and copies of all CDs provided during discovery containing documents and/or data produced during discovery, and will file with the Court a
21

certification that all electronic and hard copies of Defendant's confidential documents and data have been deleted and/or destroyed and that all copies of such documents and data have been retrieved from experts and consultants retained by Plaintiffs and their counsel, or others with whom the documents and data have been shared, and/or deleted or destroyed by them. Additionally, all non-confidential documents (and any copies thereof) produced by each party shall be returned to that party by anyone who has such a document or its copy, or the party that has such a document may execute an affidavit to be filed with the Court in lieu of return which shall affirm under oath a) that after a reasonably diligent search, all such documents have been destroyed and b) that any such documents subsequently located shall immediately be destroyed and shown to no other person. That return of the non-confidential documents or the tender of the affidavit must be made within the same time period of the obligations set forth above for documents marked as confidential. Plaintiffs and their counsel agree to comply with these provisions for all documents designated for use in Bolton v. Sprint/United Management Co., No. 05-2361-JWL, within the same time period of the obligations set forth above.
12. Shut Down of Web Page: Within three (3) days after the Court enters its Order Preliminarily Approving Settlement and Authorizing Issuance of Notice of Settlement, Plaintiffs and their counsel will shut down their webpage pertaining to this litigation, and advise Defendant's counsel when this has occurred.
13. Non-admission and Non-publicity: Nothing in this settlement shall be construed as a finding or admission that Defendant has violated the ADEA or any other law, statute or regulation, or committed any wrongdoing whatsoever, and
22

Defendant specifically denies that it has committed any such violation or wrongdoing. No party or Counselor the AARP Foundation shall directly or indirectly publicize the terms of this settlement by issuance of a press release or otherwise, beyond stating that "the matter has been resolved by Agreement," except that upon independent inquiry by the media, Plaintiffs and their Counsel may explain that while the Plaintiffs believe strongly in their claims, the resolution provides a recovery of on average over $20,000.00 per Plaintiff, that the Plaintiffs risked recovering nothing if the matter was not resolved at this stage and that the resolution permits the Plaintiffs to focus on their careers.
Upon independent inquiry by the media, Defendant may explain that it has always rejected plaintiffs' claims in this lawsuit and notes that it has not been found in violation of any laws or done anything wrong, and in fact, Sprint's workforce became older, not younger, during the time period at issue. Sprint elected to settle this case for one reason: so that it can continue to focus on serving its customers.
Each Plaintiff shall also be permitted to disclose the terms of this Agreement for purposes of securing legal or financial advice relating to any payment, or for the purposes of communicating with their family members as a further exception to the second sentence in this paragraph. Plaintiffs or opt-ins who publicize the settlement to the media, directly or indirectly, may be subject to loss of entitlement to some part or all of the payments under the settlement in an amount to be determined by the Court.
23

13. Choice of Law: Except to the extent governed by federal law, this Agreement and all payments made pursuant to it shall be governed by the laws of the State of Kansas, without regard to choice of law provisions.
14. Rules of Construction: This Agreement shall be construed as a whole, according to its fair meaning. It shall not be construed strictly for or against any party. Unless the context indicates otherwise, the term "or" shall be deemed to include the term "and" and the singular or plural number shall be deemed to include the other. Captions are intended solely for convenience of reference and shall not be used in the interpretation of this Agreement.
15. Duty to Support and Defend the Settlement Agreement: Plaintiffs who neither withdraw from nor object to this Agreement, Plaintiffs' counsel, Defendant and Defendant's counsel each agree to abide by all the terms of this Agreement in good faith and to support it fully, and shall use their best efforts to defend this Agreement from any legal challenge, whether by appeal or collateral attack, or any other litigation filing which may reduce any of the consideration that either party would receive as a result of this Agreement (monetary or otherwise).
16. Execution in Counterparts: The parties agree that this Agreement may be executed in counterparts, each of which shall be deemed to be an original and all of which together shall be deemed to be part of the same Agreement.
17. Jurisdiction: The parties agree that the United States District Court for the District of Kansas shall have continuing jurisdiction over any matters relating to or arising out of this Agreement.
24

Approved as to form and content, this
BY:~t, ~~ THE POPHAM LAW FIRM'% Dennis E. Egan Bert S. Braud Steve Dennis Claudio E. Molteni 323 West 8th Street, Suite 200 Kansas City, MO 64105

n 41 -r(
( , day of
I

,2007.

LLC. :iiE~R'

Ph~ ipJR. a~;ont
Patrick M. Gavin 1200 Main Street, Suite 2300 Kansas City, MO 64105

Christine F. Miller James F. Monafo 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105

THE MEYERS LAW FIRM, L.C.
/bAA~£~ _~_
B -Mf-:t-rt-iny -M-.M-e~ye: =-r-s-L~ .---#--Andrew H. McCue Brian D. DeFrain 222 W. Gregory Boulevard, Suite 340 Kansas City, MO 64114
LLiNDER, GRAHAM & , L.L

ROGERS & HARDIN, L.L.P.

BY:~SZ~ ~."jS~Qf;(

Hunter R. Hughes

o.to- t.

J. Timothy McDonald ~~.

Ashley R. Hurst

2700 International Tower

229 Peachtree Street, N. E.

Atlanta, GA 30303

Counsel for Defendant

25

HUMPHREY, FARRINGTON &

MC~
By:

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Kenneth B. cClaln

J'Nan Kimak

Daniel A. Thomas

221 West Lexington, Suite 400

Independence, MO 64051

AARP FOUNDATION LITIGATION
By:_ _ _ _ _ _ _ _ _ _ _ __ Thomas William Osborne Daniel B. Kohrman Laurie A. McCann 601 E. Street, NW Washington, DC 20049
Counsel for Plaintiffs

26

05/16/2007 WED 13:07 FAX 2024346424

LITIGATION

HUMPHREY, FARRINGTON & McCLAIN, P.C.
By:_ _ _ _ _ _ _~-----­
Kenneth B. McClain J'Nan Kimak Daniel A. Thomas 221 West Lexington, Suite 400 Independence, MO 64051
AARP FO DATION LITIGATION
By: au~A: NC(1~.rl-
homas William Osborne Daniel B. Kohrman Laurie A. McCann 601 E. Street, NW Washington, DC 20049
Counsel for Plaintiffs

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26

Named Plaintiffs
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Bernard Mayse Sharon Miller

Steve C-o, nstance

haron Herren Carol Kippes

Yvonne Wood-Olson

27

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Greg

8172381662

THE MEYERS LAW FIRM, LC ~ 18177500838P500~

p.3 NO. 50? (;1005

Named Plaintiffs Shirley Williams John Borel Steve Constance Terry Lee Cocherl Sharon Herren

Bernard Mayse Sharon Miller David Molz Peggy SbJrgess Yvonne Wood-Olson

27

Named Plaintiffs Shirley Williams John Borel Steve Constance Terry Lee Cocherl Sharon Herren Carol Kippes

B rnard Mayse Sharon Miller David Molz Peggy Sturgess Yvonne Wood-Olson

27

Named Plaintiffs Shirley Williams John Borel Steve Constance Terry Lee Cocherl Sharon Herren Carol Kippes

Bernard Mayse
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Sharon Miller
David Molz
Peggy Sturgess
Yvonne Wood-Olson

27

Named Plaintiffs Shirley Williams John Borel Steve Constance Terry Lee Cocherl . Sharon Herren Carol Kippes

Bernard Mayse Sharon Miller David Molz Peggy Sturgess
......

27

I

Sprint United Management Company

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Sue Haller, Viceresidef1t

28

WAIVER OF ATTORNEY'S LIENS The undersigned attorney for plaintiff Bernard W. Mayse hereby releases and waives all claims that she, or any attorney of the law firm of Randles, Mata & Brown, LLC, or the Law Offices of Sarah A. Brown, may have for attorney's fees, costs, or expenses relating to her representation of Bernard W. Mayse in connection with her representation of him in his claims against Sprint/United Management Company in Bernard Mayse v. Sprint/United Management Company,(Civ. No. 04-2485-JWL), and/or in connection with Mr. Mayse's participation in Shirley Williams v. Sprint/United Management Company, (Civ. No. 03-2200-JWL) and states that her fees, costs or expenses in connection with this representation of Mr. Mayse will be satisfied with payments from the settlement proceeds of Mr. Mayse claim and/or her arrangements with the counsel for the plaintiffs in the Williams litigation. With respect to the payment to be made to her out of the settlement proceeds in the above-captioned case, the undersigned agrees to indemnify defendant Sprint/United Management Company for any amount claimed by the law firm of Randles, Mata & Brown, LLC, the Law Offices of
Sarah A. Brown, and/or any other attorney, law firm, or other entity claiming an interest
in said payment.
wn Ran I ,Mata & Brown, LLC 4 W. 34th St., Suite 623
ansas City, MO 64111 Telephone: (816) 931-9901 Facsimile: (816) 931-0134 sarah@rmblawyers.com
29

 
 Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

2007 WL 2694029 Only the Westlaw citation is currently available.
United States District Court, D. Kansas.
Shirley WILLIAMS, et al., Plaintiffs, v.
SPRINT/UNITED MANAGEMENT COMPANY, Defendant.
No. 03–2200–JWL. | Sept. 11, 2007.
Attorneys and Law Firms
The Meyers Law Firm, LC, Dirk L. Hubbard, John M. Klamann, Klamann & Hubbard, P.A, Kansas City, MO, Daniel B. Kohrman, Laurie A. McCann, Thomas W. Osborne, AARP Foundation Litigation, Washington, DC, Dennis E. Egan, Stephen J. Dennis, Bert S. Braud, The Popham Law Firm, P.C., Kansas City, MO, Gene P. Graham, Jr., Deborah J. Blakely, White, Allinder, Graham & Buckley LLC, Kenneth B. McClain, Humphrey, Farrington & McClain, Independence, MO, Matthew C. Billips, Miller, Billips & Ates, PC, Atlanta, GA, for Plaintiffs.
Ashley R. Hurst, Hunter R. Hughes, III, J. Timothy McDonald, John Da Grosa Smith, Thomas Joseph Mew, IV, Rogers & Hardin LLP, Atlanta, GA, Chris R. Pace, Stephany J. Newport, Sprint, Overland Park, KS, Christine F. Miller, David L. Schenberg, Gerard K. Rodriguez, Harry B. Wilson, Jr., James F. Monafo, Joseph H. Guffey, Joseph H. Guffey, Tamara M. Spicer, Thomas A. McCarthy, Husch & Eppenberger, LLC, St. Louis, MO, David A. Schatz, Patrick M. Gavin, Robert A. Costello, John J. Yates, Philip R. Dupont, Husch & Eppenberger, LLC, David M. Eisenberg, Baker, Sterchi, Cowden & Rice, L.L.C., Kansas City, MO, for Defendant.
Opinion
ORDER OF FINAL APPROVAL OF SETTLEMENT
JOHN W. LUNGSTRUM, United States District Judge.
*1 This matter is before the Court in connection with the Joint Motion for Final Approval of Settlement filed by the parties, and the Court herewith enters its Order of Final Approval of Settlement for the reasons stated here.

I. BACKGROUND The proposed settlement provides $57 million dollars in monetary relief to the 1,697 member collective action previously certified under the Age Discrimination in Employment Act (“ADEA”). On May 30, 2007, this Court granted preliminary confirmation of the proposed settlement and appointed a settlement administrator. Specifically, the Court found, based on the parties’ joint filing, the Court’s knowledge of the record, and the hearing with the parties, that the terms of the Master Full and Final Settlement Agreement of All Claims (“Settlement Agreement”) appeared to be “reasonable, adequate, fair, and consistent with relevant state and federal law and warrants notice thereof being given to the individual Plaintiffs.” As a result, the Court approved the Settlement Agreement preliminarily and approved the form of Notice and Individual Releases to be sent to all Named Plaintiffs and Opt–In Plaintiffs. The Court’s Order also stayed all further litigation in this matter as of May 1, 2007 pending confirmation of the Settlement, approved of procedures regarding the sending of the Notice, and approved of the procedures for any Plaintiff to object and/or withdraw according to the terms of the Settlement Agreement.
The Settlement Administrator subsequently sent a Court-approved Notice of the proposed settlement to the ADEA Opt–In Plaintiffs. Among other things, the Notice advised the Opt–In Plaintiffs of the settlement terms and the monetary share for each particular Opt–In Plaintiff. It also instructed them of their right to withdraw and/or object to the settlement and provided the specific date for the final hearing on this settlement.
As of the date of the hearing on the Motion for Final Approval, 1,555 of the 1,686 Opt–In Plaintiffs have sent in signed Releases agreeing to the settlement terms. There were seven notices of withdrawal executed by Opt–In Plaintiffs, but each of those withdrawal notices were accompanied by other executed documents that indicated the Opt–In Plaintiff wanted to participate in the settlement. Each of these seven Opt–In Plaintiffs has signed statements voiding their withdrawal and indicating that each did not intend to withdraw but instead wishes to remain in the settlement. As such, no Opt–In Plaintiff has effectively withdrawn from this settlement. Only two Opt–In Plaintiffs have submitted objections to the settlement but, as set forth on the record at the Final Confirmation Hearing and as incorporated herein, those objections are overruled.
1

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

There has been no evidence provided to the Court that suggests that the settlement is anything other than the result of arm’s length negotiations between the parties after extensive litigation, including extensive discovery of Sprint’s policies, practices and statistical data, and other exchanges of information and discussions.
*2 A hearing to consider final approval of the proposed collective action settlement was held on September 10, 2007. Based upon the Court’s observation of this litigation and the filing of the parties, including the Settlement Agreement, the Motion for Final Approval and Exhibits, the objections by Opt–In Plaintiffs Philip Bodine and Ruby Harvey–Burgin, and the parties’ other filings, the Court grants final approval to the Settlement Agreement. This Order, which incorporates the findings and conclusions made by the Court on May 30, 2007, explains the findings and reasoning that support the determination that the settlement is fair, adequate and reasonable and consistent with relevant law. The Court also finds and hold that the releases signed by the Plaintiffs and Opt–In Plaintiffs are in compliance with applicable law, including the Older Workers Benefits Protection Act, 29 U.S.C. § 626(f).
II. STANDARD OF REVIEW In assessing the fairness of this settlement, this Court utilizes the “universal standard” of “fairness, adequacy and reasonableness.” Binker v. Commonwealth of Pennsylvania, 977 F .2d 73 8, 747–48 (3d Cir.1992)(ADEA case). A proposed class action settlement [under Rule 23] should be approved as long as it is “fair, adequate and reasonable and is not the product of collusion between the parties.” Ingram v. Coca–Cola Co., 200 F.R.D. 685 (N.D.Ga.2001)(Title VII class settlement).
In addition to examining the collusion issue, some of the relevant factors the Court may consider in determining whether a settlement is fair, adequate, and reasonable have been enumerated as follows:
(1) the likelihood of success at trial; (2) the range of possible recovery; (3) the point on or below the range of possible recovery at which a settlement is fair, adequate and reasonable; (4) the complexity, expense and duration of litigation; (5) the substance and amount of opposition to the settlement; and (6) the stage of proceedings at which the settlement was achieved.

Bennet v. Behring Corp., 737 F.2d 982, 986 (11th Cir.1984).
The Tenth Circuit expressed these factors in a similar fashion in Rutter & Wilbanks Corp. v. Shell Oil Co., 314 F.3d 1180, 1188–89 (10th Cir.2002):
(1) whether the proposed settlement was fairly and honestly negotiated; (2) whether serious questions of law and fact exist, placing the ultimate outcome of the litigation in doubt; (3) whether the value of an immediate recovery outweighs the mere possibility of future relief after protracted and expensive litigation; and (4) the judgment of the parties that the settlement is fair and reasonable.
III. FINDINGS AND CONCLUSIONS Applying the pertinent factors to this settlement and considering the only two objections, the Court finds that this settlement was fairly and honestly negotiated and is fair, adequate, and reasonable.
A. The Proposed Settlement Was Fairly And Honestly Negotiated No Plaintiff or Opt–In Plaintiff has complained that the proposed settlement was not fairly and honestly negotiated. Indeed, counsel aggressively litigated this case for more than four years. Several hundred depositions were taken or defended, more than 1,000,000 pages of documents were exchanged, and large databases of employment-related information were produced. The Court appointed David J. Waxse, United States Magistrate Judge, and Special Master John Phillips to decide numerous and contentious discovery disputes that arose during the case. At the time a settlement was reached, significant discovery had been conducted and expert reports had been exchanged. The parties were cognizant of the strengths and weaknesses of their respective cases and were preparing for briefing of significant motions relating to pattern and practice and collective action claims. The settlement was negotiated at arm’s length over a protracted period of time. The settlement was fairly and honestly negotiated.
B. The Proposed Settlement Is Fair, Adequate, And 2

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

Reasonable
(1) Likelihood of Success at Trial and Range of Potential Recovery *3 The likelihood of success on the merits is weighed against the amount and form of relief contained in the settlement. That is, the benefit this settlement provides to the Opt–In Plaintiffs should be compared with the likely recovery for the collective action group at trial. This question concerns three factors which are closely related: (1) the likelihood of success at trial; (2) the range of possible recovery; and (3) the point on or below the range of possible recovery at which a settlement is fair, reasonable, and adequate. “This standard often justifies approving settlements that are substantial compromises of the relief that could be obtained through litigation.” Ingram, 200 F.R.D. at 689.
In their filings with the Court, the parties have set forth several of the relative risks facing both Plaintiffs and Defendant that they assessed prior to reaching this settlement. Both parties had risks to evaluate. The next phase in the litigation would have involved significant disputes regarding the strength and validity of each side’s statistical evidence and the propriety of allowing this action to continue to proceed collectively. Plaintiffs produced expert reports identifying statistical evidence of discrimination, while Defendant produced expert reports attacking the assumptions utilized by Plaintiffs’ experts and offering a competing model of analysis that produced no statistical evidence of discrimination. Even if the Court were to conclude that Plaintiffs had produced sufficient evidence to avoid decertification and survive summary judgment on the question of pattern and practice liability, there were risks that Plaintiffs could lose the jury trial on that issue, followed in any event by the risk that some unknown number of Opt–In Plaintiffs would lose their Stage II hearings and receive no compensation at all. See Teamsters v. United States, 431 U.S. 324, 344, 97 S.Ct. 1843, 52 L.Ed.2d 396 (1977) (noting that employer may challenge any particular individual’s entitlement to recovery in Stage II proceeding). In short, the Court finds that serious questions remained to be resolved, which placed the ultimate outcome of the litigation in doubt.
(2) The Complexity, Expense and Duration of Further Litigation The litigation and settlement of this case resulted in the collective action group obtaining a significant benefit. “[C]ases such as this typically take years, if not decades, to resolve to judgment.” Ingram, 200 F.R.D. at 690–91 (citing cases and expert testimony and noting that “a credible projection for litigating this case through class

certification and Stage I and Stage II trials, not to mention multiple opportunities for appeal, is ten years from the date of filing.”). As in Ingram, “each phase of litigation would entail substantial expert costs, attorney time, travel and deposition costs, and other expenses. Trial on the merits would require consideration of complex dueling statistical models. In short, the likely alternative to settlement now is lengthy, burdensome, and expensive litigation.” Id. at 691. The benefit of obtaining relief now, rather than years from now, makes approval of this settlement in the best interests of the collective action group. See id.
(3) The Stage of Litigation at Which the Settlement was Reached *4 As noted above, this case did not settle until both sides had engaged in significant discovery over a four-year period and had developed important issues. The parties actively pursued numerous discovery-related motions and issues. At the time a settlement was reached, the parties were cognizant of the strengths and weaknesses of their respective cases and had the ability to make a reasoned judgment about the merits of the case during settlement negotiations.
(4) The Substance and Amount of Opposition to the Settlement Opposition to this settlement is virtually non-existent. Over 90% of the Opt–In Plaintiffs affirmatively demonstrated their assent to the settlement by returning signed releases endorsing it. All but two of the other 10% of the Opt–In Plaintiffs have agreed to the settlement by forbearing their rights to withdraw or object, effectively electing to retain the benefits of the settlement. Only two Opt–In Plaintiffs objected to the settlement. Those objections were based not on whether the settlement itself is appropriate but on whether the objectors’ portions of the settlement was appropriately calculated. While the number of objectors is “not controlling,” Cotton v. Hinton, 559 F.2d 1326, 1331 (5th Cir.1977), a relatively small number of objectors can be taken as “some indication that the class members as a group did not think the settlement was unfair.” Kincade v. General Tire & Rubber Co., 635 F.2d 501, 506 n. 4 (5th Cir.1981). This concept applies with particular force here.
(5) The Judgment of Experienced Counsel In a case where experienced counsel represent the class, the Court “absent fraud, collusion, or the like, should
3

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

hesitate to substitute its own judgment for that of counsel,” and the “trial court is entitled to rely upon the judgment of experienced counsel for the parties.” Cotton, 559 F.2d at 1330. Indeed, “[t]he endorsement of the parties’ counsel is entitled to significant weight.” UAW v. General Motors Corp., 2006 WL 891151, at *18 (E.D.Mich. Mar.31, 2006).
Both parties were represented by counsel with considerable experience in employment law and complex litigation, including class actions. Given the qualifications of Plaintiffs’ and Sprint’s counsel, which include substantial experience in class action and other complex litigation and employment discrimination cases, the Court has confidence in their collective judgment that the benefits of this settlement outweigh the delay and risk of proceeding to trial.
C. Overruling of Two Objections The only two objections to the settlement are from Opt–In Plaintiffs Philip Bodine and Ruby Harvey–Burgin. Mr. Bodine appeared through counsel at the Final Confirmation Hearing and Ms. Harvey–Burgin appeared pro se at the Final Confirmation Hearing. For the reasons stated in full on the record and incorporated herein, the court overrules those objections on the merits with the exception that the court orders plaintiffs’ counsel to reimburse Ms. Harvey–Burgin’s demonstrable, out-of-pocket travel and lodging expenses associated with her deposition.
D. Approval of Qualified Settlement Fund *5 Pursuant to the Settlement Agreement, Sprint directly or through the Settlement Administrator, will establish an escrow fund for the purpose of satisfying the portion of its obligations to Plaintiffs. The Court approves the establishment of the escrow account under the Settlement Agreement as a qualified settlement fund (QSF) pursuant to Internal Revenue Code section 468B and the Treasury Regulations promulgated thereunder. See 26 U.S.C. § 468B; 26 C.F.R. § 1.468B–1. Nothing in the escrow agreement shall alter any of Sprint’s obligations under the Settlement Agreement, including its obligations to (i) the named Plaintiffs and the Opt–In Plaintiffs, or (ii) Plaintiffs’ counsel.
E. Notice Was Adequate The Notice was initially mailed to the last known address of each Opt–In Plaintiff. For those mailings that were

returned marked “undeliverable,” a search of Internet and other on-line databases for alternate addresses for each returned Notice was done, and Notice was re-mailed to each of the newly-obtained addresses. The distribution and timing of notice in this case complies with Rule 23. Petrovic v. Amoco Oil Co., 200 F.3d 1140, 1153 (8th Cir.1999); Grunin v. Int’l House of Pancakes, 513 F.2d 114, 120–21 (8th Cir.1975).
The content of the Notice also fully complied with due process requirements. It identified all Plaintiffs, described the nature of the action, including the age claims, and explained the procedure for making objections to or withdrawing from the Settlement. It provided specifics regarding the date, time, and place of the Final Confirmation Hearing, and informed the Opt–In Plaintiffs that they may enter an appearance either personally or through counsel. The Notice also informed Plaintiffs how they could make inquiry about the Settlement to enable them to make fully informed decisions regarding the Settlement. The Notice advised the Opt–In Plaintiffs that if they did not withdraw, the Agreement would be binding upon them. The Notice further informed the Opt–In Plaintiffs about the payment of Plaintiffs’ attorneys’ fees and costs and about the payments to the Named Plaintiffs.
The content of the Notice in this case complies with Rule 23’s requirements in class actions. Petrovic, 200 F.3d at 1153; Grunin, 513 F.2d at 120–21. The information and detail provided by the Class Notice in this case go well beyond the summary information required by Rule 23(e). The Notice contains a fair recital of the subject matter and proposed terms of the Settlement. The Notice was adequate, comprehensive and timely, and afforded Opt–In Plaintiffs the information necessary to make an informed and intelligent decision whether to participate in the Settlement. Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 315, 70 S.Ct. 652, 94 L.Ed. 865 (1950); Petrovic, 200 F.3d 1140 at 1153; Grunin, 513 F.2d at 120–21.
Finally, Opt–In Plaintiffs had at least thirty (30) days from the date of the last mailing of Notice to them to submit withdrawal requests or to comment upon or object to the Settlement. This process has been sufficient to give the Opt–In Plaintiffs the time and reasonable opportunity to comment on and take part in the Settlement. See Torrisi v. Tucson Elec. Power Co., 8 F.3d 1370 (9th Cir.1993).

F. Approval Of Slight Modifications To Correct Eight

Matrix Errors

*6 There are only slight modifications to Exhibit 3 to the

Settlement

Agreement

to

correct

4

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

calculation/administrative errors in the original distributions to eight (8) Opt–In Plaintiffs. The Court approves those corrections and the amended Exhibit 3. The Court approves these corrections in the following specifics:
(a) The Court approves the specific, corrected amounts for each of the eight (8) Opt–In Plaintiffs for whom matrix calculation corrections were necessary after the Court’s preliminary approval order;
(b) The Court approves the amendment of the settlement payments to be made by Defendant Sprint as provided for in the Master Full and Final Settlement Agreement to reflect an increase to the “Payment to Plaintiffs” amount as set forth in paragraph 4.a., with such increase being in the amount of $87,481.98;1 and,
(c) The Court approves the amendment of the settlement payments to be made by Defendant Sprint as provided for in the Master Full and Final Settlement Agreement to reflect a decrease in the amount set forth in paragraph 4.b. “Payment of Attorneys’ Fees, Costs, and Expenses”, with such decrease being in the amount of $87,481.98.2 The eight (8) corrections noted herein have no impact on the overall Settlement Agreement or the amounts of settlement disbursement to any of the other 1678 Opt–In Plaintiffs. There is no additional net amount being paid by Defendant Sprint, and the attorneys’ fee and expenses sought by Plaintiffs’ counsel will be reduced below that which was set forth in the Notice. As such, the Court finds that no further notice to the Opt–In Plaintiffs is required regarding these slight corrections, other than the previously-filed public pleading and the Court’s Final Approval Order, since such changes are de minimus and do not affect the interests of any other Opt–In Plaintiffs.
G. Approval Of Agreement Regarding Non–Effect On Pensions During settlement administration, and after some of the Opt–In Plaintiffs sought assurance from their counsel that participation in the settlement and signing the waiver and release would not interfere with the retirement benefits they were receiving, the Parties advised the Court that they had agreed that nothing in the Master Full and Final Settlement Agreement or any of the Releases executed pursuant to this Settlement Agreement is intended to modify any rights that exist under the Sprint Retirement Pension Plan, the Sprint Nextel 401(k) Plan, and, if applicable, any similar pension plan sponsored by

Embarq, as those plans may be amended from time to time, in which plaintiffs are, or may become, vested beneficiaries. Accordingly, the Parties requested that language to this effect be included in the Court’s Final Approval Order confirming the Master Full and Final Settlement Agreement.
H. Approval Of Plaintiffs’ Counsel’s Fees And Expenses Plaintiffs’ counsel separately submitted their Motion for Order Directing Payment of Attorneys’ Fees and Litigation Expenses (doc. 4659). Defendant has not objected to the allocation of fees and expenses to Plaintiffs’ counsel, as set forth in the Master Full and Final Settlement Agreement and does not object to the reduction of those fees to fund distributions to be made to correct the eight (8) errors made in the initial distribution list contained in that Agreement. There have been no objections filed by any of the Opt–In Plaintiffs to the award of Plaintiffs’ counsel’s fees and expenses. The Court finds that the fee contracts providing for payment of a thirty-five percent (35%) contingent attorneys’ fee and reimbursement of advanced litigation expenses are fair and reasonable in this matter. The Court further finds it appropriate under the common fund doctrine to assess such thirty-five percent (35%) contingent attorneys’ fee and the pro-rata reimbursement of advanced litigation expenses against the total recovery allocable to those Opt–In Plaintiffs who did not expressly contract for payment and reimbursement. The Court also approves reimbursement of Plaintiffs’ counsel’s total litigation expenses in the amount of $1,650,000.00. At the Final Confirmation Hearing, the Court questioned whether it would be appropriate to reimburse the expenses of Opt–In Plaintiffs who traveled some distance for their depositions. Plaintiffs’ counsel have agreed to pay out of their attorneys’ fees the demonstrable out-of-pocket travel and lodging expenses of those Opt–In Plaintiffs who traveled more than 100 miles to provide deposition testimony. The Court accordingly approves and direct the payment of Plaintiffs’ counsel’s fees of $19,285,018.02 and expenses of $1,6500,000.00 pursuant to the Settlement Agreement as modified by the parties’ agreement as it pertains to the individuals referenced in paragraph E above, and as modified by the agreement of Plaintiffs’ counsel to pay the demonstrable out-of-pocket travel and lodging expenses of the Opt–In Plaintiffs who traveled more than 100 miles to provide deposition testimony in this case.
IV. CONCLUSION
5

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

*7 After a thorough review of the terms of the settlement, the parties’ submissions in support of the settlement, the two objections, and the factors to be considered by the Court in evaluating the fairness of such a settlement, the Court concludes that the proposed class settlement entered into between the Plaintiffs and Sprint is fair, reasonable, and adequate. The Court concludes that the settlement was reached after good faith, arm’s length negotiations and in the absence of collusion. The Court also concludes that there are substantial economic benefits of the settlement to the Opt–In Plaintiffs in this Collective Action. The Court also finds and concludes that the settlement is reasonable and adequate in light of the prospects and possibilities relating to Plaintiffs’ success in obtaining the relief prayed for as compared to the economic benefits of the settlement, the relative strength of the claims, and the cost and uncertainty of further litigation.

time, in which plaintiffs are, or may become, vested beneficiaries.
IT IS FURTHER ORDERED THAT the parties are directed to consummate and fully perform the Settlement in accordance with the terms of the Master Full and Final Settlement Agreement as modified.
IT IS FURTHER ORDERED THAT plaintiffs’ motion for order directing payment of attorneys’ fees and expenses (doc. 4659) is granted. Plaintiffs’ counsel’s attorneys’ fees and expenses are reasonable, and said fees and expenses should be paid as set forth in the Master Full and Final Settlement Agreement, as modified. Out of those attorneys’ fees, counsel are to pay the demonstrable, out-of-pocket travel and lodging expenses of those Opt–In Plaintiffs who traveled more than 100 miles to provide deposition testimony in this case.

IT IS THEREFORE ORDERED BY THE COURT THAT the parties’ joint motion for final approval of settlement (doc. 4658) is granted and the Settlement Agreement is approved as modified.
IT IS FURTHER ORDERED THAT the Court hereby enters judgment dismissing with prejudice the pattern or practice and disparate impact claims of all Named Plaintiffs and Opt–In Plaintiffs, as well as any individual disparate treatment claims, all as asserted in this case.
IT IS FURTHER ORDERED THAT the mailing of notice of the Settlement to the Opt–In Plaintiffs in this Collective Action as set forth in the Affidavit of the Settlement Administrator constitutes the best notice practical under the circumstances, and that such notice comports with due process and is due and sufficient notice for all purposes to all persons entitled thereto.
IT IS FURTHER ORDERED THAT the objections of Opt–In Plaintiffs Philip Bodine and Ruby Harvey–Burgin are overruled.
IT IS FURTHER ORDERED THAT nothing in the Master Full and Final Settlement Agreement or any of the Releases executed pursuant to this Settlement is intended to modify any rights that exist under the Sprint Retirement Pension Plan, the Sprint Nextel 401(k) Plan, and, if applicable, any similar pension plan sponsored by Embarq, as those plans may be amended from time to

*8 IT IS FURTHER ORDERED THAT this Order is a Final Order and that there are no participants in this collective action with standing to pursue any appeal.
IT IS FURTHER ORDERED THAT pursuant to the terms of the Settlement Agreement and this Court’s May 30, 2007 Order, should any reviewing Court on direct appeal and/or on writ of certiorari to the Supreme Court of the United States invalidate the Settlement Agreement or require its modification, the Settlement Agreement and any documents associated with it shall be null and void, inadmissible, and unusable in any Court proceeding regarding any issue whatsoever, and shall not be considered a binding Settlement Agreement, unless Plaintiffs and Defendant each expressly and voluntarily approve in writing any such required modification by any reviewing Court.
IT IS FURTHER ORDERED THAT the Court shall retain jurisdiction regarding administration of the settlement. The parties are to submit a 90–day Status Report with regard to the effectuation and implementation of the Settlement Agreement and Settlement Administration.
IT IS SO ORDERED.
	  

Footnotes

1

Thus, the new, increased total amount to be paid by Sprint to the Opt–In Plaintiffs and Plaintiffs pursuant to paragraphs 4.a. and

5.a. is $36,064,981.98.

6

Williams v. Sprint/United Management Co., Not Reported in F.Supp.2d (2007)

2

Thus, the new, decreased amount to be paid by Sprint to Plaintiffs’ counsel in attorneys’ fees and expenses pursuant to paragraph

4.b. of the Settlement Agreement is $20,935,018.02.

	  

7

 
 Case 2:03-cv-02200-JWL-DJW Document 285 Filed 07/02/04 Page 1 of 15

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams,

Plaintiff,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER This matter is presently before the court on plaintiff’s motion to join additional parties as plaintiffs and for provisional certification of the action as a collective action pursuant to 29 U.S.C. § 216(b) (doc. #256). Plaintiff also requests that the court facilitate joinder of the putative class members by approving the sending of a notice to those who have not yet filed written consents to join the action. As set forth in more detail below, plaintiff’s motion is granted.

Procedural History Plaintiff Shirley Williams filed a complaint on April 23, 2003 alleging violations of the
Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq., arising out of her employment with defendant.1 In her complaint, plaintiff further alleged that defendant had engaged in a pattern and practice of age discrimination against plaintiff and others similarly situated to plaintiff such
1Plaintiff’s complaint also alleges violations of the Americans with Disabilities Act, 42 U.S.C. § 12111 et seq. This claim, however, is not relevant to the motions before the court.

Case 2:03-cv-02200-JWL-DJW Document 285 Filed 07/02/04 Page 2 of 15
that the action should proceed as a collective action under the ADEA.2 Shortly after plaintiff filed her complaint, individuals began opting-in to the action by filing the requisite consent forms. To date, approximately 119 individuals have filed consent forms as opt-in plaintiffs. Moreover, the parties have engaged in considerable discovery concerning the appropriate composition of the proposed plaintiff group (i.e., the “similarly situated” issue). The parties have not yet engaged in discovery concerning the merits of plaintiff’s pattern and practice allegations nor have the parties engaged in discovery concerning any issues specific to plaintiff or any members of the opt-in group.
Plaintiff now moves the court to join the opt-in plaintiffs and to provisionally certify the action as a collective action for purposes of providing notice of the action to other potential plaintiffs.
Standard Class actions under the ADEA are authorized by 29 U.S.C. § 626(b), which expressly
borrows the opt-in class action mechanism of the Fair Labor Standards Act of 1938, 29 U.S.C. § 216(b) (1994). Section 216(b) provides for a class action where the complaining employees are
2The ADEA incorporates the procedures for enforcement of the Fair Labor Standards Act (FLSA). 29 U.S.C. § 626(b). A class action under the ADEA is therefore governed by § 16(b) of the FLSA found at 29 U.S.C. § 216(b) rather than Rule 23 of the Federal Rules of Civil Procedure. Section 16(b) provides that an action may be brought by an employee for himself or herself and on behalf of “other employees similarly situated.” An employee similarly situated does not become a party-plaintiff under § 16(b) “unless he gives his consent in writing to become such a party” and files consent in the court where the action is pending. 29 U.S.C. § 216(b).
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“similarly situated.” The Tenth Circuit has approved a two-step approach in determining whether plaintiffs are “similarly situated” for purposes of § 216(b). See Thiessen v. General Elec. Capital Corp., 267 F.3d 1095, 1105 (10th Cir. 2001). Under this approach, a court typically makes an initial “notice stage” determination of whether plaintiffs are “similarly situated.” See id. at 1102 (citing Vaszlavik v. Storage Tech. Corp., 175 F.R.D. 672, 678 (D. Colo. 1997)). That is, the district court determines whether a collective action should be certified for purposes of sending notice of the action to potential class members. See Mooney v. Aramco Servs. Co., 54 F.3d 1207, 1213-14 (5th Cir. 1995). For conditional certification at the “notice stage,” a court “require[s] nothing more than substantial allegations that the putative class members were together the victims of a single decision, policy, or plan.” See Thiessen, 267 F.3d at 1102 (quoting Vaszlavik, 175 F.R.D. at 678). The standard for certification at the notice stage, then, is a lenient one. See id. at 1103; see also Brooks v. BellSouth Telecommunications, Inc., 164 F.R.D. 561, 568 (N.D. Ala. 1995) (certification decision at the notice stage is usually based only on the pleadings and any affidavits which have been filed and, thus, the standard is fairly lenient and typically results in conditional certification of a representative class).
At the conclusion of discovery, the court then revisits the certification issue and makes a second determination (often prompted by a motion to decertify) of whether the plaintiffs are “similarly situated” using a stricter standard. Thiessen, 267 F.3d at 1102-03. During this “second stage” analysis, a court reviews several factors, including the disparate factual and employment settings of the individual plaintiffs; the various defenses available to defendant which appear to be individual to each plaintiff; fairness and procedural considerations; and whether plaintiffs made
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the filings required by the ADEA before instituting suit. Id. at 1103. While plaintiff is arguably beyond the “notice stage” in that 119 individuals have already
filed opt-in consent forms and the parties have engaged in considerable discovery with respect to the opt-in group, plaintiff has not yet sent notice of the action to potential plaintiffs and the parties have not engaged in discovery on those issues pertinent to the “second stage” analysis. Moreover, defendant does not contend that the court should employ the higher “second stage” standard at this juncture. See, e.g., Deft’s Brief at 3 (conceding that plaintiff’s burden at this stage is “low”) & 8 (stating that the case is at the “notice stage”). Thus, the court analyzes plaintiff’s motion under the lenient “notice stage” standard described above and, in doing so, looks to the “substantial allegations” in plaintiff’s first amended complaint3 and various affidavits filed by plaintiff. See, e.g., Thiessen, 267 F.3d at 1102; Sperling v. Hoffman-La Roche, Inc., 118 F.R.D. 392, 407 (D.N.J. 1988) (making initial determination that plaintiffs were similarly situated based on detailed allegations in the pleadings as supported by affidavits).
Background Consistent with the standard articulated above, the following facts are based on detailed
3While plaintiff has not yet filed her first amended complaint, she has filed a motion for leave to file her first amended complaint (doc. #254) and that motion is also pending before the court. Because the court concludes that the allegations in the proposed amended complaint are sufficient to warrant conditional certification at this stage, the court grants plaintiff’s motion (which defendant has not opposed) for leave to file the amended complaint. Plaintiff shall file the amended complaint (attached as Exhibit A to her motion for leave) within 10 days of the date of this order.
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allegations in plaintiff’s first amended complaint as supported by affidavits. According to plaintiff, defendant Sprint/United Management Company (hereinafter “Sprint”) planned and implemented several phases of a reduction in force (“RIF”) beginning in the fourth quarter of 2001 and extending through the end of the first quarter of 2003. The stated purpose of the reduction in force was to eliminate job functions and reduce costs. Plaintiff alleges that Sprint engaged in a pattern and practice of age discrimination in connection with its RIF by treating younger employees more favorably than older employees in implementing the RIF.
Specifically, plaintiff contends that Sprint, before and during the RIF process, routinely transferred younger employees (i.e., employees under the age of 40) to “safe” positions–positions that would not be eliminated during the RIF; that Sprint identified younger employees as “key talent” and took extraordinary measures to exempt those employees from the RIF; that Sprint transferred older employees (i.e., employees over the age of 40) to positions or departments which Sprint intended to phase out or eliminate during the RIF process; and that Sprint filled “open” positions with younger employees just prior to the RIF and then terminated older employees in the same or similar positions during the RIF. Plaintiff further alleges that Sprint provided managers with spreadsheets for use in making termination decisions and that these spreadsheets contained age-related information about employees.
Plaintiff also describes in her first amended complaint Sprint’s “forced ranking” or “alpha ranking” system utilized to evaluate and compare the performance of employees. According to plaintiff, this forced ranking system was implemented in early 2002. Under this system, managers were required to rank the performance of each employee in his or her department as compared to
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all other employees in the department. The ratings given to employees under the new system were
an important factor in determining which employees would be terminated during the RIF. Prior
to the implementation of the forced ranking system, each employee was simply given an overall
performance rating on a scale of 1 to 5 with the vast majority of employees receiving a “3” rating
for “fully meeting” Sprint’s expectations. According to plaintiff, older employees who had
previously received high ratings under the old system were less likely to receive high ratings under
the new system than were younger employees. Similarly, plaintiff alleges that older employees
who had previously received “3” ratings under the old system were more likely to receive lower
ratings under the new system than younger employees. Finally, plaintiff alleges that Sprint
conducted a review of its forced ranking system which revealed that the system was biased against older employees.4
4In addition, plaintiff has submitted to the court the affidavit of Sharon Louk, a former management-level employee with Sprint. Ms. Louk’s affidavit describes, among other things, her personal knowledge of various age-based comments made by certain Sprint managers during discussions concerning which employees to select for termination in the RIF, including statements such as “we need younger blood;” older employees “don’t have what it takes;” and younger employees “have more potential.” Sprint moves to strike the affidavit based on plaintiff’s failure to disclose Ms. Louk as a witness pursuant to Rule 26(a)(1) until the day before plaintiff filed her motion for provisional certification and, thus, Sprint was denied the opportunity to interview or depose Ms. Louk during the discovery period. The motion is denied as moot because the court finds that plaintiff has satisfied the standard for provisional certification even in the absence of Ms. Louk’s affidavit. Stated another way, the court has not relied on Ms. Louk’s affidavit in determining that provisional certification is appropriate. However, Sprint should have ample opportunity to depose Ms. Louk during the next phase of discovery and, thus, will not likely be able to demonstrate any prejudice should plaintiff seek to utilize Ms. Louk’s affidavit in support of final certification.
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Discussion In her motion for provisional certification of this action as a collective action, plaintiff
asserts that she is similarly situated to the opt-in plaintiffs and potential opt-in plaintiffs in that she and the plaintiffs were all terminated as a result of Sprint’s reduction in force occurring from October 2001 through March 2003; were subjected to the same “displacement guidelines” and “reduction guidelines” utilized by Sprint management in determining which employees to select for termination during the RIF; and were subjected to the same performance rating systems. Sprint opposes provisional certification of the class.
The court readily concludes that provisional certification of this action is appropriate for purposes of sending notice to potential class members. Clearly, plaintiff’s first amended complaint contains detailed allegations, supported by affidavits, that the putative class members were “together the victims of a single decision, policy, or plan.” See Thiessen, 267 F.3d at 1102. According to plaintiff’s first amended complaint, Sprint intentionally treated younger employees more favorably than older employees in connection with its reduction in force by transferring younger employees into “safe” positions; by transferring older employees to positions that were marked for elimination; by adopting an age-biased performance rating system knowing that older employees would not fare as well as younger employees under the system; and by providing decisionmakers with age-related information about employees for use in making termination decisions. These allegations are more than sufficient to support provisional certification. See, e.g., Vaszlavik, 175 F.R.D. at 678-79 (concluding that conditional certification for notice purposes was warranted based on plaintiffs’ allegations that they were victims of a plan by
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defendant to eliminate older workers through reductions-in-force); Sperling v. Hoffmann-La Roche, Inc., 118 F.R.D. 392, 406-07 (D.N.J. 1988) (concluding that certification for purposes of sending notice was appropriate where plaintiffs alleged that defendant discriminated against older workers in implementing its reduction in force).
Sprint urges that conditional certification is inappropriate because plaintiff has not come forward with evidence establishing a pattern and practice of age discrimination. As the court recently explained in denying without prejudice Sprint’s motion for partial summary judgment on the issue of pattern and practice, discovery has not yet been completed on the pattern and practice issue (indeed, full scale discovery on the issue has not even been conducted) and any arguments concerning plaintiff’s evidence of a pattern and practice of discrimination are premature. Moreover, as explained by Judge Babcock in Vaszlavik, whether plaintiff can meet her burden of establishing a pattern and practice of discrimination “is irrelevant to the question of 216(b) certification” as “the liability phase of a pattern and practice action is unaffected by the number of plaintiffs asserting the claim.” 175 F.R.D. at 680. As Judge Babcock reasoned:
The sole issue in the liability phase is whether defendant engaged in a pattern and practice of discrimination. At that stage, plaintiffs are not required to provide specific evidence that they were individually discriminated against. Therefore, phase one of the trial will not be affected by the expansion of this claim from eleven named plaintiffs to the hundreds who might be encompassed by the proposed class. Any disparities among the employment situations of the individual plaintiffs are irrelevant during the liability phase, judicial economies are clearly served by proceeding collectively, and the defendant is not prejudiced. This represents the epitome of similarly situated plaintiffs. Id. (citation omitted). For these reasons, the court rejects Sprint’s argument that conditional certification is inappropriate in light of the alleged deficiencies in plaintiff’s pattern and practice
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evidence. Sprint also contends that conditional certification is inappropriate because plaintiff cannot
establish that she is “similarly situated” to the opt-in plaintiffs or to any potential opt-in plaintiffs. In support of this argument, Sprint focuses on the dissimilarities between plaintiff and any present or potential opt-in plaintiffs. According to Sprint, plaintiffs and the opt-ins have vastly different lengths of service and performance ratings, come from different business units, held different positions and worked under different managers. Sprint also highlights that plaintiff and the opt-ins were terminated by different decisionmakers and that the termination decisions were made for a variety of different reasons. While any differences between and among plaintiff and the opt-ins may be relevant after discovery is completed and the court makes a conclusive determination of whether the plaintiffs are “similarly situated” upon revisiting the certification issue, such differences are simply not relevant at the notice stage when plaintiff, as here, has set forth substantial allegations that all plaintiffs were subjected to a pattern and practice of age discrimination. See Thiessen, 267 F.3d at 1103, 1105 (disparate factual and employment settings of individual plaintiffs and various defenses available to defendant are considered by court after discovery has been completed and court is analyzing the “similarly situated” requirement under a stricter standard). Thus, the differences between and among plaintiff and the opt-ins as described by Sprint are not fatal to plaintiff’s motion for provisional certification. See Vaszlavik, 175 F.R.D. at 678-79 (rejecting defendant’s argument that plaintiffs were not similarly situated because plaintiffs worked in markedly different circumstances and positions; concluding that despite any differences, plaintiffs were “similarly situated” for notice purposes in light of
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substantial allegations that they were all victims of a pattern and practice of age discrimination). Sprint’s final argument in opposition to plaintiff’s motion is that the “similarly situated”
standard, even at the notice stage, is not met by showing only that all plaintiffs were terminated during a reduction in force. According to Sprint, if such a showing were sufficient to support conditional certification, then every reduction-in-force would give rise to a collective action. Of course, plaintiff here has not alleged simply that all potential plaintiffs were terminated during Sprint’s reduction in force. Rather, she has alleged, and has supported her allegations with affidavits, that the potential plaintiffs were terminated during the reduction in force as a result of Sprint’s pattern and practice of discriminating against older workers in implementing the reduction in force. These allegations are sufficient for purposes of sending notice to the potential class and Sprint’s argument otherwise is not persuasive.
Having concluded that this action should be conditionally certified for purposes of notifying potential members of the class, the court turns to the specific notice proposed by plaintiff. The notice that plaintiff seeks to send out to potential class members is attached as Appendix A to plaintiff’s motion for provisional certification. Plaintiff asserts that she is ready to send this notice immediately upon approval from the court as she has already identified the names of all potential class members. While Sprint did not object in its brief to the form or the content of plaintiff’s proposed notice, counsel for Sprint notified the court by letter this week that Sprint would like the opportunity to “comment on any notice” that would be sent to potential plaintiffs in the event the court conditionally certifies this action as a collective action.
The court is somewhat puzzled by Sprint’s failure to include in its response to plaintiff’s 10

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motion any objections it might have to plaintiff’s proposed notice–particularly as plaintiff expressly moves the court to approve the specific notice that she has attached to her motion. Nonetheless, the court will provide Sprint an opportunity to file objections to the notice because the court, in setting the first phase scheduling order in this case, focused solely on the conditional certification issue and did not discuss with the parties any specific procedure for developing the actual notice that would ultimately be distributed upon certification. Thus, Sprint shall file any objections to the notice attached as Appendix A to plaintiff’s motion by 5:00pm on Wednesday, July 7, 2004 and the court will take up those objections, and any response plaintiff might have thereto, during a telephone conference that the court hereby sets for Thursday, July 8, 2004 at 3:00p.m.
One additional motion remains pending before the court–plaintiff’s motion to unseal the record with respect to her motion for provisional certification. By way of background, Sprint requested a telephone conference with the court on the day prior to plaintiff’s deadline for filing her motion for provisional certification. During that conference, Sprint made an oral motion to require that plaintiff file under seal her motion for provisional certification and all supporting materials. Because the court did not have time to review plaintiff’s filings (as Sprint’s motion was made one day prior to plaintiff’s anticipated filing) to ascertain whether any particular documents should be filed under seal, the court granted defendant’s motion but invited plaintiff to file a motion to unseal that the court could analyze in connection with the motion for provisional certification. Plaintiff has now filed that motion.
In response to plaintiff’s motion, Sprint concedes that the vast majority of the documents 11

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filed by plaintiff should be unsealed but contends that Exhibits 73 and 74 to plaintiff’s motion and the affidavits of Ms. Louk, Mr. Borel and Ms. Mendelsohn should remain sealed for the following reasons: Exhibits 73 and 74 are spread sheets that reflect the names, performance ratings and social security numbers of non-party employees; the affidavit of Ms. Louk includes information regarding compensation paid to a Sprint contractor; the affidavit of Mr. Borel includes information regarding the disability status and performance rating of a non-party employee; and the affidavit of Ms. Mendelsohn includes information regarding the performance ratings of two non-party employees. In reply, plaintiff agrees to redact the social security numbers from Exhibits 73 and 74. Thus, the only issue that remains in dispute is whether the information concerning the performance ratings of certain non-party employees, the disability status of one non-party employee and the compensation of a non-party contractor should remain sealed.
As the party seeking to keep portions of the record sealed, Sprint has the burden of showing that its interest in sealing the information concerning the non-party employees outweighs the public’s right of access to judicial records. See, e.g., Bryan v. Eichenwald, 191 F.R.D. 650, 652 (D. Kan. 2000). Stated another way, Sprint must demonstrate a public or private harm sufficient to overcome the public’s right of access. See id. Sprint has not met its burden and the court concludes that the public’s right of access to the information contained in the documents outweighs any potential (but unlikely) harm that might result in disclosing the information. For example, Sprint contends that Ms. Mendelsohn’s affidavit contains information relating to the performance ratings of two non-party employees. Specifically, Ms. Mendelsohn avers that the two employees “were rated in job performance the same as I was, Fully Met Expectations.” The court
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can discern no harm that might come to the two employees by such a disclosure–particularly because the employees’ ratings were positive–and Sprint fails to identify any such harm, pointing only to an individual’s general right to privacy in such information. Similarly, Mr. Borel avers that a particular employee who was over the age of 40 “was on short-term disability leave when she was laid-off . . . . [She] had received good ratings during her 15 year employment at Sprint [b]ut her rating was changed to an adverse rating after she was laid off by . . her manager.” Again, the court discerns no harm that might come to the individual identified in Mr. Borel’s affidavit, as the clear suggestion is that the individual was a good performer but received an adverse rating solely on the basis of her age. Moreover, the affidavit does not specify or even suggest the basis for the employee’s short term disability leave and, accordingly, the court discerns no reason to seal the mere reference to the employee’s leave.
With respect to the reference in Ms. Louk’s affidavit to the compensation paid to a particular contractor, Sprint has not explained why this information should be protected (and has failed to suggest any particular harm that might come from disclosure of the information), other than its general argument that the information is “private.” However, the contractor identified in Ms. Louk’s affidavit has not filed an affidavit stating she is concerned about having the information available to the public and Sprint’s vague interest in keeping the information sealed does not outweigh the public’s right of access. Finally, with respect to the performance ratings contained in Exhibits 73 and 74, Sprint again has not explained why the information should be kept under seal. In fact, the information contained in Exhibits 73 and 74 is the standard information found in any employment discrimination case when one employee seeks to compare his or her
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performance to other employees. Thus, in the absence of any persuasive argument why the information should be protected, the court is unwilling to keep the documents under seal.
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiff’s motion for leave to file an amended complaint (doc. #254) is granted and plaintiff shall file her First Amended Complaint attached as Exhibit A to her motion within 10 days of the date of this orde r; plaintiff’s motion for provisional certification, to join additional plaintiffs and to send notice (doc. #256) is granted; defendant’s motion to strike the affidavit of Sharon Louk (doc. #265) is denied as moot; and plaintiff’s motion to unseal recent court filings (doc. #262) is granted.
The court will conduct a telephone conference on Thursday, July 8, 2004 at 3:00p.m. to discuss the form and content of the notice that plaintiff will distribute to potential class members.
With respect to further scheduling in this action, and as set forth in paragraph 6 of the first phase scheduling order, the parties are directed to meet and confer on a schedule relating to case management, including among other issues, discovery limits and deadlines, expert discovery, and procedures and deadlines for further dispositive motions, including a motion to decertify. No later than 10 days after conferring, the parties will file with the court either a stipulated case management schedule or respective motions for entry of their own proposed scheduling orders, explaining to the court why the parties could not reach agreement.
IT IS SO ORDERED. 14

Case 2:03-cv-02200-JWL-DJW Document 285 Filed 07/02/04 Page 15 of 15 Dated this 1st day of July, 2004, at Kansas City, Kansas. s/John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 286 Filed 07/02/04 Page 1 of 17

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS,

)

)

Plaintiff,

)

)

vs.

)

)

SPRINT/UNITED MANAGEMENT COMPANY, )

)

Defendant.

)

Case No. 03-2200-JWL

FIRST AMENDED COMPLAINT

COMES NOW Plaintiff Shirley Williams, by and through counsel, and for her causes of

action against Defendant Sprint/United Management Company, alleges and avers as follows:

GENERAL ALLEGATIONS

1. Plaintiff Shirley Williams (hereinafter “Plaintiff” or “Williams”) is a 61-year-old

citizen and resident of the State of Kansas.

2. Defendant Sprint/United Management Company (hereinafter “Defendant” or

“Sprint”) is a corporation which is currently in good standing and which is duly registered to do

business in the State of Kansas and which was doing business in the State of Kansas at all times

relevant to this lawsuit. Defendant may be served by and through its registered agent, Corporation

Service Company, 200 S.W. 30th Street, Topeka, KS 66611.

3. This Court has jurisdiction over this action by virtue of 28 U.S.C. § 1331, in that it

arises under the laws of the United States of America, namely, the Age Discrimination in

Employment Act, 29 U.S.C. § 621, et seq. and the Americans with Disabilities Act, 42 U.S.C. §§

12101, et seq.

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4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 (b) by virtue of the fact that a substantial part of the events or omissions giving rise to the claims set forth herein occurred in the State of Kansas and that Defendant is registered to do and is doing business in the State of Kansas, subjecting it to personal jurisdiction in this action and making it a “resident” of this judicial district pursuant to 28 U.S.C. § 1391(c).
5. Defendant Sprint/United Management Company, constitutes, and constituted at all times relevant to this action, an "employer" as defined in 29 U.S.C. § 630(b) and 42 U.S.C. §§ 12111.
ALLEGATIONS SUPPORTING COLLECTIVE ACTION (29 U.S.C. §§ 626(b) AND 216(b))
6. Beginning in the fourth quarter of 2001, and extending at least through the end of the first quarter of 2003, Sprint planned and implemented a several phases of a “reduction in force” (“RIF”) purportedly intended to eliminate job functions and to reduce costs.
7. In connection with the RIF, Sprint engaged in a pattern or practice of age discrimination, in treating younger employees more favorably than older employees, including (but not limited to) some of the following specific actions:
a. Transferring younger employees (i.e., those under the age of 40) to “safe” positions before and during the RIF process;
b. Identifying certain younger employees (i.e., those under the age of 40) as “key talent” and taking extraordinary efforts to exempt them from the RIF;
c. Transferring older workers (i.e., those 40 years of age and older) to jobs or departments which were to be phased out or eliminated as part of a future reorganization; 2

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d. Consciously deciding not to comply with the “Older Workers Benefit Protection Act (“OWBPA”) for certain job grades, in order to avoid having to disclose demographic data and its “selection criteria” to those affected by the RIF;
e. Filling “open” positions within departments with younger employees (i.e., under the age of 40) just before the RIF, then terminating older workers (i.e., those 40 years of age and older) in the same or similar positions as part of the RIF;
f. Providing “spreadsheets” or “templates” to managers to use in making termination decisions, which spreadsheets or templates included, or were designed to include, improper factors such as age, date of birth, and other age-related criteria;
g. Providing hidden data links, within such spreadsheets and templates, that allowed managers to access improper criteria, such as age, date of birth, and other age related data, for use in making RIF decisions;
h. Setting up a “sham” process (through a company called Right Management Consultants) for displaced workers to “re-apply” for open positions with Sprint, resulting in situations where older applicants (i.e., those 40 years of age and older) were not given the same consideration as younger employees and were denied even the opportunity to interview for such open positions;
i. Continuing to hire new employees after the RIF that eliminated the positions of Plaintiffs and others similarly situated, with positions for which RIF’d employees were fully qualified;
j. Implementing a new “alpha rating” or “forced ranking” system in early 2002 which was secretly intended to provide justification for termination decisions to be made as
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part of the RIF. With respect to this new performance rating system, Plaintiff alleges the following pertinent facts: i. Through the end of 2001, most Sprint employees were given an overall
performance rating on a scale of 1-5, with 1 being the highest and 5 being the lowest; ii. The vast majority of Sprint employees evaluated through the end of 2001 received a rating of “3” under this method; a “3” rating signifies performance that “fully met” the employer’s expectations; iii. In late 2001, Sprint began discussing a new “alpha-rating” system which, among other features, would utilize the forced ranking method (using a “Bell curve” model) lionized by Jack Welch of GE to rate and compare employees; iv. One of Sprint’s intentions in adopting the new “alpha rating” system was to identify more “poor performers” within the organization; v. Despite clear warnings from its own employees studying the new rating system before implementation that such a system “does not pretend to be objective,” and could lead to increased claims of age discrimination, Sprint decided to move forward with the “alpha rating system” in early 2002; vi. Under this new rating system, Sprint managers were directed to give a “shadow rating” to all exempt employees, even though their 2001 “numeric” ratings had already been determined; vii. Sprint officially announced this new “alpha rating” system to employees in mid-February of 2002;
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viii. Sprint employees were told in writing in early 2002 that the new alpha rating system “would not affect compensation” in 2002 and that alpha ratings given in 2002 “would not become a part of any employee’s permanent record;”
ix. Nevertheless, in late February or early March of 2002, Sprint managers were expressly directed to use “shadow ratings” as one of the selection criteria for RIF decisions and, contrary to Sprint’s express representations to employees, alpha ratings were recorded in various significant employee databases;
x. In other cases, Sprint managers made RIF decisions based upon the lower “alpha ratings” given to employees over the age of 40 who had previously received overall numeric ratings of “3” and above;
xi. The “shadow ratings” given to employees in 2002 were an important factor used in the selection process for the RIF that occurred in 2002 and 2003; and
xii. Sprint conducted an “after action review” of the new alpha rating system in the late Spring and early summer of 2002, which confirmed earlier warnings that the system would result in claims of age discrimination.
8. Although Sprint professed to determine the “impact” of actual and proposed job cuts upon various discrete groups of employees, including employees over the age of 40, Sprint has shielded such information from many of its employees, and from others outside the organization, under a claim of “attorney-client” privilege.
9. Nevertheless, data provided through Sprint’s “human resource information system” (HRIS) confirms that, during various time frames relevant to this action:
a. Employees aged 40 and older have been more than twice as likely to be terminated
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as part of a RIF at Sprint than employees under the age of 40; b. Employees aged 40 and older, who had previously been rated in the highest categories
(i.e., “1” and “2”) under the numeric rating system were less likely to retain the highest ratings (i.e., “M” and “H”) under the alpha rating system than were employees under the age of 40; c. Employees aged 40 and older, who had previously been rated in the middle category (i.e., “3”) under the numeric system, were more likely to be rated in the lower categories (i.e., “I” and S”) under the alpha rating system than were employees under the age of 40. 10. Furthermore, Sprint’s own “after action review” of the new alpha rating system confirmed that: a. The system was subjective, arbitrary, non- substantive, dishonest, and inaccurate; b. The system was biased against older (over age 40) workers; and, c. The system was inequitable and inappropriate because of pool size and composition. 11. In addition to the foregoing facts, Plaintiffs are “similarly situated” in that: a. All are over 40; b. All were terminated by Sprint as part of a Reduction in Force that spans the relevant time frame October 1, 2001 through March 31, 2003; c. All are identified by “Separation Code” 63 in Sprint’s human resource information system, a database which was ordered to be produced to plaintiffs herein; d. All were satisfactory (or better) performers just before the RIF; e. All have the same retirement benefit plans — with the same age and service formulas;
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f. All have the same medical (and other) benefits; g. All were purportedly subject to the same “Displacement Guidelines” and standards; h. All were subjected to a RIF overseen by Human Resource Sprint personnel, which
department inadequately trained decision-makers with regard to age discrimination, and equal employment opportunity; i. All were subjected to a RIF infected by Sprint management’s culture of age-bias; j. All exempt salaried employees had the same performance evaluation system in place at the particular time they were RIF’d; k. For all persons over 40 who were RIF’d, younger persons were not RIF’d, despite having same or similar job duties or classifications; l. Nearly all are exempt, salaried employees; and m. Nearly all are job grades 71-79 ALLEGATIONS SPECIFIC TO PLAINTIFF SHIRLEY WILLIAMS 12. Plaintiff began her employment with Sprint in or about November of 1998 as an associate analyst. 13. Plaintiff worked for Sprint from November of 1998 to and including March 13, 2002. 14. During her employment with Sprint, Plaintiff performed her job duties satisfactorily, received numerous satisfactory performance appraisals and received periodic raises in pay. 15. In August of 1999, Plaintiff was promoted to the position of analyst. 16. In September of 2001, Williams received a satisfactory performance appraisal and was designated to receive a five (5) percent pay increase as a result of her job performance. 17. Shortly after this satisfactory performance appraisal, Williams learned that she had
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been listed as a potential witness in a disability discrimination lawsuit brought by a former co-worker of Williams against Defendant.
18. On or about November 28, 2001, Plaintiff was interviewed by counsel representing Defendant in connection with the disability discrimination lawsuit brought by a former co-worker of Williams against Defendant.
19. During this interview, Williams disclosed information that was generally supportive of the former co-worker, and disclosed the existence of a memo she wrote to her supervisor, Lorrie McCurdy (who was also a supervisor of the person bringing the other legal action against Defendant).
20. Shortly after her participation in this interview with counsel for Defendant, Williams began to receive unwarranted negative comments about her work performance.
21. On at least two occasions after her participation in the interview with counsel for Defendant concerning the co-worker’s legal action, Williams applied for analyst positions, but was denied these promotions (in favor of younger, less-qualified candidates).
22. Plaintiff applied for a senior analyst position in the Tables Department and was interviewed for this position on August 13, 2001; Plaintiff later learned that the senior analyst position was given to a much younger female, Annette Purdon (born in 1974), who had less experience with the company.
23. Plaintiff is personally aware of Sprint’s practice of transferring employees to “safe” positions before implementing a reduction in force:
a. During both the Spring and the Fall of 2001, Plaintiff personally observed that several males under the age of 40 were transferred from various positions in her business unit to work on what was called the “Renaissance Billing Platform,” a new billing system that Sprint was developing.
8

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b.
c. Rich
24.

Upon information and belief, the employees who were transferred to work on “Renaissance Billing” in the Spring of 2001 were: Brent Daniel, Jay Thompson, Shelby Brown and Josh Haddad. All were under the age of 40 at the time. Upon information and belief, the employees who were transferred to work on “Renaissance Billing” in the Fall of 2001 were: Scott Rutherford, Chris Pritchard, Brackenhauf, Ryan Gaik and Brett Talcott. All were under the age of 40 at the time. None of these employees who transferred to work on Renaissance Billing in 2001

were included in the reduction in force of March 13, 2002.

25. In February of 2002, a new “subjective” performance rating system was introduced

and Williams was improperly given a low rating.

26. Specifically, in February of 2002, Plaintiff was given a rating of 4 on her 2001 LINK,

and a “shadow rating” of “S” despite being told in her first interim and second interim reviews that

her overall work performance met all expectations.

27. Sprint promoted two males under the age of 30 to the same position and job grade that

Plaintiff held during the two-week period immediately before Plaintiff was terminated.

28. On or about March 1, 2002, two younger employees--Pat Paden (born in 1974) and

Darin Collins (born in 1975)-- were promoted to analyst positions (Grade 73) in the Tables

Department.

29. On March 13, 2002, Plaintiff was notified (along with another co-worker, Dawne

Adams, also over the age of 40 and also a grade 73) that she was to be terminated in a “reduction in

force.” Ms. Adams and Plaintiff were the oldest analysts in their department, had the longest tenure

in their department, and were the only two analysts terminated from their immediate work group on

March 13, 2002.

30. Pat Paden and Darin Collins, who had been promoted to the same position and same

9

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pay grade that plaintiff held just two weeks earlier, were not terminated on March 13, 2002. 31. Defendant discriminated against plaintiff on the basis of her age with respect to the
terms and conditions of her employment, by denying her promotional opportunities, and by terminating her employment on March 13, 2002.
32. Upon plaintiff’s termination, her position was filled by and/or her former job duties were assumed by one or more younger employees.
33. Plaintiff was treated less favorably than similarly situated younger employees in the layoff.
34. Plaintiff’s age was a motivating and/or determining factor in the decision to terminate her employment.
35. Defendant’s stated reasons for plaintiff’s termination were a pretext for discrimination on the basis of her age.
36. Based upon defendant’s discrimination against her, plaintiff filed a timely charge of age discrimination with the Equal Employment Opportunity Commission (EEOC) on or about May 21, 2002.
37. Plaintiff has received a notice of right to sue from the EEOC. 38. Plaintiff has fulfilled all conditions precedent to the filing of this action.
COUNT I--AGE DISCRIMINATION 39. Plaintiff Williams hereby incorporates by reference each and every allegation and averment in her General Allegations as though fully set forth herein. 40. Defendant Sprint discriminated against Plaintiff on the basis of her age in violation of the Age Discrimination in Employment Act, 29 U.S.C. § 623.
10

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41. Defendant Sprint, by and through its officers, employees and agents, engaged in a continuing pattern and practice of discrimination against or disparate treatment of Plaintiff based upon Plaintiff’s age, denying Plaintiff opportunities for promotions and ultimately terminating Plaintiff.
42. As a direct and proximate result of the continuing pattern and practice of discrimination directed toward Plaintiff, or of the disparate treatment of Plaintiff, Plaintiff suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, and in other respects, all in an amount yet to be determined, but not less than Seventy-Five Thousand Dollars ($75,000.00).
43. Defendant Sprint’s actions were willful, entitling Plaintiff to liquidated damages in an amount equal to the actual damages referred to in the preceding paragraph.
44. Plaintiff has already incurred and will in the future incur substantial attorney’s fees and expenses in prosecuting her claim of discrimination to which fees and expenses she is entitled pursuant 29 U.S.C. §§ 626(b) and 216(b).
WHEREFORE, Plaintiff respectfully prays judgment in her favor and against defendant Sprint/United Management Company in the form of the order of this Court: (1) permanently restraining defendant from ever again discriminating against Plaintiff or any other individual on the basis of that individual’s age; (2) reinstating Plaintiff to her position with any promotions and pay increases she would have received in the interim; (3) awarding her back pay in an amount yet to be determined; (4) in the alternative to reinstatement, awarding her front pay in an amount yet to be determined; (5) awarding her lost fringe benefits in an amount yet to be determined; (6) awarding her liquidated damages in an amount equal to her actual damages; (7) awarding her the costs and
11

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expenses, including attorney’s and expert witness fees, incurred in prosecuting her claims of discrimination; (8) awarding her damages to offset unfavorable tax consequences of any award, including attorney’s fees; and (9) awarding such other and further relief as the Court deems just and proper.
COUNT II–ADA RETALIATION 45. Plaintiff Williams hereby incorporates by reference each and every allegation and averment in her General Allegations and in Count I above as though fully set forth herein. 46. Defendant retaliated against Williams, in violation of 42 U.S.C. § 12203, after she “participated... in an investigation” by being interviewed by counsel for Defendant in connection with a disability discrimination lawsuit filed by a former co-worker, by (a) denying Williams promotions; (b) giving Williams an unfavorable performance appraisal; (c) targeting Williams for termination and/or layoff; and (d) terminating Williams on March 13, 2002. 47. Defendant’s actions were intended to coerce, intimidate, threaten or interfere with the exercise or enjoyment by Williams of rights granted her and/or protected by the Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq. in violation of the provisions of 42 U.S.C. § 12203. 48. As a direct and proximate result of the continuing pattern and practice of retaliation directed toward her or disparate treatment of her and of Defendant’s termination of her, Plaintiff has suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, loss of career opportunity, costs of seeking alternate income, expenses incurred in obtaining alternate income, pain and suffering, future medical expense, mental anguish, emotional distress, loss of enjoyment of life, and in other respects, all in an amount yet to be
12

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determined but not less than Seventy-Five Thousand Dollars ($75,000.00). 49. Defendant’s actions were wilful, wanton, malicious and in reckless disregard of
Williams’ rights; were motivated by evil motive or reckless indifference to the harm that they might inflict upon Williams or amounted to gross negligence.
50. Williams has already incurred and will incur in the future substantial attorney’s fees and expenses incurred in prosecuting this action, which fees and expenses are recoverable by virtue of 42 U.S.C. §§12117(a) and 12205, and 42 U.S.C. § 2000e-5(k).
WHEREFORE, Plaintiff respectfully prays judgment in her favor and against Defendant, in the form of the Order of this Court: (1) permanently restraining Defendant from ever again retaliating against Plaintiff or any other individual, for engaging in protected activity under the Americans with Disabilities Act; (2) reinstating Plaintiff to her former position; (3) awarding her back pay in an amount yet to be determined, but not less than Seventy-Five Thousand Dollars ($75,000.00); (4) in the alternative to reinstatement, awarding her front pay in an amount yet to be determined; (5) awarding her lost fringe benefits in an amount yet to be determined; (6) awarding her compensation for physical injury, pain and suffering, future medical, mental anguish, emotional distress, loss of enjoyment of life, and other categories of actual damage, each in an amount yet to be determined but not less than Seventy-Five Thousand Dollars ($75,000.00); (7) awarding her punitive damages in the amount of $1,000,000.00 (One Million Dollars) or such other amount as a jury may deem appropriate; (8) awarding her reasonable costs, including expenses and attorneys fees; (9) awarding her damages to offset unfavorable tax consequences of any award, including attorney’s fees; and (10) awarding her such other and further relief as the Court deems just and proper.
13

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COUNT III-ADEA COLLECTIVE ACTION 51. Plaintiff Williams hereby incorporates by reference each and every allegation and averment in her General Allegations above as though fully set forth herein. 52. Cumulatively or in the alternative, Defendant engaged in a pattern and practice of discrimination against Plaintiff and others similarly situated in the respects specified in Count I in violation of the Age Discrimination in Employment Act, 29 U.S.C. § 623 et seq. 53. Plaintiff’s charge of discrimination filed with the EEOC asserted claims on behalf of herself and others similarly situated. 54. As a direct and proximate result of the continuing pattern and practice of discrimination and/or disparate treatment of Plaintiff and others similarly situated, Plaintiff and others similarly situated have suffered actual damages in the form of lost wages, lost fringe benefits, loss of earning capacity, loss of career opportunity, costs of seeking alternate income, expenses incurred in obtaining alternate income, and in other respects, all in an amount yet to be determined but not less than Seventy-Five Thousand Dollars ($75,000.00). 55. Defendant’s actions were wilful, wanton, malicious and in reckless disregard of Plaintiff’s rights and those of others similarly situated. 56. Plaintiff has already incurred and will incur in the future substantial attorney’s fees and expenses incurred in prosecuting this action, which fees and expenses are recoverable by virtue of 29 U.S.C. §§ 626(b) and 216(b).
WHEREFORE, Plaintiff respectfully prays judgment in her favor and against Defendant, in the form of the Order of this Court: (1) permanently restraining defendant Sprint/United Management Company from ever again discriminating against Plaintiff or any
14

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other individual on the basis of that individual’s age; (2) reinstating Plaintiff and others similarly situated to their former positions; (3) awarding Plaintiff and others similarly situated back pay in an amount yet to be determined, but not less than Seventy-Five Thousand Dollars ($75,000.00); (4) in the alternative to reinstatement, awarding Plaintiff and others similarly situated front pay in an amount yet to be determined; (5) awarding Plaintiff and others similarly situated lost fringe benefits in an amount yet to be determined; (6) awarding Plaintiff and others similarly situated liquidated damages in an amount equal to their actual damages; (7) awarding Plaintiff and others similarly situated their reasonable costs, including expenses and attorneys fees; (8) awarding Plaintiff and others damages to offset unfavorable tax consequences of any award, including attorney’s fees and (9) awarding Plaintiff and others similarly situated such other and further relief as the Court deems just and proper.
Respectfully submitted, 15

Case 2:03-cv-02200-JWL-DJW Document 286 Filed 07/02/04 Page 16 of 17
THE POPHAM LAW FIRM, P.C.
By: /s/ Dennis E. Egan DENNIS E. EGAN, Bar No. 70672 BERT S. BRAUD, Bar. No. 14223 STEPHEN J. DENNIS, Bar. No. 12453 323 West 8th Street, Suite 200 Kansas City, Missouri 64l05 Telephone: (8l6) 22l-2288 Telecopier No. (816) 22l-3999
KLAMANN & HUBBARD, P.A.
By: /s/ Dirk L. Hubbard JOHN KLAMANN, Bar. No. 10190 DIRK L. HUBBARD, Bar. No. 15130 7101 College Blvd., Suite 120 Overland Park, Kansas 66210 Telephone: (913) 327-7600 Telecopier: (913) 327-7800
THE MEYERS LAW FIRM, P.C.
By: /s/ Martin M. Meyers MARTIN M. MEYERS, Bar No. 14416 222 West Gregory, Suite 340 Kansas City, Missouri 64114 816-444-8500 Fax: 816-444-8508
WHITE, ALLINDER, GRAHAM & BUCKLEY, LLC
By: /s/ Deborah J. Blakely DEBORAH J. BLAKELY, Bar No. 19010 Hidden Creek Law Building 14801 East 42nd St. Independence, Missouri 64055 816-373-9080 Fax: 816-373-9319
ATTORNEYS FOR PLAINTIFFS
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Case 2:03-cv-02200-JWL-DJW Document 286 Filed 07/02/04 Page 17 of 17

DEMAND FOR JURY TRIAL Plaintiff demands trial by jury of all issues so triable as a matter of right.

/s/ Dennis E. Egan Attorney for Plaintiffs

DESIGNATION OF PLACE OF TRIAL
Plaintiff designates Kansas City, Kansas as the place where this case should be tried.
/s/ Dennis E. Egan Attorney for Plaintiff

CERTIFICATE OF SERVICE
I hereby certify that the foregoing was filed electronically and notice of such filing was made electronically to defendant’s counsel pursuant to the Electronic Case Filing Rules of the United States District Court for the District of Kansas on July 2, 2004:

John J. Yates Patrick F. Hulla Husch & Eppenberger 1200 Main St., Suite 1700 P.O. Box 26006 Kansas City, Missouri 64105
Christine F. Miller Sonni L. Fort Husch & Eppenberger 190 Carondelet Plaza, Suite 600 St. Louis, Missouri 63105-3441

David M. Eisenberg Baker Sterchi Cowden & Rice, L.L.C. 2400 Pershing, Suite 500 Kansas City, Missouri 64108-2533
Chris R. Pace Sprint Corporation 6450 Sprint Parkway Overland Park, KS 66251

/s/ Dennis E. Egan Attorney for Plaintiffs
17

 
 Case 2:03-cv-02200-JWL-DJW Document 2789 Filed 03/30/05 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams,

Plaintiff,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force. This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiffs’ pattern and practice allegations. This matter is presently before the court on plaintiffs’ objections to a portion of the magistrate judge’s March 15, 2005 order denying plaintiffs’ motion to compel discovery. The court has scheduled a hearing with the parties for Thursday, March 31, 2005 at 2:00p.m. for the purpose of resolving plaintiffs’ motion. In preparing for the hearing, however, the court has reviewed the record as it relates to plaintiffs’ motion and readily concludes (without the need for oral argument) that the magistrate judge’s order is contrary to law to the extent it places on the movant in the context of a motion to compel the initial burden of addressing each and every objection lodged by the party resisting discovery.

Case 2:03-cv-02200-JWL-DJW Document 2789 Filed 03/30/05 Page 2 of 8
The court has decided to issue a written order on this subject to clarify for these parties and parties that appear before the court in other cases what this court believes are the respective burdens appropriately born by the parties in the context of a motion to compel discovery. Moreover, while the court typically would remand the motion back to the magistrate judge for the purpose of resolving the motion on the merits, the court in this case will address the merits of plaintiffs’ motion to compel (or, more accurately, the merits of defendant’s objections) in light of the need for expedited discovery rulings in this multi-plaintiff collective action. Thus, the court will conduct the motion hearing on Thursday, March 31, 2005 at 2:00pm for the purpose of addressing the merits of defendant’s objections to Plaintiffs’ Fifth Interrogatory No. 12.
Background Plaintiffs object to that portion of the magistrate judge’s order denying plaintiffs’ motion
to compel defendant’s complete response to Plaintiffs’ Fifth Interrogatory No. 12. That particular interrogatory states as follows:
Is Sprint, as a government contractor, required to follow the “Uniform Guidelines on Employee Selection Procedures,” 28 CFR § 1607.1 et seq.? If the answer is “yes,” identify the three (3) employees of Sprint’s who are best able to testify concerning the requirements for doing “impact” analysis for selection procedures used as a basis for any employment decision, including retention and termination. Also, identify all “impact” documents and data maintained by Sprint under the “Uniform Guidelines on Employee Selection Procedures” for the listed years: 2000; 2001; 2002; 2003; 2004. Sprint objected to the interrogatory on numerous grounds. Specifically, Sprint objected on the grounds that the interrogatory seeks irrelevant information in that the Guidelines expressly state
2

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that they do not apply to responsibilities under the ADEA; that the interrogatory “misrepresents” the nature of the Guidelines because the regulations do not require employers to follow the Guidelines; that the interrogatory is cumulative and duplicative of prior discovery requests which sought documents that the court has already adjudicated are not discoverable and, thus, the interrogatory is oppressive, vexatious, burdensome and without justification; and that the interrogatory seeks to invade the attorney-client privilege and the work-product doctrine.
After satisfying the district’s “meet and confer” requirements, see D. Kan. R. 37.2, plaintiffs filed a motion to compel, among other things, defendant’s complete response to their Fifth Interrogatory No. 12. The magistrate judge summarily denied the motion with respect to Interrogatory No. 12, ruling that defendant’s objections “stand” because plaintiffs did not meet “their initial burden of addressing all of Defendant’s objections to Interrogatory No. 12.” Thereafter, plaintiffs filed their objections to this portion of the magistrate judge’s order.
Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district courts
review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a). The clearly erroneous standard applies to factual findings, see 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069, at 355 (2d ed.1997) (and cases cited therein), and requires that the district court affirm unless it is left
3

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with the “definite and firm conviction that a mistake has been committed.” Ocelot Oil, 847 F.2d at 1464 (quoting United States v. United States Gypsum Co., 333 U.S. 364, 395 (1948)). By contrast, the “contrary to law” standard permits “plenary review as to matters of law.” See Wright, Miller & Marcus, supra, § 3069, at 355; Haines v. Liggett Group Inc., 975 F.2d 81, 91 (3rd Cir. 1992); Computer Economics, Inc. v. Gartner Group, Inc., 50 F. Supp. 2d 980, 983 (S.D. Cal. 1999) (“contrary to law” standard permits independent review of purely legal determinations by a magistrate judge); Weekoty v. United States, 30 F. Supp. 2d 1343, 1344 (D.N.M. 1998) (when reviewing legal determinations made by magistrate judge, standard of review is de novo). The magistrate judge in this case denied plaintiffs’ motion to compel with respect to Interrogatory No. 12 based on a rule of law. Thus, the court reviews that order under the more lenient “contrary to law” standard.
Discussion In their objections to the magistrate judge’s order, plaintiffs do not expressly challenge the
magistrate judge’s conclusion that the initial burden was on plaintiffs, as the movants, to address each objection asserted by defendant. However, plaintiffs do challenge the magistrate judge’s denial of their request to provide further briefing with respect to Interrogatory No. 12–a request that plaintiffs made in their February 28, 2005 status report. The magistrate judge did not permit further briefing and, instead, issued an order on March 15, 2005 denying the motion to compel with respect to Interrogatory No. 12. Because plaintiffs’ status report reflects that their proposed additional briefing with respect to Interrogatory No. 12 would have addressed several (if not all)
4

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of defendant’s objections to the interrogatory, the court concludes that plaintiffs, by expressly challenging the magistrate judge’s denial of their request to provide additional briefing, have opened the door to a review of the magistrate judge’s decision that plaintiffs had (and failed to satisfy) the burden of addressing each objection raised by defendant.
As noted above, in his order denying plaintiffs’ motion to compel with respect to Interrogatory No. 12, the magistrate judge held that defendant’s objections stand because plaintiffs “have not met their initial burden of addressing all of Defendant’s objections to Interrogatory No. 12.” In support of his ruling, the magistrate judge cited to a single case, Sonnino v. University of Kansas Hospital Authority, 221 F.R.D. 661, 671 n.37 (D. Kan. 2004), a decision also authored by the magistrate judge. In Sonnino, the magistrate judge stated, in dicta, that
the party filing the motion to compel has the initial burden of addressing each boilerplate objection in its motion to compel. By doing so, that brings the objection “into play” and places the burden on the objecting party to support its objections. If the moving party fails to address an objection in its motion to compel, the objecting party need not raise it, and the objection will stand. 221 F.R.D. at 671 n.37. The magistrate judge did not cite to any authority for these statements. The court’s research reveals that the magistrate judge, on two subsequent occasions, has reiterated his belief that the moving party has the initial burden to address all objections. In DIRECTV, Inc. v. Puccinelli, 224 F.R.D. 677 (D. Kan. 2004), the judge denied a motion to compel as to certain requests based on the moving party’s failure to satisfy its burden of addressing each and every objection in the motion to compel. 224 F.R.D. at 691-92. In doing so, he relied solely on his previous opinion in Sonnino. See id. Similarly, in Swackhammer v. Sprint Corp. PCS, 225 F.R.D. 658 (D. Kan. 2004), the magistrate judge referenced the moving party’s burden to address
5

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in its motion to compel each objection asserted by the party resisting discovery. 225 F.R.D. at 660. In doing so, he again relied solely on his prior decision in Sonnino. He clarified, however, that the objection “must have some merit on its face before the Court will uphold it.” Id.
This court’s own research has not uncovered any other cases–from the Tenth Circuit, this district, or any other courts–in which a court has placed the “initial burden” on the moving party to address each and every objection lodged by the party resisting discovery. In fact, courts have long held that the burden is on the objecting party to show why an interrogatory is improper and while the burden is on the moving party to seek court action, the burden of persuasion remains at all times with the objecting party. See 8A Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 2173, at 291-93 (2d ed. 1994) (and cases cited therein). In Cotracom Commodity Trading Co. v. Seaboard Corp., 189 F.R.D. 655, 661 (D. Kan. 1999), for example, Magistrate Judge Rushfelt rejected the defendants’ argument that their attorney-client privilege objection to a request for production of documents should stand because the plaintiffs did not raise the issue of privilege in their motion to compel. As Judge Rushfelt stated,
That plaintiffs never raised the issue of privilege to the court has no materiality. The duty rested with defendants, not plaintiffs. If defendants intended to rely upon objections of privilege or work product, they had the burden to assert them in opposing the motion to compel. Id. As another court has recently emphasized, a party resisting discovery is not entitled to prevail on its objection unless that party demonstrates “specifically how, despite the broad and liberal construction afforded the federal discovery rules, each [request] is not relevant or how each
6

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question is overly broad, [unduly] burdensome or oppressive by submitting affidavits or offering evidence revealing the nature of the burden.” Ruran v. Beth El Temple of West Hartford, Inc., 226 F.R.D. 165, 167 (D. Conn. 2005). The court in Ruran further noted that proper focus is on the “opposition brief” rather than the motion itself, as the nonmoving party bears the burden of demonstrating why the discovery requests should be denied. Id. at 168; accord PAS Communications, Inc. v. Sprint Corp., 139 F. Supp. 2d 1149, 1159 (D. Kan. 2001) (where discovery sought appears relevant, party resisting discovery bears the burden of establishing lack of relevance).
The court does not criticize the magistrate judge for adopting an approach that encourages the moving party to focus the court’s attention on the specific objections asserted by the party resisting discovery. In fact, such an approach is particularly attractive in a case like this one where counsel for plaintiffs, the moving party, have a tendency to submit lengthy briefs that often address a myriad of issues but focus very little on the precise issue before the court. For this reason, the court strongly urges plaintiffs’ counsel, in submitting briefs to the court, to concentrate their efforts on the specific issue at hand rather than “muddying” the waters with arguments and facts that appear to be only tangentially related to the particular motion before the court. That being said, however, a “per se” rule requiring the moving party in the motion to compel context to bear the initial burden of addressing each and every objection asserted by the party resisting discovery is not workable. In some instances, the moving party will simply not have the requisite knowledge to address the objection in a meaningful way. For example, if a party resists discovery on the grounds that providing the information would be too burdensome, the moving party often has no
7

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knowledge as to how the information sought is maintained in the ordinary course of business. Clearly, the nonmoving party in that case is better able to address the objection in the first instance. Suffice it to say, the court does not believe that the rule espoused by the magistrate judge is a viable one.
For lawyers and parties appearing before this court, the court will continue to require the nonmoving party to bear the burden of showing specifically why the interrogatory or other discovery request is improper. In most cases, the moving party need only file its motion to compel and draw the court’s attention to the relief the party seeks. At that point, the burden is on the nonmoving party to support its objections with specificity and, where appropriate, with reference to affidavits and other evidence.
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion to review and objections to the magistrate judge’s March 15, 2005 order (doc. 2779) is granted. The court will address the merits of defendant’s objections to Interrogatory No. 12 at the motion hearing set for Thursday, March 31, at 2:00pm.
IT IS SO ORDERED.
Dated this 30th day of March, 2005, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge 8

 
 Case 2:03-cv-02200-JWL-DJW Document 3125 Filed 07/29/05 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force. This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiff’s pattern and practice allegations. This matter is presently before the court on plaintiffs’ motion for leave to consolidate actions and to file a second amended complaint (doc. 2902). Specifically, plaintiffs move to have ten plaintiffs who have filed separate actions joined as plaintiffs in this action pursuant to Federal Rule of Civil Procedure 20(a); seek to add a disparate impact claim in light of the Supreme Court’s decision in Smith v. City of Jackson, Mississippi, 125 S. Ct. 1536 (2005); and seek to expand the definition of the class. Oral argument was held on July 26, 2005. As explained below, the court now grants in part and denies in part plaintiffs’ motion. The court begins with plaintiffs’ request to have ten plaintiffs joined as named plaintiffs in

Case 2:03-cv-02200-JWL-DJW Document 3125 Filed 07/29/05 Page 2 of 8
this action. During the motion hearing, the court and the parties reached a consensus that the benefits plaintiffs desired to obtain through joinder could be achieved by simply permitting the plaintiffs in the separately filed actions to opt in to this case. Indeed, five of these plaintiffs (Sharon S. Miller; Yvonne Wood; David C. Molz; Carol L. Kippes; Sharon Herren) have already opted in to this case. Thus, the court denies without prejudice plaintiffs’ motion as to the joinder issue (subject to refiling if appropriate after the pattern and practice phase of the case) and will permit the remaining five plaintiffs in the separately filed cases, Cocherl v. Sprint , 04-2273-JWL; Selberg v. Sprint, 04-2238-JWL; Borel v. Sprint, 04-2008-JWL; Constance v. Sprint, 03-2510CM; and Sturgess v. Sprint, 03-2449-JWL, to opt in to this case.1 These plaintiffs shall file their consent to join forms no later than Friday, August 12, 2005 and they must provide to defendant completed questionnaires no later than Friday, August 26, 2005.
The court turns, then, to plaintiffs’ request to add a disparate impact claim based on defendant’s use of the “alpha rating” or “forced ranking” performance review system. Defendant opposes this amendment on the grounds that it is futile. See E.spire Communications, Inc. v. New Mexico Public Regulation Commission, 392 F.3d 1204, 1211 (10th Cir. 2004) (“A court properly may deny a motion for leave to amend as futile when the proposed amended complaint would be subject to dismissal for any reason, including that the amendment would not survive a motion for summary judgment.”). Specifically, defendant contends that plaintiffs have failed to identify the “specific part” of the alpha rating system that allegedly has a disparate impact on older workers;
1Constance v. Sprint, 03-2510-CM will be transferred from Judge Murguia to this court at the same time that this order is filed.
2

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that the alpha rating system, as a matter of law, could not have a disparate impact on older workers; that plaintiffs have misstated the “reasonable factor other than age” requirement and the rating system, as a matter of law, is reasonable; and that plaintiffs have failed to exhaust their administrative remedies with respect to a disparate impact claim. Each of these arguments is rejected and the court will permit plaintiffs to assert a disparate impact claim.
Defendant contends that plaintiffs have failed to identify a “specific part” of the alpha rating system that has a disparate impact on older workers. This argument is based on the Supreme Court’s statement in City of Jackson that an employee is responsible for “isolating and identifying the specific employment practices that are allegedly responsible for any observed statistical disparities.” 125 S. Ct. at 1545 (emphasis in original). The Supreme Court criticized the employees in City of Jackson for failing to “identify any specific test, requirement, or practice within the pay plan that has an adverse impact on older workers” and noted that the employees did “little more than point out that the pay plan at issue is relatively less generous to older workers than to younger workers.” Id. The City of Jackson case does not suggest that the plaintiffs here must identify a “specific part” of the alpha rating system. Rather, the alpha rating system itself is a specific employment practice that plaintiffs have identified within the context of the RIF that allegedly has an adverse impact on older workers and causes older workers to be disproportionately affected by the RIF. Contrary to defendant’s argument, then, plaintiffs have done far more than point out a “generalized policy” that leads to disparate impact. See Finch v. Hercules, Inc., 865 F. Supp. 1104, 1128 (D. Del. 1994) (plaintiff who challenged RIF’s forced ranking process sufficiently identified “specific employment practice” for purposes of
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establishing a prima facie case of disparate impact). Defendant’s second argument is that there is simply no component of the alpha rating
system which could operate to result in a disproportionate negative impact on older workers. According to defendant, although the review system incorporates subjective performance criteria, nothing inherent in the use of such criteria would have a disparate impact on older workers; at the most, the use of subjective criteria would enable decisionmakers to mask their age-bias and, thus, would support a claim for intentional discrimination. This argument is rejected. First, the use of subjective criteria is a proper subject for a disparate impact analysis. See Watson v. Fort Worth Bank and Trust, 487 U.S. 977, 990 (1988) (disparate impact analysis is in principle no less applicable to subjective employment criteria than to objective or standardized tests). Second, plaintiffs are certainly allowed to plead in the alternative and the court cannot say at this juncture that plaintiffs can prove no set of facts that would entitle them to relief under a disparate impact theory. While the Second Circuit has suggested (and defendant urges) that the same policy or practice cannot be the focus of both a disparate impact claim and a disparate treatment claim, see Maresco v. Evans Chemetics, Div. of W.R. Grace & Co., 964 F.2d 106, 115 (2d Cir. 1992), plaintiffs here have alleged facts that would support both theories.
Defendant also contends that the amendment should be denied because the proposed complaint “does not correctly allege the ‘reasonable factor other than age’ component of an ADEA disparate impact claim.” In their proposed complaint, plaintiffs state that the “alpha rating system had a disparate impact on persons age 40 and over, and Defendant has no reasonable factor other than age to explain that disparate impact.” According to defendant, the key is whether the decision
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to utilize the challenged practice was based on reasonable factors other than age (RFOA). Regardless of whether plaintiffs misstated the issue, the amendment will not be denied on that basis. Plaintiffs have no obligation to plead anything at all with respect to the RFOA defense–a defense that is defendant’s burden to plead and prove. See Palochko v. Manville Corp., 21 F.3d 981 (10th Cir. 1994) (suggesting that RFOA defense is an affirmative defense). Defendant also contends that its decision to utilize the alpha rating system is reasonable as a matter of law and, thus, the amendment should be denied. This argument is simply not appropriate at this juncture. See Bloom v. Ruhnke, 2002 WL 1472236 (10th Cir. July 10, 2002) (issue of whether defendant had reasonable justification for instituting policy could not be resolved on motion to dismiss; reasonableness had to be demonstrated at trial or through a motion for summary judgment).
Finally, defendant claims that the amendment should be denied because plaintiffs have not exhausted their administrative remedies with respect to a disparate impact claim. This argument is rejected for two alternative reasons. First, prior to the Supreme Court’s ruling in City of Jackson, the Tenth Circuit had expressly held that disparate impact claims are not cognizable under the ADEA. See Ellis v. United Airlines Inc., 73 F.3d 999, 1007 (10th Cir. 1996). While the court’s research has not uncovered any authority in this context or a sufficiently analogous context, the court simply does not believe that plaintiffs would have been required to exhaust a disparate impact claim when, at the time that plaintiffs were pursuing their administrative remedies, the Circuit had expressly rejected the viability of that claim and the Supreme Court simply had not addressed the issue. Because the Circuit did not recognize the claim at all, there was simply no remedy for the claim that plaintiffs could exhaust. Second, several of the
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underlying EEOC charges in this case reference the performance review system. Thus, because the facts underlying plaintiffs’ disparate impact claim appear in the administrative charge, a disparate impact claim is reasonably related to the disparate treatment claims asserted by plaintiffs. See Brown v. Coach Stores, Inc., 163 F.3d 706, 712 (2d Cir. 1998) (disparate impact claim was reasonably related to failure-to-promote disparate treatment claim where EEOC investigation would have included investigation of promotion policies and their effect on minority employees); Gomes v. Avco Corp., 964 F.2d 1330 (2d Cir. 1992) (same, where investigation of disparate impact claim would reasonably have flowed from an investigation of disparate treatment claim; complaint simply asserted two different theories of relief to remedy particular incidents of discrimination described in EEOC charge).
Having rejected each of defendant’s arguments concerning the addition of a disparate impact claim, the court will permit plaintiffs to amend their complaint to assert this claim. See Townsend v. Weyerhaeuser Co., 2005 WL 1389197 (W.D. Wis. June 13, 2005) (in light of City of Jackson, permitting plaintiff to advance disparate impact claim for the first time in response to defendant’s motion for summary judgment); Lit v. Infinity Broadcasting Corp., 2005 WL 1377842 (E.D. Pa. June 8, 2005) (granting motion to amend complaint to include disparate impact claim in light of City of Jackson case, extending discovery on that issue and delaying summary judgment briefing on that claim).
The final issue raised by plaintiffs’ motion is their efforts to expand the class to include those employees whose employment was terminated beginning in late July 2001 (the class is presently limited to those employees who, among other things, were terminated on or after
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October 1, 2001) and to include certain employees who were classified as “E grade” (executive level) employees (the class is presently limited to those employees who were assigned to job grades 71 through 79). The court will not permit plaintiffs to expand the class definition at this juncture as it finds the request to do so untimely. See Moore v. Reynolds, 153 F.3d 1086, 1116 (10th Cir. 1998) (district court may deny a motion to amend when the request is untimely or a result of undue delay). Plaintiffs have been on notice since at least August 2004 that the reduction in force may have started earlier than October 2001. For example, Linda Ford, a former employee of defendant, filed her consent to join form on August 13, 2004 and she indicated on the form that her employment was terminated on July 21, 2001. Similarly, Rebecca Castro filed a consent to join form on August 27, 2004 indicating that her employment was terminated on July 21, 2001. Plaintiffs made no attempt to expand the class definition at any time after receiving these consent to join forms. While it is less certain when plaintiffs became aware that certain individuals terminated in the reduction in force were “E grade” employees, the court is nonetheless convinced that plaintiffs’ attempt to expand the class definition to include executive-level employees for the first time after nearly two years of discovery simply comes too late.
IT IS THEREFORE ORDERED BY THE COURT that plaintiffs’ motion for leave to consolidate actions and to file second amended complaint (doc. 2902) is granted in part and denied in part. Plaintiffs shall file their second amended complaint, consistent with this order, no later than Friday, August 12, 2005.
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Case 2:03-cv-02200-JWL-DJW Document 3125 Filed 07/29/05 Page 8 of 8 IT IS FURTHER ORDERED BY THE COURT that Terry Lee Cocherl; Carolyn Selberg;
John Borel; Steve Constance; and Peggy Sturgess shall file their consent to join forms no later than Friday, August 12, 2005 if they desire to opt in to this collective action and they must provide to defendant completed questionnaires no later than Friday, August 26, 2005.
IT IS SO ORDERED. Dated this 29th day of July, 2005, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 3157 Filed 08/12/05 Page 1 of 20

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams,

Plaintiff,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiff’s pattern and practice allegations. This matter is presently before the court on defendant’s motion to set aside and/or modify and objections to the magistrate judge’s June 22, 2005 order requiring Sprint to produce to plaintiff the following categories of documents: (a) candidate selection worksheets and spreadsheets; (b) realignment selection worksheets and spreadsheets; (c) all other worksheets and spreadsheets regarding or relating to the RIF; (d) human resources (HR) notes, minutes and agendas regarding the RIF; (e) all other HR notes or documents regarding RIF decisions; (f) all emails transmitting spreadsheets; (g) all e-mails about RIF decisions; (h) all e-mails transmitting RIF instructions or guidelines; (i) all RIF instructions or guidelines; (j) all e-mails transmitting

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or discussing RIF timetables or updates; (k) all summary documents regarding RIF reduction numbers by divisions, department or other organizational nature; (l) all documents regarding or relating in any way to the reason defendant made the decision to do a RIF; (m) all documents received by defendant in 2001, 2002 and/or 2003 from any financial consultant, investment banker, or investment service recommending a RIF; (n) all documents regarding or relating in any way to any alternatives considered other than a RIF; (o) all documents regarding or relating in any way to discussions, determinations, and/or decisions regarding the number of employees to RIF and/or amount/percentage of budget to be cut; (p) all before, during and after RIF organizational charts; (q) all documents prepared by or on behalf of defendant for any management (executives, presidents, vice presidents, directors and/or managers) in connection with the RIF during 2001, 2002 and/or 2003; (r) all documents prepared by or on behalf of defendant for any management (executives, presidents, vice presidents, directors and/or managers) describing any selection criteria for termination of employees in connection with the RIF during 2001, 2002 and/or 2003; (s) all documents prepared by or on behalf of defendant for any management (executives, presidents, vice presidents, directors and/or managers) and/or reviewed by any management which refer or relate in any way to positions eliminated or to be eliminated during 2001, 2002 and/or 2003; (t) all documents and/or computerized databases containing data used in any fashion in connection with the RIF in 2001, 2002 and/or 2003; (u) all documents relating to any computerized record-keeping and/or report writing program for information concerning the RIF in 2001, 2002 and/or 2003.
Defendant objects to each of the twenty-one categories of documents that it has been 2

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ordered to produce. As set forth in more detail below, defendant’s motion is granted in part and denied in part.
Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district courts
review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a). The clearly erroneous standard applies to factual findings, see 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069, at 355 (2d ed.1997) (and cases cited therein), and requires that the district court affirm unless it is left with the “definite and firm conviction that a mistake has been committed.” Ocelot Oil, 847 F.2d at 1464 (quoting United States v. United States Gypsum Co., 333 U.S. 364, 395 (1948)). The standard of review applicable to defendant’s motion here, however, is somewhat modified for two reasons. First, the court, at a hearing on April 26, 2005, made various rulings concerning the concept of “individualized” or “plaintiff-specific” discovery and advised the parties that any subsequent disputes concerning rulings made at that hearing would be heard by the court as opposed to the magistrate judge. Defendant’s objections concerning these issues, then, have not been presented to the magistrate judge in the first instance and the court reviews those objections de novo. Second, the magistrate judge’s ruling that is memorialized in the June 22, 2005 written order was initially made orally on June 16, 2005 in an expedited fashion whereby defendant did
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not have the opportunity to advance several of the objections that are advanced here.1 Those objections, then, are also reviewed de novo by the court.
The April 26, 2005 Hearing Defendant’s primary objection to the magistrate judge’s order of June 22, 2005 is that
many of the discovery requests reflected in the order “exceed the parameters of discovery” established by the court during a motion hearing and status conference held on April 26, 2005. By way of background, the court held a motion hearing on April 26, 2005 with respect to a motion to review an order entered by the magistrate judge in which he denied plaintiff’s motion to compel defendant’s responses to several sets of requests for production of documents propounded by individual plaintiffs. The magistrate judge denied the motion based on his belief that this court had previously held that any “individualized” discovery (or discovery of information specific to individual plaintiffs) would not be permitted at this stage of the litigation. As the court clarified at the April 26, 2005 hearing, however, some plaintiff-specific information is relevant and discoverable for purposes of plaintiff’s pattern and practice claim. By way of example, the court and the parties discussed at the hearing (in the context of opt-in plaintiff Ken Cromley’s discovery requests) that various requests concerning younger employees who were retained or transferred
1The court is in no way criticizing the magistrate judge for his expedited review of plaintiff’s discovery requests. Indeed, as the court and the parties agree, an expedited process for the resolution of discovery disputes in this case–a case that has approximately 1700 opt-in plaintiffs and is highly document intensive–is critical to keeping this case moving toward an ultimate resolution.
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compared to an individual plaintiff; requests concerning positions for which the individual plaintiff had applied; and information concerning the individual plaintiff’s alpha review, or performance rating, would be appropriate categories of information for discovery at this stage (subject to any objections defendant might assert other than “plaintiff-specific discovery is not relevant at this stage of the litigation”).
That being said, however, the court expressly rejected plaintiff’s proposal to seek that type of information for 200 individual plaintiffs, as that number was arbitrarily selected by plaintiff. Rather, the court limited plaintiff to propounding such requests on behalf of 20 individual plaintiffs and advised plaintiff that she would have to provide an affidavit from an expert indicating the necessity to gather additional information in order to offer a reliable opinion or otherwise perform an appropriate analysis to support a request for plaintiff-specific discovery on a greater number of individual plaintiffs (unless plaintiff could obtain defendant’s agreement as to some number higher than 20). At the conclusion of the hearing, then, plaintiff received the green light to propound plaintiff-specific discovery requests on behalf of 20 individual plaintiffs of her choosing with the understanding that she would need to seek permission from the court, based on defendant’s agreement or otherwise supported by expert testimony, before she sought plaintiffspecific discovery on a larger number of individual plaintiffs. Thus, while the court concluded that plaintiff-specific discovery was not, by definition, foreclosed at this stage of the litigation, it limited such discovery, in the absence of further evidence from plaintiff or agreement of the parties, to 20 individual plaintiffs. To date, plaintiff has not sought permission from the court to expand her plaintiff-specific discovery efforts beyond 20 individual plaintiffs.
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With that framework in mind, the court turns to the specific categories of information that the magistrate judge ordered defendant to produce and that defendant contends exceed the parameters of discovery established by the court on April 26, 2005. Subparagraph (c) of the order requires defendant to produce “all other worksheets/spreadsheets regarding or relating to the RIF.” Defendant asserts that plaintiff’s counsel has advised that this request includes documents regarding individual termination decisions on all employees terminated in the RIF (or series of RIFs) at issue in this case. According to defendant, then, the request, as clarified by plaintiff’s counsel in discussions with defense counsel, exceeds the parameters of discovery established by the court at the April 26, 2005 hearing.2 In her response, plaintiff suggests that this request does not seek any discovery which could be considered “individual” discovery. Indeed, the request, on its face, suggests that plaintiff is only seeking those worksheets or spreadsheets relating to the overall RIF itself including, for example, the decision to conduct the RIF (or series of RIFs) at issue in this case and/or the implementation of the RIF itself, including the total number of individuals targeted for termination in the RIF and whether certain positions (as opposed to
2Defendant also objects to this request on the grounds that it is overly broad because it lacks temporal limitations. This objection is overruled. While the request does not contain an express temporal limitation, a limitation is inherent in the nature of the request. The request is expressly limited to “the RIF” which can only mean the RIF or series of RIFs at issue in this case, a RIF that was implemented beginning in October 2001 and ending in March 2003. Presumably, then, documents responsive to the request would date back to the time period leading up to October 2001 (to the extent responsive worksheets or spreadsheets were generated in preparation for the first wave of layoffs) and just beyond March 2003 (to the extent responsive worksheets or spreadsheets were generated after the last wave of layoffs). Defendant asserts this same objection to many of the requests set forth in the June 22, 2005 order and each of those “temporal limitation” objections are overruled.
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individuals) were specifically targeted for elimination in the RIF. To that extent, defendant’s objection is overruled and it is required to produce the information. To the extent, however, that plaintiff does seek to discover worksheets and spreadsheets that might reflect information about individual termination decisions or other information that relates not to the overall RIF but to specific plaintiffs, the objection is sustained as that request would clearly exceed the scope of discovery described at the April 26, 2005 hearing and defendant is not required to produce that information.
In subparagraph (d), defendant is required to produce “HR notes, minutes, agendas regarding the RIF.” Defendant objects on the grounds that the request could be interpreted to include HR notes regarding “each individual RIF decision” and, to that extent, the request exceeds the scope of discovery contemplated by the court on April 26, 2005. In her response, plaintiff clarifies that she is, in fact, seeking HR notes, minutes and agendas regarding “each RIF decision” and she urges that such information is discoverable. To the extent plaintiff is suggesting that she is entitled to discover HR notes, minutes and agendas that relate to the individual termination decisions of any of the 14,700 employees terminated in the RIF, the court disagrees. Such discovery would reach far beyond the limits of discovery authorized by the court at the April 26, 2005 hearing. More importantly, the request would defeat the purpose of having a collective action and is entirely inconsistent–at least at this phase–with a pattern and practice case. As the Tenth Circuit explained in Thiessen, the “initial focus in a pattern-or-practice case is not on individual employment decisions, ‘but on a pattern of discriminatory decisionmaking.’” See Thiessen v. General Elec. Capital Corp., 267 F.3d 1095, 1006 (10th Cir. 2001) (quoting Cooper v. Fed. Reserve Bank of
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Richmond, 467 U.S. 867, 876 (1984)). Plaintiff has not alleged that discovery of all HR materials concerning 14,700 individual termination decisions is necessary to enable her to establish a pattern and practice of discrimination. See Owens v. Sprint/United Management Co., 221 F.R.D. 649, 652 (D. Kan. 2004) (when the request is overly broad on its face or when relevancy is not readily apparent, the party seeking the discovery has the burden to show the relevancy of the request).
Thus, defendant’s objection to subparagraph (d) is sustained to the extent plaintiff is seeking HR notes, agendas and minutes regarding individual termination decisions and defendant is not required to produce documents responsive to that request. However, defendant is required to produce HR notes, minutes and agendas relating to the overall RIF itself including, for example, the overarching decision to conduct the RIF (or series of RIFs) at issue in this case, the total number of individuals targeted for termination in the RIF, whether certain positions (as opposed to individuals) were specifically targeted for elimination in the RIF, general guidelines concerning the implementation of the RIF and the consideration of any selection criteria for the RIF.
Subparagraphs (e) and (g) of the June 22, 2005 order require defendant to produce “all other HR notes or documents regarding RIF decisions” and “all e-mails about RIF decisions.” According to defendant, the express reference to “RIF decisions” suggests that plaintiff is seeking the production of any e-mail (drafted by any Sprint employee) or any HR document concerning any of the nearly 14,700 separate RIF-related termination decisions that occurred during the relevant time frame. While plaintiff states in her response that she is not seeking plaintiff-specific discovery but only “basic RIF documents related to the core pattern and practice issues in this
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case,” and while her counsel emphasized at the hearing before Judge Waxse that her request for “e-mails about RIF decisions” was not intended to seek documents about individual decisions but only “documents about the RIF,” the requests on their face are as broad as defendant suggests. In fact, the requests are even broader than defendant suggests as the requests would include not only documents regarding 14,700 termination decisions, but also documents regarding thousands and thousands of retention decisions.
The court agrees with defendant that these requests, to the extent that they would include all e-mails and all HR notes or documents regarding the individual termination decisions of any of the 14,700 employees terminated in the RIF, reach far beyond the limits of discovery authorized by the court at the April 26, 2005 hearing. Moreover, as explained above, the requests defeat the purpose of having a collective action and are inconsistent with the phased framework of a pattern and practice case. Plaintiff has not alleged that the nature and volume of the information requested in subparagraphs (e) and (g) are necessary to enable her to establish a pattern and practice of discrimination. In fact, as explained above, her response and her counsel’s argument at the hearing before Judge Waxse suggest that the requests do not even seek information about individual decisions.
Thus, defendant’s objections to subparagraphs (e) and (g) are sustained and defendant is not required to respond to the requests. Plaintiff may resubmit to defendant revised requests that are narrowly tailored to those items that she actually intends to discover. Those requests would presumably be limited to notes or documents drafted by defendant’s HR employees or e-mails drafted by any Sprint employee concerning, for example, the overarching decision to conduct the
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RIF (or series of RIFs) at issue in this case, the total number of individuals targeted for termination in the RIF, whether certain positions (as opposed to individuals) were specifically targeted for elimination in the RIF, general guidelines concerning the implementation of the RIF and the consideration of any selection criteria for the RIF.
In subparagraphs (h) and (i) of the June 22, 2005 order, defendant is required to produce “all e-mails transmitting RIF instructions or guidelines” and “all RIF instructions or guidelines.” According to defendant, plaintiff’s counsel has advised defendant that the requests were intended to include not only global instructions or guidelines to management but also any instructions or guidance of any kind to management regarding individual RIF-related decisions. Defendant asserts, then, that the requests exceed the parameters of discovery established by the court at the April 26, 2005 hearing. While it is not entirely clear from her response, plaintiff suggests that, in fact, she is only seeking global, overarching instructions and guidelines relating to the RIF and not instructions or guidance relating to individual termination decisions. A plain reading of the requests reflects that plaintiff is seeking global instructions or guidelines regarding implementation of the RIF. To that extent, defendant’s objection is overruled and it is required to produce the information. To the extent the requests seek to discover instructions or guidance about individual termination decisions, retention decisions or anything other than “global” issues, the objection is sustained as those requests would clearly exceed the scope of discovery described at the April 26, 2005 hearing and defendant is not required to produce that information.
Subparagraph (j) of the June 22, 2005 order requires defendant to produce “all e-mails transmitting or discussing RIF timetables or updates.” Defendant objects to the request because,
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as written, it encompasses all e-mail communications relating to the timing of individual separations as well as updates concerning individual separations. Plaintiff’s response does not clarify the nature of the documents sought by the request. To the extent the request seeks e-mails transmitting or discussing timetables or updates about the overall RIF, defendant’s objection is overruled and it is required to produce any responsive documents. To the extent the request seeks e-mails transmitting or discussing timetables or updates about any individual termination decisions or retention decisions, the objection is sustained as that request would clearly exceed the scope of discovery described at the April 26, 2005 hearing.
Subparagraph (p) of the June 22, 2005 order requires defendant to produce “all before, during, and after RIF organizational charts.” While defendant does not object to producing charts demonstrating corporate structure “before, during and after” RIF events (aside from its objection that the request is duplicative of an earlier request, an objection which the court overrules below), defendant does object to producing charts identifying individual employees as that request would reach beyond the scope of discovery authorized by the court on April 26, 2005. Significantly, defendant does not contend that providing organizational charts identifying individual employees, to the extent such charts exist, would be unduly burdensome. The court does not believe that this request, even to the extent it seeks organizational charts identifying individual employees within various organizational units before, during and after the RIF, exceeds the parameters of discovery authorized by the court in April. Presumably, “organizational charts” would not reflect the reasons underlying 14,700 individual termination decisions or the reasons underlying defendant’s retention decisions but would reflect only the bigger picture of which employees were retained, which
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employees were transferred and which employees were terminated in the RIF. To the extent such charts exist, then, they would not constitute “plaintiff-specific” information. Defendant’s objection is overruled.
Subparagraphs (q), (r) and (s) of the June 22, 2005 order require defendant to produce all documents prepared by or on behalf of defendant for any management in connection with the RIF during 2001, 2002 and/or 2003 including documents describing any selection criteria for termination of employees and documents relating to positions eliminated or scheduled to be eliminated during 2001, 2002 and/or 2003. Defendant asserts that these requests exceed the boundaries of permissible discovery at this stage of the litigation. To the extent the requests seek documents relating to general selection criteria and positions scheduled for elimination, the objection is overruled as such discovery is simply not the type of “plaintiff-specific” discovery limited by the court at the April 26, 2005 hearing. However, plaintiff’s broader request for “all documents prepared by or on behalf of defendant for any management in connection with the RIF” could be construed to include documents relating not only to the overall RIF but also to individual termination decisions or specific employees or plaintiffs. To the extent the request seeks such information, defendant’s objection is sustained as that request would clearly exceed the scope of discovery described at the April 26, 2005 hearing and defendant is not required to produce that information. The objection is overruled to the extent the request is limited to documents concerning the overall decision to conduct the RIF (or series of RIFs) at issue in this case and/or the implementation of the RIF itself, including the total number of individuals targeted for termination in the RIF, whether certain positions (as opposed to individuals) were specifically
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targeted for elimination in the RIF, general guidelines concerning the implementation of the RIF and the consideration of any selection criteria for the RIF.
Finally, in subparagraph (t) of the June 22, 2005 order, the magistrate judge orders defendant to produce “all documents and/or computerized databases containing data used in any fashion in connection with the RIF in 2001, 2002 and/or 2003.” Defendant asserts that the request exceeds the bounds of discovery established at the April 26, 2005 hearing because it seeks “entire databases.” As explained above, the April hearing addressed only “individualized” discovery or discovery of information specific to individual plaintiffs. Defendant does not suggest that the databases requested by plaintiff would reveal information specific to individual plaintiffs (e.g., information about the reasons for individual termination decisions). The mere fact that the databases might identify various employees by name (and defendant does not even suggest that they do) does not render the information contained in the databases “plaintiff-specific.” Defendant’s objection, then, is overruled.
The Waiver Issue Defendant next objects to the magistrate judge’s order on the grounds that several of
plaintiff’s requests (i.e., the requests identified in subparagraphs (m), (p), (q), (r), (s), (t) and (u) of the order) are identical to requests appearing in plaintiff’s First Request for Production of Documents filed in September 2003. While defendant objected to these requests in November 2003, plaintiff did not timely compel production of the documents and did not timely contest defendant’s objections to the requests. Indeed, this court, on February 6, 2004, denied plaintiff’s
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motion to compel production relating to her First Request for Production of Documents on the grounds that the motion was untimely under the local rules of this court. According to defendant, then, plaintiff has waived her right to contest Sprint’s objections to these requests.
Plaintiff readily concedes that these requests mirror identical requests made in September 2003 and she further concedes that she did not act timely in response to the objections asserted by defendant in November 2003. According to plaintiff, she is not precluded from propounding these discovery requests at this phase of the litigation, a phase where the case has now been certified and the parties are preparing for a trial on plaintiff’s pattern-and-practice allegations, when her September 2003 discovery and defendant’s objections thereto occurred in the first stage of this litigation–prior to certification as a collective action. Judge Waxse agreed with plaintiff and rejected defendant’s waiver argument at the June 16, 2005 hearing. As explained by Judge Waxse:
I guess I’m not convinced that we ought to resolve this based on how it was dealt with in the past. My goal is to get the information that’s discoverable in a cost efficient and timely manner. And so it appears to me that even though you’ve pointed out plenty of reasons why this should have been done a long time ago, the more important question is: Is there any reason it shouldn’t be done now other than time? Transcript of June 16, 2005 Hearing at 35. Defendant has not shown that Judge Waxse’s conclusion is clearly erroneous or contrary to law. In fact, this court, in denying plaintiff’s motion to compel as untimely in February 2004, specifically contemplated that plaintiff would be entitled to propound the same discovery requests in the pattern-and-practice phase of the litigation. In concluding that plaintiff was not prejudiced
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by the court’s denial of her motion to compel, the court advised the parties that if the case was ultimately certified as a collective action, then “the kind of information that I think the plaintiff sought here, this is well within the scope of information that you ought to receive here,” and that “the issues that are addressed in that discovery are subject to being revisited at a later date.” See Transcript of Feb. 6, 2004 Hearing at 6-7, 28. Plaintiff’s approach with respect to these particular requests and Judge Waxse’s handling of the waiver issue are both entirely consistent with what was contemplated by the court back in February 2004. Defendant’s objection is overruled.
Requests About Which No Real Dispute Exists A review of the parties’ briefs reveals that no real dispute exists about several of the
requests made by plaintiff. For example, subparagraphs (a) and (b) of Judge Waxse’s June 22, 2005 order direct defendant to produce candidate selection worksheets/spreadsheets and realignment selection worksheets/spreadsheets. In its motion, defendant asserts that it has “fully responded” to previous, similar requests from plaintiff and that no further response should be required. The previous requests, however, were limited to candidate selection worksheets containing the job position and/or name of any of the opt-in plaintiffs. The request set forth in Judge Waxse’s order is not limited to opt-in plaintiffs but seeks candidate selection and realignment worksheets including the names of all individuals impacted by the RIF (or series of RIFs extending from October 2001 through March 2003) at issue in this case. While defendant notes that it has already produced “RIF-related due diligence spreadsheets prepared by Sprint’s HR organization” and that these documents are responsive to the requests set forth in Judge Waxse’s
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order, the requests are not limited to “due diligence” spreadsheets and are not limited to documents prepared by defendant’s human resources organization. It is unclear, then, whether defendant has in its possession other documents that are responsive to the requests or whether defendant is asserting that the documents already produced are the only responsive documents in its possession. Thus, Sprint must produce any additional documents responsive to these requests within 30 days of the date of this order and, at the same time, must certify to plaintiff that all documents in its possession responsive to these requests have been produced and that no additional responsive documents exist in its possession.3
With respect to the request identified in subparagraph (m) of Judge Waxse’s order (all documents received by defendant in 2001, 2002 and/or 2003 from any financial consultant, investment banker, or investment service recommending a RIF), defendant asserts that no responsive documents exist. Defendant, then, must certify under oath to plaintiff within 30 days of the date of this order that it does not have documents in its possession responsive to this request. With respect to the request identified in subparagraph (f) of Judge Waxse’s order (all emails transmitting spreadsheets), defendant asserts that the request is overly broad, vague and ambiguous because the request, on its face, seeks any e-mail created by any Sprint employee attaching spreadsheets of any nature at any time. Defendant, however, presumes (correctly, as confirmed by plaintiff) that plaintiff is seeking e-mails transmitting spreadsheets relating to the RIF at issue in this case and, to that end, has agreed to produce and, apparently, is in the process
3Significantly, defendant does not contend that the requests set forth in subparagraphs (a) and (b) are unduly burdensome.
16

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of producing, e-mails transmitting spreadsheets relating to the RIF at issue in this case. Thus, defendant need only certify under oath to plaintiff within 30 days of the date of this order that all documents responsive to the request, as narrowed by the parties’ agreement, have been produced.
The requests identified in subparagraphs (l), (n) and (o) of Judge Waxse’s order seek documents relating to the reason defendant made the decision to do a RIF; any other alternatives considered other than a RIF; and discussions, determinations and/or decisions regarding the number of employees to RIF and/or the amount/percentage of budget to cut. Defendant asserts that these requests are vague, ambiguous and overly broad because it is unclear whether plaintiff seeks documents concerning the rationale for individual RIF decisions and “RIFs within small organizations” as opposed to “RIFs including significant numbers of individuals.” A plain reading of the requests, however, indicates that the requests do not seek plaintiff-specific information and do not seek information relating to individual RIF decisions (i.e., decisions regarding which employees would be retained and which employees would be terminated and the reasons underlying those decisions). Rather, the requests seek documents relating to the overarching decision to conduct the RIF at issue in this case in which Sprint terminated the employment of nearly 15,000 employees. To that extent, defendant asserts that it has “produced communications and other documents” related to such requests. It is unclear, however, whether Sprint has produced all responsive documents in its possession. Thus, Sprint must produce any additional documents responsive to these requests within 30 days of the date of this order and, at the same time, must certify to plaintiff that all documents in its possession responsive to these requests have been produced and that no additional responsive documents exist in its possession.
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Remaining Requests and Objections Thereto In subparagraph (k) of Judge Waxse’s June 22, 2005 order, he directs defendant to produce
“all summary documents regarding RIF reduction numbers by divisions, department or other organizational nature. These are documents that break down the RIF decisions and the areas affected, as well as the headcount of employees and contractors.” Defendant objects to this request on the grounds that it is vague, ambiguous and has no temporal scope. The court readily overrules defendant’s temporal scope objection for the reasons set forth above in footnote 2 of this order.
With respect to defendant’s assertion that the request is vague and ambiguous, the court disagrees and finds the objection disingenuous. According to defendant, it is unclear whether plaintiff seeks “any document regarding employee and contractor headcount, any documents regarding RIFs, and/or any documents that specifically include information about employee and contractor headcount and RIFs.” On its face, the request clearly does not seek any and all documents regarding employee and contractor headcount. It seeks all “summary” documents that reflect the headcount of employees and contractors by division, department or other organizational unit after the execution of the RIF at issue in this case (the RIF that was implemented beginning in October 2001, ending in March 2003 and affecting nearly 15,000 employees). Similarly, the request obviously does not seek any and all documents regarding RIFs. Again, it seeks “summary” documents reflecting by division, department or other organizational nature the numbers of individuals affected by the particular RIF (or series of RIFs) at issue in this case from October 2001 through March 2003.
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Defendant also contends that it is unclear whether plaintiff seeks documents which include information about decisionmakers, departments or other organizational structure. This assertion is meritless. A plain reading of the request does not call for any information concerning decisionmakers. It seeks information concerning organizational structure and department only to the extent summary documents exist which break down by department or some other organizational unit the numbers of individuals affected by the RIF at issue in this case. Defendant, then, shall produce the information requested in subparagraph (k).
Subparagraph (u) of the June 22, 2005 order requires defendant to produce “all documents relating to any computerized record-keeping and/or report writing program for information concerning the RIF in 2001, 2002 and/or 2003.” Defendant objects to this request on the grounds that it “‘lacks particularity” and is overly broad.4 Defendant, however, fails to explain how the request is overly broad and any alleged overbreadth is not apparent on the face of the request. The court, then, must overrule the objection. See Williams v. Sprint/United Management Co., 2005 WL 731070, at *4 (D. Kan. Mar. 30, 2005) (a party resisting discovery on the grounds that the request is overly broad is not entitled to prevail on its objection unless that party demonstrates specifically how, despite the broad and liberal construction afforded the federal discovery rules, each request is overly broad); Stoldt v. Centurion Indus., Inc., 2005 WL 375667, at *2 (D. Kan. Feb. 3, 2005) (unless a discovery request is overly broad on its face, the party resisting discovery
4Defendant’s only other objection to subparagraph (u) is that plaintiff waived her right to contest defendant’s objections by failing to compel a response to this request when it was first propounded back in September 2003. The court, however, has already rejected defendant’s waiver argument.
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has the burden to support its overbreadth objection).
IT IS THEREFORE ORDERED BY THE COURT THAT defendant’s motion to set aside and/or modify and objections to the magistrate judge’s June 22, 2005 order (doc. 3016) is granted in part and denied in part.
IT IS FURTHER ORDERED BY THE COURT THAT defendant, to the extent its objections have been overruled in this order, shall produce documents responsive to the requests within 30 days of the date of this order. If defendant cannot in good faith meet this deadline for production, it shall notify the court within 14 days of the date of this order that it anticipates needing additional time to fulfill its discovery obligations, when it anticipates it will be able to fulfill its obligations, and the reasons that the obligations cannot be met within the 30-day time frame.
IT IS SO ORDERED.
Dated this 12th day of August, 2005, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 3194 Filed 08/31/05 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams,

Plaintiff,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiffs’ pattern and practice allegations. This matter is presently before the court on plaintiffs’ motion to review and objections to the magistrate judge’s July 12, 2005 order granting defendant’s motion for protective order regarding advertising and marketing discovery. As set forth in more detail below, plaintiffs’ motion is denied as the magistrate judge did not abuse his discretion in granting the protective order.

Case 2:03-cv-02200-JWL-DJW Document 3194 Filed 08/31/05 Page 2 of 7
Background On April 21, 2005, plaintiffs filed a deposition notice duces tecum under Federal Rule of
Civil Procedure 30(b)(6) seeking to depose Sprint’s designated representative to give testimony on Sprint’s behalf “concerning its public relations, advertising and/or marketing programs designed to [sic] its brand and/or public image during the years 2001, 2002 and 2003.” The notice also requested that the designated individual bring to the deposition various advertising and marketing materials, including documents relating to internal policy decisions regarding what Sprint’s image was and/or should be and documents provided to or received by any professional advertising or marketing organization concerning Sprint’s brand and/or image.
On June 8, 2005, Sprint filed a motion for protective order under Rule 26(c), asserting that information and documents concerning Sprint’s advertising and marketing efforts are wholly irrelevant to plaintiffs’ claims.1 On July 12, 2005, the magistrate judge granted defendant’s motion, concluding that “plaintiffs have not shown that their discovery request for information concerning Defendant’s public relations, advertising and marketing programs designed for its brand and public image is reasonably calculated to lead to the discovery of admissible evidence based upon the current claims in this case.” Plaintiffs object to the magistrate judge’s order, contending that the requested discovery is relevant as it will likely show that “senior level managers wanted Sprint’s marketing efforts and its image or brand to reflect a culture of youth,
1While defendant’s initial objections to plaintiff’s notice included objections in addition to relevance, defendant’s motion for protective order focused solely on defendant’s relevance objection.
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just as they wanted the Sprint workforce to be a culture of youth.”
Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district courts
review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a).
In the context of nondispositive discovery disputes, including the decision to grant a protective order pursuant to Federal Rule of Civil Procedure 26(c), a district court will review the magistrate judge’s order for an abuse of discretion. See Microsoft v. MBC Enterprises, 2004 WL 3007078, at *8 (10th Cir. Dec. 29, 2004) (district court reviews magistrate judge’s discovery order for abuse of discretion; expressing “some concern whether the district court afforded the proper degree of deference to the magistrate judge’s discovery order”) (citing 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069 (2d ed. 1997) (noting that discovery disputes “might better be characterized as suitable for an abuse-of-discretion analysis”)); Cummings v. General Motors Corp., 365 F.3d 944, 954 (10th Cir. 2004) (“It is the unusual or exceptional case where the reviewing court will vacate a protective order entered by a trial court under Fed. R. Civ. P. 26(c).”); LaFleur v. Teen Help, 342 F.3d 1145, 1152-53 (10th Cir. 2003) (reviewing magistrate judge’s grant of discovery protective order for abuse of discretion).
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Discussion Plaintiffs seek discovery of marketing and advertising materials relating to Sprint’s “brand
or public image.” According to plaintiffs, such information will “likely show that senior level managers wanted Sprint’s marketing efforts and its image or brand to reflect a culture of youth, just as they wanted the Sprint workforce to be a culture of youth.” In support of their motion, plaintiffs rely in large part on the Tenth Circuit’s decision in Minshall v. McGraw Hill Broadcasting Co., 323 F.3d 1273 (10th Cir. 2003). According to plaintiffs, Minshall supports the principle that an employer’s attempt to project a youthful image is relevant and admissible to demonstrate an impermissible age animus in a discriminatory discharge case. The magistrate judge disagreed with plaintiffs, concluded that Minshall was distinguishable and granted the protective order on the grounds that the discovery sought was not relevant to plaintiffs’ claims. Plaintiffs have not shown that the magistrate judge abused his discretion in this regard.
In Minshall, the plaintiff, a former on-air investigative reporter for the defendant’s television news program, was terminated and he sued the defendant for age discrimination. 323 F.3d at 1277-78. At trial, evidence was introduced showing that the defendant’s news director–the person who made the decision to terminate the plaintiff’s employment–made various changes to the program in an effort to reach a younger demographic. See id. at 1278, 1281. These changes included presenting “sexier stories” in the news, endeavoring to achieve a “more youthful presentation,” and making overall changes to the news format. See id. at 1281. The Circuit held that the news director’s comments about wanting to reach a younger demographic and desiring a “more youthful presentation” were sufficient to permit a jury to infer that the plaintiff’s
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employment was terminated based on his age. See id. at 1282. Specifically, the Circuit held that there was a nexus between the new director’s comments and her decision to terminate plaintiff’s employment because, under the “youthful” news format developed by the news director, the news director did not want to utilize on-air reporters over the age of 40. See id.
In Minshall, then, a clear link existed between the defendant’s “public image” and its decision to terminate the plaintiff’s employment; that is, the defendant, in an effort to portray a youthful image in the hopes of reaching a younger audience, wanted to utilize younger on-air reporters who would promote the “youthful” image necessary (or perceived to be necessary) to reach the desired audience. By contrast, there is no obvious link between Sprint’s public image and its workforce or, more specifically, the RIF decisions in this case. Even assuming that Sprint’s advertising and marketing campaigns were designed to reach a younger demographic, the mere fact that Sprint is attempting to sell its products to young customers would not tend to show that Sprint terminated the employment of these plaintiffs based on age or that it bore any animus against older workers. As Judge Waxse concluded, then, Minshall is readily distinguishable from the facts presented here.
Thus, while plaintiffs assert that Sprint’s attempt to target younger customers (if, in fact, it is targeting such customers) necessarily means that Sprint wanted a younger workforce, they have no evidence suggesting such a link. Plaintiffs attempt to establish a nexus between Sprint’s public image and its workforce through the deposition testimony of Len Lauer, Sprint’s Chief Operating Officer. Mr. Lauer acknowledged in his deposition the importance of having a workforce that reflects the market. Plaintiffs contend that Mr. Lauer’s testimony concerning the
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workforce and the market suggests that Sprint, through its advertising and marketing, was targeting a young market and therefore wanted its workforce to be young to appeal to the target market. The court disagrees with plaintiffs’ conclusion.
Mr. Lauer does not remotely suggest in his deposition that Sprint was targeting a young market. In fact, Mr. Lauer’s testimony clearly reflects that Sprint, in certain circumstances, was seeking a workforce that reflected a multicultural market. Mr. Lauer explained, by way of example, that Sprint would like to have a number of Hispanic people working in its marketing department because those individuals would be more sensitive to the needs and desires of a growing Hispanic market, including the need for Spanish-language materials and Spanish-speaking employees at Sprint’s call centers. Moreover, even assuming that Sprint was targeting a young customer base, it does not necessarily follow that Sprint would not want older people in the workforce or that Sprint has an animus against older workers. Unlike the facts of Minshall, where the plaintiff appeared on television and was, in effect, the “image” or “face” of the employer, here there is no evidence that plaintiffs were the “face” of Sprint or otherwise represented Sprint to the outside world. Neither is there evidence that the ages of Sprint’s employees would have any bearing on customer attitudes or that Sprint’s customers, for whatever reason, would be more likely to purchase Sprint products if Sprint had youthful employees. In short, plaintiffs have not shown that Sprint’s efforts to target young customers are relevant to their employment discrimination claims.
For the foregoing reasons, the court readily concludes that the magistrate judge properly exercised his discretion in granting defendant’s motion for protective order.
6

Case 2:03-cv-02200-JWL-DJW Document 3194 Filed 08/31/05 Page 7 of 7 IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion to review
and objections to the magistrate judge’s July 12, 2005 order (doc. 3106) is denied. IT IS SO ORDERED. Dated this 31st day of August, 2005, at Kansas City, Kansas. s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 3333 Filed 09/29/05 Page 1 of 33

DJW/byk

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al., Plaintiffs,
v. SPRINT/UNITED MANAGEMENT COMPANY,
Defendant.

CIVIL ACTION No. 03-2200-JWL-DJW

MEMORANDUM AND ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant’s decision to terminate her employment during a reduction-in-force (RIF). Currently, 1727 plaintiffs remain in the case out of the 2354 plaintiffs who opted into this provisionally certified collective action pursuant to 29 U.S.C. § 216(b). The parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Defendant’s Response to the Court’s July 12, 2005 Order (doc. 3037), which ordered Defendant to show cause why it should not produce electronic Microsoft Excel spreadsheets in the manner in which they were maintained and why it should not be sanctioned for “scrubbing” the metadata and locking certain data on the electronic spreadsheets prior to producing them to Plaintiffs without either the agreement of the parties or the approval of the Court.

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I. Background Information
Plaintiff Williams commenced this action in April 2003, and, to date, the docket reflects that over
3300 pleadings and orders have been filed. The case is assigned to Chief Judge John W. Lungstrum but
is referred to the undersigned Magistrate Judge for pretrial proceedings, including discovery. Due to the
highly contentious nature of this litigation, the Magistrate Judge has conducted discovery conferences twice
a month since March 2005 to resolve discovery issues identified by the parties. One of the ongoing
discovery disputes has been Defendant’s production of spreadsheets that relate to the RIFs at issue in this
case.
Plaintiffs raised the issue of the RIF-related spreadsheets at the May5, 2005 discoveryconference.
Item 1 on Plaintiffs’ List of Issues for the May 5, 2005 discovery conference was “Defendant’s Failure to
Produce Candidate Selection Spreadsheets and Other Basic RIF Documents.”1 Item 2 was listed as
1The following explanation accompanied Item 1 on Plaintiffs’ List of Issues for the May 5, 2005 discovery conference (doc. 3301):
These documents constitute the essential materials regarding the termination and other RIF decisions that are at issue in this collective action. Plaintiffs requested these documents in November of 2003 and again in December of 2004, and yet Defendant has produced only a few improperly redacted versions relating to some Plaintiffs and initial Opt-in Plaintiffs. At an April 12th meet and confer with [Plaintiffs’ counsel], Defendant’s counsel promised these documents would begin being produced inbatches. At the meet and confer prior to the April 21st hearing, Plaintiffs noted that Defendant still had not begun producing any of these documents. Defendant’s counsel acknowledged at that time that he had nine (9) boxes of these documents in his office. At the April 21st hearing, Defendant stated it would begin getting these documents produced. To date, Defendant has still not begun production of these documents which are of core relevance to this collective action. Defendant’s counsel has been indefinite and imprecise as to when Defendant will be able to certify that it has produced all of these basic RIF decision documents and spreadsheets. At the May 5th conference, Plaintiffs seek the Court’s Order that Defendant produce all such documents no
(continued...) 2

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“Defendant’s Failure to Produce Basic RIF Documents Such as HR Notes and Other Documents Re: RIF Decisions.”2 At the May 5, 2005 discovery conference, Plaintiffs requested that the Court enter an order requiring Defendant to produce candidate selection spreadsheets and other basic RIF documents by May 16, 2005.3 Defendant objected to a May 16, 2005 deadline and suggested a June 1, 2005 deadline instead.4 Plaintiffs advised the Court they would agree to a June 1, 2005 deadline.5 The Court accepted this compromise position and ordered Defendant to produce Items 1 and 2 from Plaintiffs’ May 5, 2005 List of Issues by June 1, 2005 or show cause why it could not produce them by that date.6
Two weeks later, at the May 19, 2005 discovery conference, Plaintiffs requested that Defendant be required to produce the actual electronic “active file” version of all the Excel RIF spreadsheets.
1(...continued) later than May 16, 2005. 2The following explanation accompanied Item 2 on Plaintiffs’ List of Issues for the May 5, 2005 discovery conference (doc. 3301): Plaintiffs requested these documents in November of 2003, and yet Defendant continues to trickle such documents in and to indicate that it has not produced all such documents. Indeed, Defendant’s counsel recently advised Plaintiffs’ counsel that it had not produced various Sprint Human Resources officials’ notes and other documents regarding the RIF decisions at issue in this case and that Defendant would not consider producing such documents until a new, formal request for production was made. At the May 5th conference, Plaintiffs seek the Court’s Order that Defendant produce all such documents no later than May 16, 2005. (emphasis in original)
3May 5, 2005 Discovery Conf. Transcript (Tr.) (doc. 2905) p. 15, l. 11-21. 4Id. at p. 25, l. 18-21. 5Id. at p. 26, l. 10-12. 6Id. at p. 27, l. 3-7.
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Plaintiffs’ stated reason for requesting that the spreadsheets be produced in their electronic form was so Plaintiffs could perform “statistical or manipulative things without taking the spreadsheets and going through the laborious process of keying in all that data again.”7 When the Court asked Defendant whether it was now producing the active file of the spreadsheets requested by Plaintiffs, Defendant reported that it was continuing to produce the TIFF8 imagesofthe spreadsheets as previously agreed by the parties. The Court then stated that:
[G]enerally, when things are maintained in the regular course of business in electronic form, they should be produced in that form, unless there’s an agreement otherwise. And it sounds like what you’re telling me, there was an agreement otherwise, until May 11, and then it was pointed out you want them in the form they were maintained.9 The Court thenasked Defendant whyitcould not produce the spreadsheets in their electronic form. Defendant responded by suggesting that it should be allowed to finish its review of the documents to be produced in TIFF image and then go back at a later time and review what it holds in electronic format. The Court commented on Defendant’s reference to reviewing documents by stating that “on the information
7May 19, 2005 Tr. (doc. 2915) p. 11-12, l. 24-25; 1-2. 8TIFF (Tagged Image File Format) is one of the most widely used and supported graphic file formats for storing bit-mapped images, with many different compression formats and resolutions. A TIFF file is characterized by its “.tif” file name extension. The Sedona Conference Glossary for E-Discovery and Digital Information Management (The Sedona Conference Working Group Series, May 2005 Version), available at http://www.thesedonaconference.org. The Sedona Conference is a nonprofit legal policy research and educational organization which sponsors Working Groups on cutting-edge issues of law. The Working Group on Electronic Document Production is comprised of judges, attorneys, and technologists experienced in electronic discovery and document management matters. 9May 19, 2005 Tr. p. 12, l. 17-24.
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that’s in electronic form, the only review [Defendant has] to do is the privilege review.”10 Following this
exchange, the Court further clarified its position on electronic document production of the spreadsheets:
What I’m talking about is if you’re talking about documents maintained on Excel, you’ve got that in some form, whether it’s on disk or paper, whatever it’s on. It’s an electronic form of Excel containing the data. The only thing you would have to do is review it for privilege and then give it to them.11
At the June 2, 2005 discovery conference, Plaintiffs again raised the issue of Defendant producing
the RIF spreadsheets in their electronic Excel form. Plaintiffs explained why they needed the electronic
version of the spreadsheets in the following exchange:
PLAINTIFFS’ COUNSEL: There are, on each of these documents, things that show you why you have to have an electronic copy. These are spreadsheets. There are columns not there, that should be there. There are columns where the entry will have a sentence, and it cuts off in midsentence because the box ends. And we all know, on the computer, we click on that and we get everything.12
*** The electronic form of this document would reveal whether or not it had any actual other columns or types of information available on a spreadsheet.13
THE COURT: Okay. Before we get much further here, I thought it was clear from the last time we discussed this electronic issue, that you [Defendant] were looking for them and you were going to produce them. It’s not an issue that you’re not going to do it. It’s a question of when.14
DEFENDANT’S COUNSEL: Absolutely. And the only caveat is the one that I mentioned to you, is that there may be the issue of Social Security numbers. And if there are privileged
10Id. at p. 16, l. 11-13. 11Id. at p. 16, l. 19-25. 12June 2, 2005 Tr. (doc. 2940) p. 55, l. 11-18. 13Id. at p. 57, l. 15-18. 14Id. at p. 57, l. 19-24.
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communications, which are these analyses that were prepared, if they are on those documents, we’ll redact those and point out that they have been redacted, but still give them the electronic version of it, with the notation that that’s missing.15 At the June 9, 2005 discovery conference, Plaintiffs again raised the issue of Defendant producing the RIF spreadsheets in their electronic Excel format. The Court renewed its show cause order, stating, “for today on this issue we’ll leave the show cause that you’re going to do the electronic spreadsheets by [June] 24th.”16 This ruling was memorialized in paragraph 1 of the Court’s June 16, 2005 Order, which stated: “The Court’s previous Show Cause Order to Defendant remains on the following three categories of discovery: (a) Electronic versions of Excel and other spreadsheets, (b) Other documents (other than Minutes) relating to the RIF meetings, and (c) E-mails accompanying the spreadsheets.”17 On June 23, 2005, Defendant tendered to Plaintiffs’ counsel 3083 Excel spreadsheets in electronic form and indicated that there were 983 additional spreadsheets identified that had not been fully processed for production and would be produced no later than June 27, 2005.18 At the July 7, 2005 discovery conference, Plaintiffs’ counsel advised the Court that Defendant, prior to producing the electronic versions of the Excel spreadsheets, had utilized software to scrub the spreadsheet files to remove the metadata. Plaintiffs claim this metadata would have contained information such as file names, dates of the file, authors of the file, recipients of the file, print-out dates, changes and modification dates, and other information. Plaintiffs’ counsel stated that Defendant did not provide them
15Id. at p. 57-58, l. 15-25; 1-8. 16June 9, 2005 Tr. (doc. 3146) p. 17, l. 22-24. 17Doc. 2953. 18See Defendant’s Response to Show Cause Order (doc. 2968).
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with any type of log of what information was scrubbed. Plaintiffs’ counsel also advised the Court that Defendant had locked certain cells and data on the Excel spreadsheets prior to producing them so that Plaintiffs could not access those cells.
Defendant admitted that it had scrubbed the metadata from and locked certain data on the spreadsheets prior to producing them. It argued that the spreadsheets’ metadata is irrelevant and contains privileged information. Defendant further argued that Plaintiffs never requested the metadata be included in the electronic Excel spreadsheets it produced and that metadata was never discussed at any of the discovery conferences.
After hearing the respective argumentsofcounsel, the Court ordered Defendant to show cause why it should not be sanctioned for not complying with “what at least I understood my Order to be, which was that electronic data be produced in the manner in which it was maintained, and to me that did not allow for the scrubbing of metadata because when I talk about electronic data, that includes the metadata.”19 The Court then gave Defendant seven days to show cause why it had scrubbed metadata and locked data, “because my intent from the two previous Orders was to do as I said, produce it in the format it’s maintained, not modify it and produce it.”20 The Court advised Defendant that if it could show justification for scrubbing the metadata and locking the cells, the Court would certainly consider it, but cautioned that
19July 7, 2005 Tr. (doc. 3147) p. 60, l. 20-25. 20Id. at p. 61, l. 4-6.
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“it’s going to take some clear showing or otherwise there are going to be appropriate sanctions, which at least will be the production of the information in the format it was maintained.”21
The Court’s corresponding written Order dated July 12, 2005 (doc. 3037), required Defendant to show cause in writing: (1) “why it should not produce the electronic spreadsheets in the manner in which they were maintained” and (2) “why it should not be sanctioned for its failure to comply with the Court’s ruling from the June 9, 2005 discovery conference, memorialized in the Court’s June 16, 2005 Order (doc. 2953), directing Defendant to produce electronic spreadsheets in the manner in which they were maintained.”22 The Order more specifically required Defendant “to show cause why it scrubbed the metadata and locked certain data on these electronic spreadsheets prior to producing them to Plaintiffs without either the agreement of the parties or the approval of the Court.”23 II. Discussion
In its response to the Court’s Show Cause Order, Defendant states that it provided the spreadsheets as requested by Plaintiffs in native Excel format, with the following four modifications, none of which affected the discoverable data regarding the RIFs at issue this lawsuit: (1) Defendant deleted the adverse impact analyses; (2) Defendant deleted the social security numbers of employees referenced in the spreadsheets; (3) Defendant deleted metadata from the electronic files that included the spreadsheets; and (4) Defendant locked the value of the cells in the spreadsheets.
21Id. at p. 61, l. 9-13. 22Doc. 3037. 23Id.
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Defendant asserts that these four modifications to the RIF spreadsheets were made in good faith and forlegitimatepurposes, namely to protect fromdisclosureinformationthatJudge Lungstrumdetermined is not discoverable, to ensure the Court’s rulings could not be circumvented, and to maintain the integrity of the data. Defendant maintains that under these circumstances its actions were appropriate and do not warrant the imposition of sanctions.
A. Adverse Impact Analyses and Social Security Numbers Although Defendant’s response to the Show Cause Order explains why it redacted or removed adverse impact analyses information and social security numbers from the electronic spreadsheets prior to producing them, the Court finds this explanation is not necessary, as Defendant previously indicated that it intended to redact this information. At the June 2, 2005 discovery conference, Defendant indicated to the Court that it intended to redact social security numbers and privileged communications consisting of the adverse impact analyses that were prepared.24 Plaintiffs did not object at the June 2, 2005 discovery conference to Defendant’s stated intention to redact this information prior to producing the spreadsheets. Plaintiffs also never raised Defendant’s redaction of the adverse impact analyses information or social security numbers at the July 7, 2005 discovery conference when they reported that Defendant had scrubbed the spreadsheets’ metadata and locked spreadsheet data. Moreover, the Court’s Show Cause Order did not require Defendant to show cause why it deleted the adverse impact analyses and social security numbers. The Court therefore finds that Defendant need not show cause for the redaction or removal of the adverse impact analyses and social security numbers from the RIF spreadsheets. B. Metadata
24See June 2, 2005 Tr. p. 57-58. 9

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The Court’s Show Cause Order, however, does require Defendant to show cause for its actions in scrubbing the metadata from the electronic spreadsheets prior to producing them to Plaintiffs. Defendant claims that it scrubbed the metadata from the spreadsheets to preclude the possibility that Plaintiffs could “undelete” or recover privileged and protected information properly deleted from the spreadsheets and to limit the information in the spreadsheets to those pools from which it made the RIF decisions currently being litigated. In an attempt to justify its actions, Defendant contends that emerging standards of electronic discovery articulate a presumption against the production of metadata, which is not considered part of a document, unless it is both specifically requested and relevant. Defendant next argues that Plaintiffs never sought the production of metadata. Finally, Defendant argues that its removal of metadata was consistent with, if not compelled by, Judge Lungstrum’s prior orders. Defendant asserts that these reasons support a determination that it has shown cause for its removal of the metadata from the Excel spreadsheets prior to producing them to Plaintiffs.
1. Emerging standards of electronic discovery with regard to metadata a. What is metadata?
Before addressing whether Defendant was justified in removing the metadata from the Excel spreadsheets prior to producing them to Plaintiffs, a general discussion of metadata and its implications for electronic document production in discovery is instructive.
Metadata, commonly described as “data about data,” is defined as “information describing the history, tracking, or management of an electronic document.”25 Appendix F to The Sedona Guidelines:
25Proposed advisory committee note to Federal Rule of Civil Procedure 26(f). The pending rule amendments and notes can be viewed at:
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Best Practice Guidelines & Commentary for Managing Information & Records in the Electronic Age defines metadata as “information about a particular data set which describes how, when and by whom it was collected, created, accessed, or modified and how it is formatted (including data demographics such as size, location, storage requirements and media information.)”26 Technical Appendix E to the Sedona Guidelines provides an extended description of metadata. It further defines metadata to include “all of the contextual, processing, and use information needed to identify and certify the scope, authenticity, and integrity of active or archival electronic information or records.”27 Some examples of metadata for electronic documents include: a file’s name, a file’s location (e.g., directory structure or pathname), file format or file type, file size, file dates (e.g., creation date, date of last data modification, date of last data access, and date of last metadata modification), and file permissions (e.g., who can read the data, who can write to it, who can run it).28 Some metadata, such as file dates and sizes, can easily be seen by users; other metadata can be hidden or embedded and unavailable to computer users who are not technically adept.29
25(...continued) http://www.uscourts.gov/rules/comment2005/CVAug04.pdf#page=24. On September 20, 2005, the Judicial Conference approved the proposed rule amendments and they were transmitted to the Supreme Court for approval. The proposed rule amendments are set to become effective December 1, 2006.
26The Sedona Guidelines: Best Practice Guidelines & Commentary for Managing Information & Records in the Electronic Age, App. F (The Sedona Conference Working Group Series, Sept. 2005 Version), available generally at http://www.thesedonaconference.org and more specifically at http://www.thesedonaconference.org/content/miscFiles/TSG9_05.pdf.
27Id. at App. E. 28Id. at App. E. n.1. 29Id. at App. E.
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Most metadata is generally not visible when a document is printed or when the document is converted to an image file.30 Metadata can be altered intentionally or inadvertently and can be extracted when native files are converted to image files.31 Sometimes the metadata can be inaccurate, as when a form document reflects the author as the person who created the template but who did not draft the document.32
In addition, metadata can come from a variety of sources; it can be created automatically by a computer, supplied by a user, or inferred through a relationship to another document.33
Appendix E to The Sedona Guidelines further explains the importance of metadata:
Certain metadata is critical in information management and for ensuring effective retrieval and accountability in record-keeping. Metadata can assist in proving the authenticity of the content of electronic documents, as well as establish the context of the content. Metadata can also identify and exploit the structural relationships that exist between and within electronic documents, such as versions and drafts. Metadata allows organizations to track the many layers of rights and reproduction information that exist for records and their multiple versions. Metadata may also document other legal or security requirements that have beenimposed on records; for example, privacyconcerns, privileged communications or work product, or proprietary interests.34
The Microsoft Office Online website lists several examples of metadata that may be stored in
Microsoft Excel spreadsheets, as well as other Microsoft applications such as Word or PowerPoint: author
30Id. 31The Sedona Conference Glossary, p. 28-29. 32The Sedona Principles: Best Practices, Recommendations & Principles for Addressing Electronic Document Discovery, Cmt. 12.a. (The Sedona Conference Working Group Series, July 2005 Version), available generally at http://www.thesedonaconference.org, and more specifically at available at http://www.thesedonaconference.org/content/miscFiles/7_05TSP.pdf. 33The Sedona Guidelines, App. E. 34Id.
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name or initials, company or organization name, identification of computer or network server or hard disk where document is saved, names of previous document authors, document revisions and versions, hidden text or cells, template information, other file properties and summary information, non-visible portions or embedded objects, personalized views, and comments.35
It is important to note that metadata varies with different applications. As a general rule of thumb, the more interactive the application, the more important the metadata is to understanding the application’s output. At one end of the spectrum is a word processing application where the metadata is usually not critical to understanding the substance of the document. The information can be conveyed without the need for the metadata. At the other end of the spectrum is a database application where the database is a completely undifferentiated mass of tables of data. The metadata is the key to showing the relationships between the data; without such metadata, the tables of data would have little meaning. A spreadsheet application lies somewhere in the middle. While metadata is not as crucial to understanding a spreadsheet as it is to a database application, a spreadsheet’s metadata may be necessary to understand the spreadsheet because the cells containing formulas, which arguably are metadata themselves, often display a value rather than the formula itself. To understand the spreadsheet, the user must be able to ascertain the formula within the cell.
Due to the hidden, or not readily visible, nature of metadata, commentators note that metadata created by any software application has the potential for inadvertent disclosure of confidential or privileged
35Microsoft Office Online: Find and Remove Metadata (Hidden Information) in Your Legal Documents, http://office.microsoft.com/en-us/assistance/HA010776461033.aspx.
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informationin both a litigationand non-litigationsetting, whichcould give rise to an ethical violation.36 One method commonly recommended to avoid this inadvertent disclosure is to utilize software that removes metadata from electronic documents.37 The process of removing metadata is commonly called “scrubbing” the electronic documents.38 In a litigation setting, the issue arises of whether this can be done without either the agreement of the parties or the producing party providing notice through an objection or motion for protective order.
b. Whether emerging standards of electronic discovery articulate a presumption against the production of metadata
Withthe increasingusage ofelectronic document productionin discovery, metadata presents unique challenges regarding the production of documents in litigation and raises many new discovery questions. The group of judges and attorneys comprising the Sedona Conference Working Group on Best Practices for Electronic Document Retention and Production (Sedona Electronic Document Working Group) identified metadata as one of the primary ways in which producing electronic documents differs from producing paper documents.39 The Sedona Electronic Document Working Group also recognized that
36See e.g., Brian D. Zall, Metadata: Hidden Information in Microsoft Word Documents and its Ethical Implications, 33-Oct. Colo. Law. 53 (2004).
37Id. at 58. 38Id. 39The Sedona Principles, p. 5-6.
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understanding when metadata should be specifically preserved and produced represents one of the biggest challenges in electronic document production.40
Defendant contends thatemergingstandards ofelectronic discoveryarticulatea presumptionagainst the production of metadata. To determine whether Defendant’s contention is accurate, the Court must first identify the emerging standards for the production of metadata. Then the Court must determine whether these emerging standards provide any guidance on the issue before the Court, i.e., whether a court order directing a party to produce electronic documents as they are maintained in the ordinary course of business requires the producing party to produce those documents with the metadata intact. A related issue is determining which party has the initial burden with regard to the disclosure of metadata. Does the requesting party have the burden to specifically request metadata and demonstrate its relevance? Or does the party ordered to produce electronic documents have an obligation to produce the metadata unless that party timely objects to production of the metadata?
The Court starts with the current version of Federal Rule of Civil Procedure 34. This rule provides that “[a]ny party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor’s behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information can be obtained, translated, if necessary, by the respondent through detection devices into reasonably usable form).”41 “A party who produces documents for inspection shall produce them as
40Id. 41Fed. R. Civ. P. 34(a).
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they are kept in the usual course of business or shall organize and label them to correspond with the categories in the request.”42
FederalRule of Civil Procedure 34 includes “data compilations”in the listing ofitems thatconstitute a “document.” The 1970 amendment advisory committee note to Rule 34 states that “Rule 34 applies to electronics data compilations from which information can be obtained only with the use of detection devices, and that when the data can as a practical matter be made usable by the discovering party only through respondent’s devices, respondent may be required to use his devices to translate the data into usable form.”43 Although neither Rule 34 nor its advisory committee notes defines “data compilations,” the 1972 proposed rules advisory committee note to Federal Rule of Evidence 803(6) explains that “the expression ‘data compilation’ is used as broadly descriptive of any means of storing information other than the conventional words and figures in written or documentary form. It includes, but is by no means limited to, electronic computer storage. The term is borrowed from revised Rule 34(a) of the Rules of Civil Procedure.”44 Using this broad definition of a “data compilation,” an Excel spreadsheet, and perhaps the underlying metadata itself, would be considered a “data compilation” under Rule 34. The current version of Rule 34, however, provides limited guidance with respect to when “data compilations” or other types of electronic documents have to be produced and in what form they should be produced.
In the past year, the Civil Rules Advisory Committee has proposed to the Judicial Conference several amendments to the Federal Rules of Civil Procedure addressing the discovery of electronically
42Fed. R. Civ. P. 34(b). 43Fed. R. Civ. P. 34(a) advisory committee’s note. 44Fed. R. Evid. 803(6) advisory committee’s note.
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stored information.45 One of the proposed amendments to Rule 34(a) adds “electronically stored
information” as a separate category along with “any designated documents.” In addition, the proposed
amendments to Rule 34(b) add the following language about the production of electronically stored
information:
Unless the parties otherwise agree, or the court otherwise orders, ***
(ii) if a request for electronically stored information does not specify the form or forms of production, a responding party must produce the information in a form or forms in which it is ordinarily maintained, or in a form or forms that are reasonably usable.46
The proposed committee note to Rule 34(b) provides the following guidance on the form of production:
The amendment to Rule 34(b) permits the requesting party to designate the form or forms in which it wants electronically stored information produced. The form of production is more important to the exchange of electronically stored information than of hard-copy materials, although a party might specify hard copy as the requested form. Specification of the desired form or forms may facilitate the orderly, efficient, and cost-effective discovery of electronically stored information. The rule recognizes that different forms of production may be appropriate for different types of electronically stored information. Using current technology, for example, a party might be called upon to produce word processing documents, e-mail messages, electronic spreadsheets, different image or sound files, and material from databases. Requiring that such diverse types of electronically stored information all be produced in the same form could prove impossible, and even if possible could increase the cost and burdens of producing and using the information. The rule therefore provides that the requesting party may ask for different forms of production for different types of electronically stored information. 47
45The pending rule amendments can be viewed at http://www.uscourts.gov/rules/Reports/ST09-2005.pdf. On September 20, 2005, the Judicial Conference approved the proposed rules amendments and they were transmitted to the Supreme Court for approval. The proposed rule amendments are set to become effective December 1, 2006.
46Id.
47Id.
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Although the proposed amendments to Rule 34 use the phrase “in a form or forms in which it is ordinarily maintained,” they provide no further guidance as to whether a party’s production of electronically stored information“in the formor forms in whichit is ordinarilymaintained”would encompass the electronic document’s metadata.
In the few cases where discovery of metadata is mentioned, it is unclear whether metadata should ordinarily be produced as a matter of course in an electronic document production. In the case In re Verisign, Inc. Securities Litigation,48 Judge Ware of the Northern District of California generally upheld the ruling of Magistrate Judge Trumbell that requiring the production of electronic documents in electronic format was not contrary to law but was supported by the federal rules. At issue in the Verisign case was the court’s prior order directing the defendants to produce responsive electronic documents in their native format.49 The order expressly stated that “[p]roduction of TIFF version alone is not sufficient,” and that “[t]he electronic version must include metadata as well as be searchable.”50 While Verisign is helpful, it does not answer the question of whether metadata must be produced when the court’s order does not expressly reference metadata.
In another case, which involved the imposition of sanctions against a corporate defendant who repeatedly engaged in a number of discovery abuses, Magistrate Judge Hemann recommended that default
48No. C 02-2270 JW, 2004 WL 2445243 (N.D. Cal. Mar. 10, 2004). 492004 WL 2445243, at *2. 50Id. at *1.
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judgment be entered against the defendant as sanctions for its discovery abuses.51 One of the discovery abuses involved the defendant’s production of electronic files with metadata missing. Telxon and the plaintiffs argued that the missing documents, missing attachments, missing metadata, and hard copies of documents in a version different from the versions on any of the electronic databases produced suggested that the defendant was withholding or had improperly destroyed discoverable information. The magistrate judge was skeptical of the defendant’s explanations for missing documents and metadata and for differences between hardcopy versions of documents and those on the electronic databases.52 Although the case does not directly state that metadata should have been produced, that conclusion can be inferred from the court’s holding.
Having concluded that neither the federal rules nor case law provides sufficient guidance on the production of metadata, the Court next turns to materials issued by the Sedona Conference Working Group on Electronic Document Production. The Court finds two of the Sedona Principles for Electronic Document Production particularly helpful in determining whether Defendant was justified in scrubbing the metadata from the electronic spreadsheets. Principle 9 states that “[a]bsent a showing of special need and relevance a responding party should not be required to preserve, review, or produce deleted, shadowed,
51In re Telxon Corp. Sec. Litig., No. 5:98CV2876, 1:01CV1078, 2004 WL 3192729 (N.D. Ohio July 16, 2004), reported in LEXIS as Hayman v. Price Waterhouse Coopers, LLP, 2004 U.S. LEXIS 27296. Note that the litigation concluded before the district judge issued any ruling on the magistrate judge’s Amended Report and Recommendation.
52Id. at *34 (The magistrate judge found the defendant’s explanations for the missing documents and metadata and for differences between hardcopy versions of documents and those on any of the electronic databases less than convincing. She stated the defendant’s explanations “may explain these phenomena in whole or in part, but ‘may’ is the operative conditioner here.”)
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fragmented, or residual data or documents.”53 Principle 12 provides that “[u]nless it is material to resolving the dispute, there is no obligation to preserve and produce metadata absent agreement of the parties or order of the court.”54
Comment 9.a. to the Sedona Principles for Electronic Document Production focuses on the scope of a “document” under Fed. R. Civ. P. 34. It notes that although Rule 34 was amended in 1970 to add “data compilations” to the list of discoverable documents, there was no suggestion that “data compilations” was intended to turn all forms of “data” into a Rule 34 “document.”55 The comment suggests that the best approach to understanding what constitutes a “document” is to examine what information is readily available to the computer user in the ordinary course of business.56 If the information is in view, it should be treated as the equivalent of a paper “document.”57 Data that can be readily compiled into viewable information, whether presented on the screen or printed on paper, is also a “document” under Rule 34.58 The comment, however, cautions that data hidden and never revealed to the user in the ordinary course of business should not be presumptively treated as a part of the “document,” although there are circumstances in which the data may be relevant and should be preserved and produced.59 The comment
53The Sedona Principles, Principle 9. 54The Sedona Principles, Principle 12. 55The Sedona Principles, Cmt. 9.a. 56Id. 57Id. 58Id. 59Id.
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concludes that such data may be discoverable under Rule 34, but the evaluation of the need for and relevance of such discovery should be separately analyzed on a case-by-case basis.60 Comment 9.a. provides the following illustration:
A party demands that responsive documents, “whether in hard copy or electronic format,” be produced. The producing party objects to producing the documents in electronic format and states that production will be made through PDF or TIF images on CD-ROMs. The producing party assembles copies of the relevant hard copy memoranda, prints out copies of relevant e-mails and electronic memoranda, and produces them in a PDF or TIF format that does not include metadata. Absent a special request for metadata (or any reasonable basis to conclude the metadata was relevant to the claims and defenses in the litigation), and a prior order of the court based on a showing of need, this production of documents complies with the ordinary meaning of Rule 34.61 Metadata is specifically discussed in depth in Comment 12.a. to the Sedona Principles. The comment states that “[a]lthough there are exceptions to every rule, especially in an evolving area of the law, there should be a modest legal presumption in most cases that the producing party need not take special efforts to preserve or produce metadata.”62 The comment further notes that it is likely to remain the exceptional situation in which metadata must be produced.63
60The Sedona Principles, Cmt. 9.a. (citing McPeek v. Ashcroft, 202 F.R.D. 31, 33 (D. D.C. 2001); McPeek v. Ashcroft, 212 F.R.D. 33, 35-37 (D.D.C. 2003)).
61The Sedona Principles, Cmt. 9.a. 62The Sedona Principles, Cmt. 12.a. (citing Pub. Citizen v. Carlin, 184 F.3d 900, 908-11 (D.C. Cir. 1999), cert. denied, 529 U.S. 1003 (2000)). 63The Sedona Principles, Cmt. 12.a.
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The comment lists several ways in which routine preservation and production of metadata may be beneficial.64 The comment balances these potential benefits against the “reality that most of the metadata has no evidentiary value, and any time (and money) spent reviewing it is a waste of resources.”65 The comment concludes that a reasonable balance is that, unless the producing party is aware or should be reasonably aware that particular metadata is relevant, the producing party should have the option of producing all, some, or none of the metadata.66 The comment sets forth one important caveat to giving the option of producing metadata to the producing party: “Of course, if the producing party knows or should reasonably know that particular metadata is relevant to the dispute, it should be produced.”67
c. Application to this case The narrow issue currently before the Court is whether, under emerging standards of electronic discovery, the Court’s Order directing Defendant to produce electronic spreadsheets as they are kept in the ordinary course of business requires Defendant to produce those documents with the metadata intact. As noted above, the Court finds insufficient guidance in either the federal rules or case law, and thus relies primarily on the Sedona Conference Principles and comments for guidance on the emerging standards of electronic document production, specifically with regard to metadata. While recognizing that the Sedona Principles and comments are only persuasive authority and are not binding, the Court finds the Sedona
64Id. 65Id. 66Id. 67Id.
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Principles and comments particularly instructive in how the Court should address the electronic discovery issue currently before it.
Comment 9.a. to the Sedona Principles for Electronic Document Production approaches discoverability based on what constitutes a “document” under Rule 34. This comment uses viewability as the determining factor in whether something should be presumptively treated as a part of a “document.” Using viewability as the standard, all metadata ordinarily visible to the user of the Excel spreadsheet application should presumptively be treated as part of the “document” and should thus be discoverable. For spreadsheet applications, the user ordinarily would be able to view the contents of the cells on the spreadsheets, and thus the contents of those cells would be discoverable.
In light of the proposed amendment to Rule 34, which adds “electronically stored information” as its own separate category, it is no longer necessaryto focus onwhat constitutes a “document.” With regard to metadata in general, the Court looks to Principle 12 and Comment 12.a. to the Sedona Principles. Based upon this Principle and Comment, emerging standards of electronic discovery appear to articulate a general presumption against the production of metadata, but provide a clear caveat when the producing party is aware or should be reasonably aware that particular metadata is relevant to the dispute.
Based on these emerging standards, the Court holds that when a party is ordered to produce electronic documents as they are maintained in the ordinary course of business,68 the producing party should produce the electronic documents with their metadata intact, unless that party timely objects to production of metadata, the parties agree that the metadata should not be produced, or the producing party
68This same reasoning would apply if the court ordered a partyto produce the electronic documents as an “active file” or in their “native format.”
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requests a protective order.69 The initial burden with regard to the disclosure of the metadata would therefore be placed on the party to whom the request or order to produce is directed. The burden to object to the disclosure of metadata is appropriately placed on the party ordered to produce its electronic documents as they are ordinarily maintained because that party already has access to the metadata and is in the best position to determine whether producing it is objectionable. Placing the burden on the producing party is further supported by the fact that metadata is an inherent part of an electronic document, and its removal ordinarily requires an affirmative act by the producing party that alters the electronic document.
i. Relevancy Defendant maintains that the metadata it removed from its electronic spreadsheets has absolutely no evidentiary value and is completely irrelevant. It argues that Plaintiffs’ suggestion that the metadata may identify the computers used to create or modify the spreadsheets or reveal titles of documents that may assist in efforts to piece together the facts of the RIFs at issue in this case has no relevance to Plaintiffs’ claim that Defendant maintained discriminatory policies or practices used to effectuate a pattern and practice of age discrimination. Defendant likewise argues that the metadata is not necessary because the titles of documents can be gleaned from the subject spreadsheets, and these titles adequately describe the data included in such spreadsheets. The Court agrees with Defendant that certain metadata from the spreadsheets may be irrelevant to the claims and defenses in this case. The Court, however, does not find that all of the spreadsheets’ metadata is irrelevant. In light of Plaintiffs’ allegations that Defendant reworked pools of employees in
69The same principle may apply when a party requests electronic documents be produced as they are maintained in the ordinary course of business, as an “active file,” or in their “native format.”
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order to improve distribution to pass its adverse impact analysis, the Court finds that some of the metadata is relevant and likely to lead to the discovery of admissible evidence. While the Court cannot fashion an exhaustive list of the spreadsheet metadata that may be relevant, the Court does find that metadata associated with any changes to the spreadsheets, the dates of any changes, the identification of the individuals making any changes, and other metadata from which Plaintiffs could determine the final versus draft version of the spreadsheets appear relevant. Plaintiffs’ allegation that Defendant reworked the pools is not a new allegation. Thus, Defendant should reasonably have known that Plaintiffs were expecting the electronic spreadsheets to contain their metadata intact. Furthermore, if Defendant believed the metadata to be irrelevant, it should have asserted a relevancy objection instead of making the unilateral decision to produce the spreadsheets with the metadata removed.
ii. Reliability Defendant also argues that the metadata removed from the electronic spreadsheets may be inaccurate and therefore has no evidentiary value. The Court finds that this is not sufficient justification for removing the metadata absent agreement of the parties or the Court’s approval. If Defendant had any concerns regarding the accuracy or reliabilityofthe metadata, it should have communicated those concerns to the Court before it scrubbed the metadata.
iii. Privilege Defendant also argues that production of certain metadata removed by Defendant would facilitate the revelation of information that is attorney-client privileged and/or attorney work product. Defendant claims that through the use of easily accessible technology, metadata mayrevealinformationextracted from
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a document, such as the items redacted by Defendant’s counsel, as well as other protected or privileged matters. It further claims that metadata may create a data trail that reveals changes to prior drafts or edits.
The Court agrees with Defendant that it should not be required to produce metadata directly corresponding to the information that it was permitted to redact, namely the adverse impact analyses and social security numbers. The Court is cognizant that all or some of the metadata may reveal the redacted information. The Court will therefore permit Defendant to remove metadata directly corresponding to Defendant’s adverse impact analyses and social security number information.
For any other metadata Defendant claims is protected bythe attorney-client privilege or as attorney work product, the Court finds that Defendant should have raised this issue prior to its unilateral decision to produce the spreadsheets with the metadata removed. Fed. R. Civ. P. 26(b)(5) requires a party withholding otherwise discoverable information on the basis of privilege to make the claim expressly and to describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing the privileged information, will enable the other parties to assess the applicability of the privilege. Normally, this is accomplished by objecting and providing a privilege log for “documents, communications, or things”70 not produced.
In this case, Defendant has failed to object and has not provided a privilege log identifying the electronic documents that it claims contain privileged metadata. Defendant has not provided the Court with evena generaldescriptionofthe purportedly privileged metadata that was scrubbed fromthe spreadsheets. As Defendant has failed to provide any privilege log for the electronic documents it claims contain metadata that will reveal privileged communications or attorney work product, the Court holds that Defendant has
70Fed. R. Civ. P. 26(b)(5). 26

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waived71 any attorney-client privilege or work product protection with regard to the spreadsheets’
metadata except for metadata directly corresponding to the adverse impact analyses and social security number information, which the Court has permitted Defendant to remove from the spreadsheets.72
2. Plaintiffs never requested the production of metadata
Defendant also argues that Plaintiffs never requested the metadata and that metadata was never
mentioned during any of the discovery conferences. While metadata was never mentioned during any of
the discovery conferences or in any of the Court’s orders, the Court finds that Defendant should reasonably
have been aware that the spreadsheets’ metadata was encompassed within the Court’s directive that it
produce the electronic Excel spreadsheets as they are maintained in the regular course of business.
Defendant is correct in asserting that Plaintiffs never expressly requested metadata and that the Court never
expressly ordered Defendant to produce the electronic spreadsheets’ metadata. However, taken in the
context of Plaintiffs’ stated reasons for requesting the Excel spreadsheets in their native electronic format
and the Court’s repeated statements that the spreadsheets should be produced in the electronic form in
which they are maintained, the Court finds that Defendant should have reasonably understood that the
71See Employer’s Reinsurance Corp. v. Clarendon Nat’l Ins. Co., 213 F.R.D. 422, 428 (D. Kan. 2003) (stating that it is well-established law in this district that failure to produce a privilege log can result in a waiver of any protection afforded to those documents); Haid v. Wal-Mart Stores, Inc., No. 99-4186-RDR, 2001 WL 964102, at *1 (D. Kan. June 25, 2001) (failure to produce a privilege log or production of an inadequate privilege log may be deemed a waiver of the privilege asserted); Starlight Int’l, Inc. v. Herlihy, No. 97-2329-GTV, 1998 WL 329268, at *3 (D. Kan. June 16, 1998) (same).
72The Court recognizes that this ruling impacts the relief requested by Plaintiffs in their pending Motionto Declare Defendant Has Waived Any Asserted Privilege WithRegard to CertainDocumentsand Electronic Spreadsheets (doc. 3192). The Court intends its ruling herein to resolve the issue of waiver with regard to metadata only. The remainder of Plaintiffs’ Motion to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets (doc. 3192) is still pending.
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Court expected and intended for Defendant to produce the spreadsheets’ metadata along with the Excel spreadsheets. If Defendant did not understand the Court’s ruling, it should have requested clarification of the Court’s order. As the Sedona Working Group on Electronic Document Production observed: “Of course, if the producing party knows or should reasonably know that particular metadata is relevant to the dispute, it should be produced.”73 Here, the Court finds that Defendant should have reasonably known that the metadata was relevant to the dispute and therefore should have either been produced or an appropriate objection made or motion filed.
3. WhetherJudge Lungstrum’s priororders compelthe removal of metadata Defendant next argues that itsremovalof metadata fromthe RIF spreadsheets was consistent with, if not compelled by, Judge Lungstrum’s prior orders. Defendant appears to be arguing that Judge Lungstrum’s prior rulings with regard to the adverse impact analyses compel the removal of all metadata. As discussed in section II.A. above, Defendant may redact its adverse impact analyses and social security numbers from the spreadsheets prior to producing them to Plaintiffs. Defendant may also remove the metadata directly corresponding to the redacted information. The undersigned Magistrate Judge, however, does not find that Judge Lungstrum’s prior rulings compel the removal of all other metadata. But in any event, if Defendant believed that Judge Lungstrum’s rulings compelled the removal of all metadata, then Defendant should have either objected or requested a protective order before it produced the spreadsheets with all metadata removed. C. Locked Spreadsheet Cells and Data
73The Sedona Principles, Cmt. 12.a. 28

Case 2:03-cv-02200-JWL-DJW Document 3333 Filed 09/29/05 Page 29 of 33
The Court next addresses whether Defendant has shown cause for the locking of certain data and cells on the Excel spreadsheets produced to Plaintiffs. Defendant states that it locked the value of the cells in the spreadsheets to ensure the integrity of the data regarding RIFs, i.e., to ensure that the data could not be accidentally or intentionally altered. Defendant claims its purpose was not to preclude Plaintiffs from sorting or filtering the data, a task it claims Plaintiffs could easily accomplish by copying the data to another spreadsheet. Instead, Defendant claims it locked the data to preclude inadvertent or intentional modification of the data it produced. It argues that because electronic data is not ordinarily static, locking the data was essential to ensure that Defendant could demonstrate data subsequently used in the case was identical to data it produced electronically. It asserts that no malicious intent was associated with Defendant’s efforts to preserve the integrity of the data it produced.
The Court finds that Defendant has failed to show sufficient cause for its unannounced and unilateral actions in locking certain data and cells on the Excel spreadsheets the Court ordered it to produce to Plaintiffs in the manner in which they were maintained. None of the reasons asserted by Defendant justifies its decision to lock the spreadsheet cells and data prior to producing them to Plaintiffs. While the Court’s Order did not expressly state that the spreadsheets should be produced “unlocked,”Defendant should have been reasonably aware that locking the spreadsheets’ cells and data was not complying with the spirit of the Court’s directive that the spreadsheets be produced as theyare kept in the ordinarycourse of business. Moreover, at the June 2, 2005 discovery conference, Plaintiffs specifically detailed their difficulties with the hard copy versions of the spreadsheets produced by Defendant, including their complaints that the hard copy versions cut off the information contained in the spreadsheet columns and cells.
29

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Defendant’s concerns regarding maintaining the integrity of the spreadsheet’s values and data could have been addressed by the less intrusive and more efficient use of “hash marks.” For example, Defendant could have run the data through a mathematical process to generate a shorter symbolic reference to the original file, called a “hash mark” or “hash value,” that is unique to that particular file.74 This “digital fingerprint” akin to a tamper-evident seal on a software package would have shown if the electronic spreadsheets were altered. When an electronic file is sent with a hash mark, others can read it, but the file cannot be altered without a change also occurring in the hash mark.75 The producing party can be certain that the file was not altered by running the creator’s hash mark algorithm to verify that the original hash mark is generated.76 This method allows a large amount of data to be self-authenticating with a rather small hash mark, efficiently assuring that the original image has not been manipulated.77
Defendant also states that despite its ongoing concerns withthe integrityofthe data in the electronic spreadsheets, it has voluntarily reproduced “unlocked” copies of the spreadsheets that were produced before July 7, 2005. It also represents that all successive productions of spreadsheets have not been locked. The Court concludes from Defendant’s statement that it has already produced “unlocked” spreadsheets to Plaintiffs. To the extent that Defendant has not produced “unlocked” versions of all of the spreadsheets previously produced with locked cells or data, Defendant shall produce “unlocked” versions
74Dean M. Harts, Reel to Real: Should You Believe What You See? Keeping the good and eliminating the bad of computer-generated evidence will be accomplished through methods of self-authentication and vigilance, 66 Def. Couns. J. 514, 522 (1999).
75Id. 76Id. 77Id.
30

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of those spreadsheets by the next discovery conference on October 6, 2005, or advise the Court at the discovery conference of the date when this information will be produced. III. Sanctions
The Court’s Show Cause Order also required Defendant to show cause why it should not be sanctioned for its failure to comply with the Court’s ruling directing Defendant to produce electronic spreadsheets in the manner in which they were maintained. Defendant states that it did not understand the Court’s direction to produce electronic spreadsheets included the production of metadata and that its actions were not made in bad faith. It points out that it has already produced hundreds of documents in response to formal and informal requests for production, answered hundreds of interrogatories, and produced and scheduled scores of witnesses for deposition in support of its assertion that it has acted in good faith throughout this litigation.
The Court concludes that Defendant has shown cause why it should not be sanctioned for its actions in scrubbing the metadata and locking spreadsheet cells and data. Although the Court intended its ruling requiring Defendant to produce the electronic RIF-related spreadsheets in the manner in which they were ordinarily maintained to include the metadata, the Court recognizes that the production of metadata is a new and largely undeveloped area of the law. This lack of clear law on production of metadata, combined with the arguable ambiguity in the Court’s prior rulings, compels the Court to conclude that sanctions are not appropriate here.
The Court, however, wants to clarify the law regarding the production of metadata in this case. When the Court orders a party to produce an electronic document in the form in which it is regularly maintained, i.e., in its native format or as an active file, that production must include all metadata unless that
31

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party timely objects to production of the metadata, the parties agree that the metadata should not be produced, or the producing party requests a protective order.
Defendant avoids sanctions with regard to its locking of the spreadsheet cells and data by its decision to voluntarily reproduce “unlocked” versions of these spreadsheets to Plaintiffs. As directed above, to the extent that Defendant has not produced “unlocked” versions of all the spreadsheets previously produced with locked cells or data, it shall produce “unlocked” versions of those spreadsheets by the next discovery conference on October 6, 2005, or advise the Court at the discovery conference of the date when this information will be produced.
IT IS THEREFORE ORDERED that Defendant has failed to show cause why it should not produce the electronic spreadsheets in the manner in which they were maintained. Defendant therefore shall produce the electronic spreadsheets in the manner in which they were maintained, which includes the spreadsheets’ metadata. Defendant may, however, redact its adverse impact analyses and any social security numbers from the spreadsheets prior to producing them to Plaintiffs. Defendant may also remove the metadata directly corresponding to the redacted information. Defendant shall produce the electronic spreadsheets by the next discovery conference on October 6, 2005, or advise the Court at the October 6, 2005 discovery conference of the date when these spreadsheets will be produced. Any assertion of attorney-client privilege or work product protection with regard to the metadata contained within these Excel spreadsheets, other than the metadata directly corresponding to the adverse impact analyses and social security number information, is deemed waived due to Defendant’s failure to object and produce a privilege log regarding the metadata.
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IT IS FURTHER ORDERED that to the extent Defendant has not reproduced “unlocked” versions of the spreadsheets previously produced with locked cells or data, Defendant shall produce “unlocked”versions of those spreadsheets by the next discovery conference on October6, 2005 or advise the Court at the discovery conference of the date when these spreadsheets will be produced.
IT IS FURTHER ORDERED that Defendant has shown sufficient cause why it should not be sanctioned for its failure to comply with the Court’s ruling directing it to produce electronic spreadsheets in the manner in which they were maintained.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 29th day of September, 2005.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

33

 
 Case 2:03-cv-02200-JWL-DJW Document 3410 Filed 11/01/05 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force. This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiff’s pattern and practice allegations. On July 29, 2005, the court issued an order denying in part and granting in part plaintiffs’ motion for leave to consolidate actions and to file a second amended complaint. Specifically, the court granted plaintiffs’ motion to the extent plaintiffs sought to assert a disparate impact claim in the light of the Supreme Court’s decision in Smith v. City of Jackson, Mississippi, 125 S. Ct. 1536 (2005); denied plaintiffs’ motion to the extent plaintiffs sought to have ten plaintiffs who had filed separate actions joined as named plaintiffs in this action; and denied plaintiffs’ motion to the extent plaintiffs sought to expand the definition of the class. This matter is presently before the court on two motions related to the court’s July 29,

Case 2:03-cv-02200-JWL-DJW Document 3410 Filed 11/01/05 Page 2 of 8
2005 order. Plaintiffs have filed a motion to reconsider (doc. 3161) that portion of the court’s order precluding plaintiffs from expanding the definition of the class. Defendant has filed a motion to strike (doc. 3184) portions of plaintiffs’ second amended complaint. For the reasons explained below, both motions are granted.
Plaintiff’s Motion to Reconsider In their motion for leave to consolidate actions and to file a second amended complaint,
plaintiffs represented to the court that their proposed second amended complaint reflected the joinder of ten individuals as named plaintiffs; adds a claim for disparate impact; identifies “Sprint Corporation” as an additional defendant; and “expands on factual details based on discovery to date.” Nowhere in plaintiffs’ motion did they specify what “factual details” were added in the proposed amended complaint and plaintiffs did not highlight any factual allegations that had been changed by the proposed amendment. Subsequent briefing on the motion, then focused solely on the joinder issue and the disparate impact claim. Consequently, the court, in preparing for oral argument on the motion, focused solely on the joinder issue and the disparate impact claim.
Consistent with the issues highlighted by plaintiffs in their motion, the parties’ oral argument focused almost entirely on joinder and disparate impact. In wrapping up his argument to the court, plaintiff’s counsel summarized the motion to amend as follows:
The other things this complaint does besides add disparate impact is to add Sprint Corp. as a defendant and do some basic factual updates. Those are logistical things, given some of the wholly-owned nature of the subsidiaries that we learned of as we moved on in this case.
2

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Plaintiffs’ counsel, then, never advised the court that the proposed amended complaint sought to expand the scope of “similarly situated” employees by including, for the first time, E-grade or executive level employees (previously, “similarly situated” employees were defined as those employees in job grades 71 through 79) and by including, for the first time, those employees terminated through reduction in force beginning in July 2001 (previously, “similarly situated” employees were defined as those employees terminated through reduction in force beginning October 1, 2001). Indeed, the court was made aware of the proposed changes by defendant’s counsel, who apparently noticed the changes while preparing for oral argument.1 Defendant, then, asserted that plaintiffs were belatedly attempting to expand the definition of the class. While plaintiffs argued that they should be permitted to make the proposed amendment, they failed to present any focused arguments to the court2 and the court, ultimately persuaded by defendant’s argument, denied the proposed amendment.
Plaintiffs now move the court to reconsider its ruling. Ignoring their own deficiencies in identifying and explaining the proposed changes, plaintiffs recite a myriad of ways in which the court has committed clear error, best summarized by plaintiffs’ statement that the court has
1The proposed amendments concerning E-grade employees and those employees terminated as early as July 2001 were hardly noticeable in terms of additional or modified language to the complaint.
2Indeed, the nature of plaintiffs’ argument led the court to believe that plaintiffs would not be aggrieved if the court denied the proposed amendment. For example, plaintiffs’ counsel stated that plaintiffs were prepared to simply use the October 1, 2001 deadline if the court denied the motion and that plaintiffs would follow the court’s order “on whether [the proposed changes] should stay or not.” Had plaintiffs been more candid in their communications to the court to begin with and better prepared to address the issue at oral argument, this procedural skirmish would have been avoided.
3

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“handed defendant a procedurally (and substantively) defective ‘dispositive motion’ victory when defendant has shown nothing to deserve the windfall of wholesale and preemptive eradication of claims.” (emphasis in original). Plaintiffs’ basic argument is that the court’s premise–that plaintiffs were attempting to expand the definition of the class–is erroneous because, while the “class definition” concept is critical in the Rule 23 context in the sense that it delineates those individuals who are members of the class and, as such, who will be bound by any judgment unless they affirmatively opt out of the class, any concept of “class definition” in the collective action context is largely inapplicable except to the extent that some defined group of “similarly situated” persons are notified of the action and invited to file consents to join. Stated another way, plaintiffs assert that the only limitation on a “class” in the collective action context is that putative plaintiffs be similarly situated to the named plaintiff and file consents to join, both of which are present with respect to the E-grade employees and those employees who were terminated prior to October 1, 2001. According to plaintiffs, then, their proposed changes did not expand the “class definition” but simply clarified the group of individuals who were already class members by virtue of having timely filed consents to join and being similarly situated to Ms. Williams.
Defendant tacitly concedes that the class definition concept is not pertinent in the collective action context. Nonetheless, defendant urges that the court’s order was entirely appropriate because plaintiffs are belatedly attempting to expand the scope of their claims by including new classifications of individuals who are “similarly situated” to Ms. Williams.3 The
3Defendant states in its response that plaintiffs have not shown any “exceptional circumstances” under Federal Rule of Civil Procedure 60(b) that would entitle them to the
4

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problem with defendant’s argument, however, is that these individuals are not “new” to the case. As plaintiffs highlight, all of the E-grade employees and those employees who were terminated prior to October 1, 2001 timely filed their consent to join forms and have been participating in this case for many months. Plaintiffs, then, are not belatedly seeking to add additional plaintiffs. At most, they are belatedly seeking to “update” their complaint to reflect the true scope of this case as it has existed for many months.
The court also finds it significant that defendant does not allege that it will suffer any prejudice if plaintiffs are permitted to amend their complaint to include reference to the E-grade employees and to those employees terminated prior to October 1, 2001. Because defendant has known about the existence of these plaintiffs for many months, certainly there is no surprise or prejudice in having the complaint reflect the presence of those parties. The court’s conclusion that plaintiffs have not delayed in updating their complaint, coupled with the lack of prejudice to defendant, counsels in favor of permitting plaintiffs to amend their complaint. See Calderon v. Kansas Dept. of Social and Rehab. Servs., 181 F.3d 1180, 1185-86 (10th Cir. 1999) (“The liberal granting of motions for leave to amend reflects the basic policy that pleadings should enable a claim to be heard on its merits.”).
For the foregoing reasons, plaintiffs’ motion to reconsider is granted and they will be
relief they seek. Because plaintiffs filed their motion within 10 days of the court’s order on their motion to amend, the motion for reconsideration is governed by Rule 59(e) rather than Rule 60(b). See Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000). In their motion, plaintiffs assert the need to correct clear error and prevent manifest injustice–appropriate bases for a Rule 59(e) motion. See id. (citing Brumark Corp. v. Samson Resources Corp., 57 F.3d 941, 948 (10th Cir. 1995)).
5

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permitted to revise their second amended complaint to include references to E-grade employees and to those employees terminated as early as July 2001.4
Defendant’s Motion to Strike In their motion for leave to consolidate actions and to file a second amended complaint,
plaintiffs sought to have ten individuals joined as named plaintiffs in this action. Plaintiffs proposed second amended complaint reflected this effort by setting forth nearly 200 new paragraphs of factual allegations regarding these ten individuals. The court denied plaintiffs’ motion to the extent plaintiffs sought to join these individuals as named plaintiffs, noting that the benefits plaintiffs desired to obtain through joinder could be achieved by simply permitting the plaintiffs in the separately filed actions to opt in to this case (five of whom already had opted in to the case). The court, however, granted plaintiffs’ motion in other respects unrelated to the ten individuals and directed plaintiffs to file their second amended complaint, consistent with the court’s order, no later than August 12, 2005. Despite the court’s denial of plaintiffs’ motion on the joinder issue, the second amended complaint filed by plaintiffs on August 12, 2005 contains each of the nearly 200 new paragraphs of factual allegations regarding the ten individuals whom plaintiffs sought to have joined as named plaintiffs. Defendant now moves to strike each of these paragraphs on the grounds that plaintiffs did not seek or receive leave to include these paragraphs
4Nothing in this order precludes defendant from filing a motion seeking to have the claims of some or all of these plaintiffs dismissed if those plaintiffs’ claims are untimely, have been waived by virtue of a release or otherwise fail.
6

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in their second amended complaint. The motion is granted. After the permissive filing period, Federal Rule of Civil Procedure 15(a) allows a plaintiff
to amend the complaint “only by leave of court or by written consent of the adverse party.” Plaintiffs had neither leave of court nor written consent of defendant to assert the additional allegations in their second amended complaint. Significantly, none of the paragraphs that defendant seeks to strike relate to the sole issue on which plaintiff was granted leave to amend–the assertion of a disparate impact claim (aside from those paragraphs stating that each of the ten individuals sustained damages as a result of defendant’s conduct that had a disparate impact based on age). Plaintiffs suggest that the court’s decision to permit these ten individuals to opt in to the case justifies plaintiffs’ retention of the paragraphs containing factual allegations specific to these ten opt-in plaintiffs. The court disagrees. The court in no way suggested that plaintiffs had permission to amend their complaint by offering factual detail about these ten individuals. The court simply directed plaintiffs to file consent to join forms for the individuals who had not yet opted in and directed plaintiffs to submit their completed questionnaires to defendant. The court expressly denied the motion to amend as it related to the ten individuals. Defendant’s motion to strike, then, is granted.
IT IS THEREFORE ORDERED BY THE COURT plaintiffs motion to reconsider (doc. 3161) is granted and defendant’s motion to strike (doc. 3184) is granted.
IT IS FURTHER ORDERED BY THE COURT THAT plaintiffs’ second amended 7

Case 2:03-cv-02200-JWL-DJW Document 3410 Filed 11/01/05 Page 8 of 8 complaint is stricken in its entirety and plaintiffs shall file a revised second amended complaint, reflecting the rulings set forth herein, no later than November 15, 2005.
IT IS SO ORDERED. Dated this 1st day of November, 2005, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge
8

 
 Case 2:03-cv-02200-JWL-DJW Document 3543 Filed 01/24/06 Page 1 of 3

DJW/byk

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,
Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,
Defendant.

CIVIL ACTION No. 03-2200-JWL-DJW

ORDER Plaintiffs have requested an order compelling Defendant to provide an exact duplicate of the index Defendant referenced and shown to Plaintiffs in open Court at the January 19, 2006 discovery conference and for a telephone conference on the issue.1 At the January 5, 2006 discovery conference, and memorialized in its January 6, 2006 Order (doc. 3533), the Court ordered Defendant to produce, in their native electronic format, all spreadsheets that Defendant had previously produced to Plaintiffs in non-electronic format only and that are available to Defendant in electronic format. At the January 19, 2006 discovery conference, Defendant advised the Court of its progress in complying with the Court’s Order. Defendant advised the Court that it was comparing the spreadsheets that it had already produced in electronic format with the ones produced in hard copy and it was generating an index that would tell it the answer to

1Plaintiffs’ request, as well as Defendant’s response and Plaintiffs’ reply were e-mailed to the Court. This e-mail exchange is attached as Exhibit 1 to this Order.

Case 2:03-cv-02200-JWL-DJW Document 3543 Filed 01/24/06 Page 2 of 3
that question.2 With the caveat that the indexwas not yet finished, Defendant provided its “work in progress” index to Plaintiffs for review. Defendant stated at the discovery conference that the finalized indexwould be provided to Plaintiffs the next day.3 Defendant further explained that the index would show: the Bates number of the documents Defendant produced in response to Judge Lungstrum’s August 12, 2005 Order, the title of that spreadsheet, and the native format production number.4
Plaintiffs advised the Court by email on January 23, 2006 that the document it received from Defendant was neither in the form of the index Defendant represented that it would produce, nor did it contain all of the information that was shown in Defendant’s “work in progress” index referenced and shown at the January 19, 2006 discovery conference. Defendant responded by claiming that it has several reasons why it did not provide the “work in progress” index referenced and shown at the January 19, 2005, but provided an index “identifying the spreadsheets previously produced in hard copy in response to Judge Lungstrum’s August 12, 2005 Order which had already been produced in native, electronic format in response to [Judge Waxse’s] previous orders.”5
Based on the Court’s review of the parties’ e-mails on this matter, the Court denies the relief sought by Plaintiffs at this time. Counsel are ordered to confer in person to attempt to resolve this issue. If they cannot resolve the issue, it will be taken up at the next discovery conference.
IT IS SO ORDERED.
2Jan. 19, 2006 Discovery Conf Transcript (Tr.) p. 3, l. 18-25. 3Jan. 19, 2006 Tr. p. 4, l. 10. 4Jan. 19, 2006 Tr. p. 4, l. 15-18. 5Defendant’s E-mail response attached as Exh. 1 to this Order.
2

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Dated in Kansas City, Kansas on this 24th day of January, 2006.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

3

 
 Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 1 of 32

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO., Defendant.

MEMORANDUM AND ORDER At the September 1, 2005 status conference, Plaintiffs submitted for the Court’s review a document entitled “List of Documents Withheld by Defendant Despite No Involvement of Legal Department or Counsel” (the “List”)1. In this document, Plaintiffs request the Court compel Defendant to produce the referenced documents. In support of this request, Plaintiffs assert Defendant fails in its privilege log to establish the elements required to invoke the attorney-client privilege or the work product doctrine for the referenced documents.

During the conference, the Court ultimately construed the “List” as a Motion to Compel (doc. 3203) and ordered Defendant to explain the basis for its objections to producing the documents at issue.2 The parties subsequently briefed the issues3 and, upon careful review of the pleadings and evidence submitted by counsel, as well as the applicable law, the Court is now ready to rule. For the reasons set forth below, Plaintiffs’ motion will be granted in part and denied in part.

1The List is attached as Exhibit 1 to the September 6, 2005 Court Order (doc. 3203).
2See September 6, 2005 Court Order at ¶6 (doc. 3203).
3See Defendant’s initial brief (doc. 3335), Plaintiffs’ responsive brief (doc. 3453) and Defendant’s sur-reply (doc. 3522).

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 2 of 32

Discussion

In their briefing, the parties group the privilege log documents at issue into the following five

(5) discrete categories:

C

Communications between Human Resources management and Janet Larson, an

individual within the Human Resources department who was asked by Sprint’s Law

Department to assist in collecting documents responsive to Plaintiffs’ requests;

C

Correspondence between non-lawyer members of management communicating legal

advice from Sprint’s Law Department;

C

Document containing handwritten notes taken by Sprint managers during meetings

with counsel; and

C

Documents containing adverse impact analyses that Judge Lungstrum allegedly ruled

were not discoverable in this matter.

C

Documents that have been, or will be, produced by Defendant with or without

redactions.

Based on these groupings, the Court first will address the attorney-client privilege as it

applies to each of the five (5) categories of documents. The Court then will address whether each

of the five (5) categories of documents is protected from disclosure by the work product doctrine.

A. The Attorney-Client Privilege

1. Attorney-Client Privilege: The Legal Standard Plaintiffs argue that without a showing of involvement by legal counsel, the documents on the List cannot be protected by the attorney-client privilege. In response, Defendant maintains it adequately has shown the documents on the List to be related to Sprint’s Legal Department. Given this dispute, the first issue to be determined by the Court is the extent to which legal counsel must be involved in a communication in order to establish the elements required to invoke the attorneyclient privilege.

2

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Because this action arises under a federal statutory scheme, federal law provides the rule of decision as to application of the attorney-client privilege.4 Under federal common law, the essential elements of the attorney-client privilege are:
(1) Where legal advice of any kind is sought (2) from a professional legal advisor in his capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or by the legal advisor, (8) except the protection be waived.5 Notably, and relevant to the dispute between the parties here, the Court finds the essential elements of the privilege as defined above do not require an attorney to have either authored or received the document at issue in order to maintain the privilege. The Court further finds that “[w]hat is vital to the privilege is that the communication be made in confidence for the purpose of obtaining legal advice from the lawyer.”6 In support of these findings, the Court relies on Proposed Rule of Evidence 503 and the resulting development of federal common law with regard to the attorney-client privilege issue. In 1972, the Chief Justice of the United States Supreme Court proposed to Congress various Rules of Evidence for federal courts (“Proposed Rules”).7 The Proposed Rules were drafted by the Judicial Conference Advisory Committee on Rules of Evidence and approved by the Judicial
4See Sprague v. Thorn Americas, Inc., 129 F.3d 1355, 1368-69 (10th Cir. 1997) (federal privilege law applies to federal claims). The Court notes no real conflict between federal and Kansas law regarding the attorney-client privilege exists. See Hiskett v. Wal-Mart Stores, Inc., 180 F.R.D. 403, 405 (D. Kan. 1998).
5Marten v. Yellow Freight Sys., Inc., No. 96-2013-GTV, 1998 WL 13244, at *5 (D. Kan. Jan. 6, 1998) (quoting Great Plains Mut. Ins. Co. v. Mutual Reinsurance Bureau, 150 F.R.D. 193, 196 n. 4 (D. Kan. 1993)).
6United States v. Kovel, 296 F.2d 918, 922 (2d Cir. 1961). 7Rules of Evidence for United States Courts and Magistrates, 56 F.R.D. 183 (1972).
3

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Conference of the United States and by the Supreme Court. 8 The Proposed Rules contained nine specific testimonial privileges, one of which specifically defined the attorney-client privilege:9
A client has a privilege to refuse to disclose and to prevent any other person from disclosing confidential communications made for the purpose of facilitating the rendition of professional legal services to the client, (1) between himself or his representative and his lawyer or his lawyer’s representative, or (2) between his lawyer and the lawyer's representative, or (3) by him or his lawyer to a lawyer representing another in a matter of common interest, or (4) between representatives of the client or between the client and a representative of the client, or (5) between lawyers representing the client.10 Proposed Rule 503(b) expressly recognizes that the attorney-client privilege protects confidential communications made both by the client and to the client. Moreover, Proposed Rule 503(b) clarifies that the attorney-client privilege protects confidential communications not only between lawyer and client, but also among various other individuals who need to know the content of the confidential communications to further the rendition of legal services to the client.11 Proposed Rule 503 ultimately was rejected by Congress in favor of the more general language within Fed. R. Evid. 501 to “provide the courts with the flexibility to develop rules of privilege on a case-by-case basis,” and “to leave the door open to change.”12 “Although Congress did not adopt this rule, courts have relied upon Proposed Rule 503(b) as an accurate definition of the federal
8Jaffee v. Redmond, 518 U.S. 1, 9 n.7 (1996) (citation omitted). 9Id. (citing Proposed Rules 501-513, 56 F.R.D. 183, 230-261 (1972)). 10Proposed Rule 503(b), 56 F.R.D. at 236 (emphasis added). 11Id. 12Trammel v. United States, 445 U.S. 40, 47 (1980) (quoting 120 Cong. Rec. 40891 (1974) (statement of Rep. Hungate)); see also Jaffee, 518 U.S. at 8 (citing S. Rep. No. 93-1277, at 13 (1974), reprinted in 1974 U.S.C.C.A.N. 7051, 7059)).
4

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common law of attorney-client privilege.”13 Numerous courts have observed that Proposed Rule 503 is “‘a useful starting place’ for an examination of the federal common law of attorney-client privilege.””14 As one treatise has observed, “[Proposed Rule 503] restates, rather than modifies, the common-law lawyer-client privilege. Thus, it has considerable utility as a guide to the federal common law.”15
One of the first cases citing to Proposed Rule 503 as part of an examination into the federal common law of attorney-client privilege was Eutectic Corporation v. Metco, Inc.16 In Eutectic, the plaintiffs challenged the validity of the defendant’s patents and moved to compel the defendant to produce certain documents. The communications the defendant sought to withhold involved five persons: the two co-inventors of the patents in question, the attorney retained by the defendant, a vice-president of the company who was a patent liaison to the attorney, and his assistant liaison. Since the attorney did not send any of the communications and was not the original recipient of them, the plaintiffs contended that the documents were merely intracorporate communications and thus outside the scope of the attorney-client privilege.
13United States v. Spector, 793 F.2d 932, 938 (8th Cir. 1986), cert. denied, 479 U.S. 1031 (1987) (citing 2 J. Weinstein, Evidence ¶ 503(2) at 503-17 (1975) (“[D]espite the failure of Congress to enact a detailed article on privileges, Standard 503 should be referred to by the Courts.”)).
14 Subpoena Duces Tecum, 112 F.3d 910, 915 (8th Cir. 1997) (quoting In re Bieter Co., 16 F.3d 929, 935 (8th Cir. 1994)).
153 Jack B. Weinstein & Margaret A. Berger, Weinstein’s Federal Evidence, § 503.02 (Joseph M. McLaughlin, ed., Matthew Bender 2d ed.1997); see also id. at § 501.02 (noting that the proposed evidence rules concerning privilege were the culmination of seven years of work done by judges, lawyers, and academics and that the rules were approved by the Supreme Court by a vote of eight to one).
1661 F.R.D. 35 (E.D.N.Y. 1973). 5

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Although the court found no explicit request from the attorney for the information, the court ultimately did find the documents to be protected by the attorney-client privilege in that the defendants provided sufficient proof to establish that the documents contained confidential information gathered for the dominant purpose of facilitating the attorney’s efforts to provide services to the client.17
This Court subscribes to the view of the court in Eutectic.18 Organizational clients and business entities often are personified by a number of employees. In preparation for, or in the midst of, consultations with an attorney, employees of the client will often consult one another to ensure that the attorney’s advice is based on full knowledge of all relevant facts. With regard to the attorney-client privilege, the United States Supreme Court specifically acknowledges that “sound legal advice or advocacy serves public ends and that such advice or advocacy depends upon the lawyer being fully informed by the client.”19 The Court goes on to say that “[t]he lawyer-client privilege rests on the need for the advocate and counselor to know all that relates to the client’s reasons for seeking representation if the professional mission is to be carried out.”20
1761 F.R.D. at 40. 18Notably, this Court previously issued an unpublished opinion consistent with the holding in Eutectic. See Lintz v. American Gen. Finance, Inc., Civ. 98-2213-JWL, 1999 WL 450197, at *4 (D. Kan. June 24, 1999) (holding that although written communication between management employees of defendant is not necessarily protected by the attorney-client privilege, defendant successfully demonstrated applicability of privilege by establishing that written communication was confidential in nature and contained legal advice obtained from counsel for defendants). 19Upjohn Co. v. United States, 449 U.S. 383 (1981) (quoting Trammel v. United States, 445 U.S. 40, 51 (1980)). 20Id.
6

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For all of these reasons, the Court finds that although written communication between corporate management employees is not necessarily protected by the attorney-client privilege, a party may be able to successfully demonstrate applicability of privilege by establishing that the communication was made in confidence for the primary purpose of obtaining legal advice.21 In order to do so, however, the party asserting the privilege must be able to establish the other elements of the privilege. For example, no privilege will attach for documents designed merely to communicate non-privileged business data or for documents where the element of confidentiality is lacking.
With these parameters in mind, the Court now will address whether the attorney-client privilege protects from disclosure any of the privilege log documents grouped into the five (5) categories described above.
2. Attorney-Client Privilege: Category One Documents In support of its attorney-client privilege argument, Defendant begins by asserting the Category One documents listed in the privilege log (1) are not relevant to Plaintiffs’ claims because they were created after this case was filed; and (2) are not responsive to any discovery request made by Plaintiffs. Upon consideration of these assertions, the Court finds them immaterial to the issue presented in this motion to compel: whether the attorney-client privilege protects from disclosure
21See Lintz,1999 WL 450197 at *4; see also United States v. Chevrontexaco Corp., 241 F.Supp.2d 1065, 1077 (N.D. Cal. 2002); In re Grand Jury Proceedings, M-11-189, 2001 WL 1167497, at *24 (S.D.N.Y. Oct. 3, 2001); Penn Valley Pump Co., Inc. v. Alfa Laval Pumps, Inc., No. 97-5194, 1999 WL 1293348 (E.D. Pa. Dec. 30, 1999); First Chicago Intern. v. United Exchange Co. Ltd., 125 F.R.D. 55, 58 (S.D.N.Y. 1989); Cuno, Inc. v. Pall Corp., 121 F.R.D. 198, 203 (E.D.N.Y. 1988); United States v. American Tel. & Tel. Co., 86 F.R.D. 603, 619 (D.D.C. 1979); Burlington Indus. v. Exxon Corp., 65 F.R.D. 26, 39 (D. Md. 1974); Eutectic, 61 F.R.D at 40; Danisch v. Guardian Life Insur. Co. of Am., 18 F.R.D. 77, 80 (S.D.N.Y. 1955).
7

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 8 of 32
any of the Category One privilege log documents. Accordingly, the Court finds Defendant’s first assertions not relevant to the issues before the Court.
Next, Defendant argues that the Category One documents listed in the privilege log are protected from disclosure by the attorney-client privilege on grounds that the documents represent communications between Human Resources management and Janet Larson, an individual within the Human Resources department who was asked by Sprint’s Law Department to assist in collecting documents responsive to Plaintiffs’ document requests. The Court disagrees.
First, the Court finds Defendant’s characterization of the documents in its pleadings to be wholly inconsistent with the detailed privilege log provided by Defendant prior to briefing this issue. And even if the privilege log did describe the documents as written internal requests for production of documents made at the direction of an attorney, this general description – without any further detail – fails to establish the elements required to invoke the attorney-client privilege. Simply put, Defendant’s blanket claim as to the applicability of the privilege fails to assert – let alone establish – that the documents are confidential substantive communications that involve requesting or providing legal advice.
As opposed to a blanket claim of privilege, Fed. R. Civ. P. 26(b)(5) requires a party withholding otherwise discoverable information on the basis of privilege or other protection to make the claim expressly and to describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing the privileged or protected information, will enable the other parties to assess the applicability of the privilege or protection. Normally, this is accomplished by objecting and providing a privilege log for documents, communications, or things not produced.
8

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 9 of 32
The party asserting the privilege bears the burden of establishing its existence.22 The asserting party must make a “clear showing” that the asserted objection applies.23 To carry that burden, the asserting party must “describe in detail” the documents or information sought to be protected and provide “precise reasons” for the objection to discovery.24 In addition, the asserting party must provide sufficient information to enable the court to determine whether each element of the asserted objection is satisfied; a “blanket claim” as to the applicability of the privilege does not satisfy the burden of proof.25 Defendant’s failure to meet this burden when the trial court is asked to rule upon the existence of the privilege is not excused because the document is later shown to be one that would have been privileged if a timely showing had been made.26
In rejecting Defendant’s blanket claim of privilege, the Court now turns to the detailed privilege log submitted by Defendant in this case. Upon review of the privilege log, the Court finds, with the exception of three (3) documents, that the information provided by Defendant for Category One documents is inadequate to meet the burden of proof with regard to a claim of protection based on the attorney-client privilege.
22Id. 23Ali v. Douglas Cable Comm., Ltd. Partnership, 890 F. Supp. 993, 994 (D. Kan. 1995). 24McCoo v. Denny’s, Inc., 192 F.R.D. 675, 680 (D. Kan. 2000) (citing Nat’l Union Fire Ins. Co. v. Midland Bancor, Inc., 159 F.R.D. 562, 567 (D. Kan. 1994)). 25Id. (citing Jones v. Boeing Co., 163 F.R.D. 15, 17 (D. Kan. 1995) and Kelling v Bridgestone/Firestone, Inc., 157 F.R.D. 496, 497 (D. Kan. 1994)). 26Peat, Marwick, Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984).
9

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As a preliminary matter, the privilege log indicates that only one (1) of the 154 Category One documents was authored or received by a member of Defendant’s Legal Department. Notwithstanding identification of an attorney as the recipient of this communication, the rather generic description of this document as an “email re: presentation” ultimately fails to demonstrate the more critical element of the privilege: that the communication was made in confidence for the primary purpose of obtaining legal advice or services. Notably, “not all communications between attorney and client are privileged; rather, they must relate to legal advice.”27
The privilege log further indicates that the remaining 153 Category One documents are written materials authored by an unknown individual or an employee in Human Resources and sent to either another unknown individual or another Human Resources employee. Although this fact initially weighs against a conclusion that the documents were created to give or request legal advice, the Court has found, supra, that identification of the author and recipient as non-lawyers is not determinative of the privilege issue. Again, the central inquiry is whether the communication was made in confidence for the primary purpose of obtaining legal advice or services.
Of the 154 Category One documents, the Court finds that only three (3) document descriptions in the privilege log include references to an attorney, lawyer or legal advice:

Bates
3098530986
163678163679

Type email
email

Date

Author

8/17/04 - HR 8/18/04 emplo yee(s)

11/10/02 PCS employee(s)

Recipient
HR employee(s)
HR, PCS employee(s)

Subject
email including legal advice re: calibration data
email re: results of first legal review 11/5/02

Privilege A /C , W P
A /C , W P

27Burton v. R.J. Reynolds Tobacco Co., 177 F.R.D. 491, 496-97 (D. Kan. 1997) (citations omitted).
10

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 11 of 32

181540- ????? unknown unknown 181541

unknown

workforce realignment & selection A/C process transmitting legal advice re: demographic analysis

The Court finds that with respect to the documents bearing bate stamps 30985-30986 and

163678-163679, Defendant has met the burden of proof with regard to a claim of protection based

on the attorney-client privilege: the privilege log adequately describes the documents at issue as

communications made in confidence for the primary purpose of obtaining legal advice or services.

Defendant has failed, however, to meet the burden of proof with regard to a claim of protection

based on the attorney-client privilege for documents bearing bate stamps 181540-181541. Although

the document is summarily described as one that includes legal advice, Defendant fails to identify

either an author or a recipient for the communication. Because both the author and recipient of this

document are designated as unknown, the Court is not persuaded that the information regarding the

workforce realignment and selection process involved the requesting or giving of legal advice.

For these reasons, and with the exception of the documents bearing bate stamps 30985-30986

and 163678-163679, the Court finds the information provided by Defendant in its privilege log for

Category One documents is inadequate to meet the burden of proof with regard to a claim of protection based on the attorney-client privilege. Again, it is the party asserting the privilege that must make a “clear showing” that the asserted objection applies.28 To carry that burden, the asserting

party must provide sufficient information to enable the court to determine whether each element of the asserted objection is satisfied.29 It is well settled that Defendant’s failure to meet its burden when

the court is asked to rule upon the existence of the privilege is not excused because the document is

28Ali, 890 F. Supp. at 994. 29McCoo, 192 F.R.D. at 680 (citing Jones, 163 F.R.D. at 17).
11

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 12 of 32

later shown to be one that would have been privileged if a timely showing had been made.30

3. Attorney-Client Privilege: Category Two Documents Defendant argues the Category Two documents listed in the privilege log are protected from disclosure by the attorney-client privilege because such documents represent the communication of

legal advice between non-lawyer members of Defendant’s management team.

As in the preceding subsection, the Court finds Defendant’s characterization in the pleadings

of Category Two documents to be inconsistent with the detailed privilege log provided by Defendant prior to briefing this issue. The Court finds that documents bearing bate stamps 7618-7619, 44511-55512 [sic]31, 20513-20516, 20517-20541, 26010-26011, 35300-35302 are adequately

described as legal advice communicated between non-lawyer members of Defendant’s management

team. This description is consistent with a finding that the documents were confidential and

communicated to non-lawyers to further the rendition of legal services to the client, which the Court

has found, supra, to be a communication protected by the attorney-client privilege.

The rest of the documents in Category Two can be grouped into the following subcategories:

C

ethics help line reports drafted by an unknown person and communicated to no one;

C

case reports regarding investigations of various employees that were drafted by an

unknown person and communicated to no one; and

C

emails within the human resources department regarding human resource meetings

and issues related to human resources.

The Court finds the information provided by Defendant in its privilege log for these

30Peat, Marwick, Mitchell & Co., 748 F.2d at 542.
31This document is erroneously listed as 44511-55512, when the privilege log actually identifies the document as 44511-44512.
12

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 13 of 32
subcategories of documents is inadequate to meet the burden of proof with regard to a claim of protection based on the attorney-client privilege. Again, Defendant has failed to include information in the privilege log for these documents from the Court could find that documents qualify as communications made in confidence for the primary purpose of obtaining legal advice or services.
4. Attorney-Client Privilege: Category Three Documents Defendant argues the Category Three documents listed in the privilege log are protected from disclosure by the attorney-client privilege because each of the documents contains handwritten notes taken by Defendants’ managers during meetings with counsel. The Court rejects this blanket argument. “Not every communication between an attorney and client is privileged, only confidential communications which involve the requesting or giving of legal advice.”32 “The focal point of the protection afforded by the attorney-client privilege lies with ‘communications’ between attorneys and their clients” – although the privilege protects disclosure of substantive communication between attorney and client, “it does not protect disclosure of the underlying facts by those who communicated with the attorney.”33 [T]he protection of the privilege extends only to communications and not to facts. A fact is one thing and a communication concerning that fact is an entirely different thing. The client cannot be compelled to answer the question, “What did you say or write to the attorney?” but may not refuse to disclose any relevant fact within his knowledge merely because he incorporated a statement of such fact into his communication to his attorney.34
32Burton v. R.J. Reynolds Tobacco Co., Inc., 175 F.R.D. 321, 327 (D. Kan. 1997) (citing Fisher v. United States, 425 U.S. 391, 403 (1976); United States v. Olano, 62 F.3d 1180 (9th Cir. 1995)).
33IMC Chemicals, Inc. v. Niro, Inc., No: 98-2348-JTM, 2000 WL 1466495, at *8-9 (D. Kan. July 19, 2000) (quoting Upjohn Co. v. United States, 449 U.S. 383, 395-96 (1981)).
34Id. 13

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 14 of 32

Accordingly, if relevant facts are incorporated into an otherwise attorney-client protected

document, the document still will be subject to disclosure after redaction of the privileged material.35

In other words, a party cannot shield documents and/or facts from disclosure by combining them or

interlacing them with privileged material; nonprivileged underlying factual information must be

disclosed and the log must be specific enough for the Court and the opposing party to determine into

which category the information falls.

Based on its review of Defendant’s privilege log for the Category Three documents, the

Court finds the following documents are protected from disclosure by the attorney-client privilege:

C

the handwritten portion of the documents bearing bates stamps 22230-22245,

described in the privilege log as “email with handwritten notes including references

to legal issues associated with RIF”; and

C

the handwritten portion of the documents bearing bates stamps 46294-46298,

described in the privilege logs as “handwritten notes by Marvin Motley (HR) re:

adverse impact”

This finding is based on the fact that the handwritten notes are adequately described in the log as

legal advice communicated between non-lawyer agents employed within the human resources

department of Defendant. With that said, however, there is no indication in the privilege log that the

documents upon which the handwritten notes appear are anything but nonprivileged underlying

factual information interlaced with privileged materials; accordingly, the underlying email and

documents are not protected from disclosure.

With regard to the remainder of the Category Three documents, Defendant has failed to meet

its burden of proof with regard to a claim of protection based on the attorney-client privilege.

Although many of the documents are summarily described as communications involving

35Burton., 177 F.R.D. at 499-500. 14

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 15 of 32
conversations with or about legal counsel, Defendant fails to identify either an author or a recipient for the communication. Because both the author and the recipient of this document are designated as unknown, the Court simply is not persuaded that the handwritten notes involve the requesting or giving of legal advice. Moreover, although the descriptions include references to conversations with legal counsel, Defendant has not established that the notes reflect communications made to further the rendition of legal services to the client. Again, “[n]ot every communication between an attorney and client is privileged, only confidential communications which involve the requesting or giving of legal advice.”36
5. Attorney-Client Privilege: Category Four Documents Defendant identifies this category as documents containing confidential and privileged adverse impact analyses that Judge Lungstrum previously ruled were not discoverable in this matter. Plaintiffs disagree on two levels. First, Plaintiffs maintain that many of the documents identified as adverse impact analyses by Defendant in the pleadings are not described as such in the privilege log. Second, Plaintiffs argue that Judge Lungstrum’s ruling was applicable only to the two particular adverse impact documents involved in his in camera review, and not to every document that contains adverse impact information. The appropriate starting place for this discussion is Judge Lungstrum’s previous rulings on the issue, which has been transcribed as follows:
36Burton, 175 F.R.D. at 327 (citing Fisher, 425 U.S. at 403; Olano, 62 F.3d at 1180). 15

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 16 of 32

[A]lthough my earlier ruling was limited to certain documents specifically that I reviewed and said these are clearly within the ambit of attorney/client privilege, I have seen nothing that leads me to believe that age impact documents generated as a specific request in connection with a specific RIF by the legal department of the defendant would be anything other than attorney/client privileged documents …. It appears to me that this case in that sense is garden variety, and so therefore if all there is are documents – no matter how helpful or interesting they would be if I were the plaintiff in this case – that were generated in response to defendant’s lawyers saying, We would like to look at this so that we can give you some advice about what you ought to do in connection with that RIF, that’s just not something the plaintiffs are going to be able to get to.37

With Judge Lungstrum’s ruling in mind, and upon a review of the privilege log documents

identified within Category Four, the Court finds Defendant has met its burden of proof with regard

to a claim of protection based on the attorney-client privilege for the following Category Four

documents from the privilege log, which can be separated into the following subgroups:

C

Documents identified in the “Type of Document” column as

C

“impact ratio analysis” documents

C

“adverse impact analysis” documents

C

“adverse impact” documents

C

Documents identified as “spreadsheets” in the “Type of Document” column described as

C

“adverse impact”

C

“impact ratio analysis”

C

“due diligence matrix”

C

Documents identified as “emails” in the “Type of Document” column and described as

including and/or attaching for transmittal

C

adverse impact information

C

impact ratio analysis

C

legal advice re IT directors

Eliminating these documents, the Court finds only the following twenty-five (25) Category 4

privilege log documents remain for a determination regarding the attorney-client privilege:

37March 31, 2005 Transcript of Proceedings before the Honorable John W. Lungstrum, Ex. C to Defendant’s Index of Exhibits (doc. 3419) at pp. 11-12.
16

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 17 of 32

54563-74

email 2/19/02

54627-28 54629 54630

email 2/25/02 email 2/22/02 email 3/1/02

54769
54874
57214 57215 57236-48 57305-26 57327-28
57329 57330 57383-84
57429-71 57136-47

email 2/242/25/02
email 3/2/028/26/04
email 2/22/02
email 3/1/02 email 2/18/02 email 3/11/02
email 2/242/25/02
email 2/22/02
email 3/1/02 email 2/24-
2/25/04 email 3/2/02 email 2/19/02

57212-13 57168-89 153456-58 153915-17

email 2/24/022/25/02
email 3/11/02
email 2/24/03 2/25/03
email 2/24/03

153918-19

email 12/30/02

153955-4001 154084-95

email email

12/27/02 12/30/02

HR HR
HR HR HR HR HR HR
HR HR

email re 2002-CC Corp Com & BD-alpha ratings Egrades with attached alpha ratings spreadsheet

AC, WP

email re 2002-CC-Finance- re: alpha changes

AC

email re 2002-CC-Finance- re: attorney-client privileged doc AC

email re 2002-CC-Finance-re” EEO analysis -

AC

managers and professionals

email re alpha changes

AC

HR HR CA email re finance-Krause directs EEO alpha analysis 04-LT

HR HR

email re attorney-client privileged document

HR HR

email re EEO analysis - manager and professionals

HR HR

email re client ratings 2-18-02

HR HR

email re 2002 - CC - Finance - PF A B and C

HR HR and email re alpha changes Finance

HR HR

email re attorney-client privileged document

HR HR

email re EEO analysis - managers and professionals

HR HR

email re alpha changes

AC
AC, WP AC AC AC, WP AC
AC AC AC

HR HR HR HR
HR HR

email re Krause directs EEO alpha analysis
email re 2002 CC - corp com & BD - alpha ratings Egrades
email re alpha changes

AC AC
AC, WP

HR HR HR HR

email re 2002 CC - Finance - PF D, E and F E-Mail re ntwk svcs demographics

AC AC, WP

HR HR

E-Mail re ntwk svcs demographics with attached demographics

HR IT/

E-Mail re summary of Monday’s discussion

Network

HR HR

E-Mail re network services director selection master

HR HR

E-Mail re summary of Monday’s discussion with attached director priority list

AC, WP AC AC AC, WP

17

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 18 of 32

163528-31 163667-68

email email

11/5/0211/8/02
11/14/02

PCS HR
HR HR, PCS

emails to John Shannon (HR) re Davis Al, Batt Al and prep for reductions
email re realignment worksheets

AC, WP AC

Upon review of the descriptions for these twenty-eight (28) emails, the Court finds Defendant has failed to meet its burden of proof with regard to a claim of protection based on the attorney-client privilege. As a preliminary matter, descriptions designating documents as “attorney-client privileged” with no other information are insufficient to properly make a claim of privilege. As previously stated, Fed. R. Civ. P. 26(b)(5) requires a party withholding otherwise discoverable information on the basis of privilege to make the claim expressly and to describe the nature of the documents not produced in a manner that, without revealing the privileged information, will enable the other parties to assess the applicability of the privilege or protection.
Simply put, the privilege log fails to include a description establishing the referenced communications were made in confidence for the primary purpose of obtaining legal advice or to include a description establishing that the documents were, in Judge Lungstrum’s words, “generated in response to defendant’s lawyers saying, ‘We would like to look at this so that we can give you some advice about what you ought to do in connection with that RIF.’” Thus, Defendant has failed to meet its burden of proof with regard to a claim of protection based on the attorney-client privilege for these twenty-eight (28) documents.
6. Attorney-Client Privilege: Category Five Documents Defendant argues the Category Five privilege log documents for which it claims protection based on the attorney-client privilege listed below are documents that have been, or will be, produced with or without redactions.
18

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 19 of 32

2045620460 2222822229 4436644367 4642546426 5455054562 5477054776 183392
181374
181636
179372
179373 182105

email

3/08/02

HR

HR

email transmitting adverse impact analysis AC, WP

email
Ethics Help line Report email

10/8/0210/9/02 3/25/02
8/16/02

HR

HR

unknown NA

GMG

HR

email transmitting memorandum regarding AC WARN issues

ethics help line report re management practices/property rights of others

AC, WP

email re business stack ranking

AC

email
email
email
handwritten note handwritten notes email
email email

2/18/02
3/2/023/25/02 3/14/02
unknown
unknown
6/11/04
6/11/04 10/23/0310/24/03

HR

HR

HR

HR

Mgr

HR, Dir Adv.

Tech. Lab Ntwk Sys Dev.

unknown unknown

email re 2002-CC- client ratings 2/18/02 with attached alpha ratings spreadsheet
email re alpha exceptions and stub grants incl atty work product from Ned H olland
email re CM R LINK rating/merit discussion with Carol Kippes
handwritten note re email file

unknown NA

handwritten notes re RIF file

HR
HR PCS, HR

HR

email re action required: November 2003

employee travel and expense report

HR

email re 2003 LINK ratings

HR, PCS, Bus

email re open position - test engineer I

Indirect Acct Mgr

AC, WP AC, WP AC AC AC AC AC AC

In response, Plaintiffs claim that many of these documents are not protected by the attorneyclient privilege and should be produced in their entirety without redaction. Upon review of the descriptions provided in the privilege log, the Court finds that Defendant shall be permitted to produce redacted versions of documents bearing bates stamp numbers 20456-60 and 22228-29 with regard to adverse impact analyses and advice regarding WARN. The Court finds the remainder must be produced without redaction as the description provided fails to establish the referenced communications were made in confidence for the primary purpose of obtaining legal advice.

19

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B. Work Product Protection 1. Work Product: The Legal Standard With regard to those documents identified in the privilege log as attorney work product,
Plaintiffs argue again that, without a showing of involvement by legal counsel, the documents at issue cannot be protected by the work product doctrine.
To establish work product protection, a party must show that “(1) the materials sought to be protected are documents or tangible things; (2) they were prepared in anticipation of litigation or for trial; and (3) they were prepared by or for a party or a representative of that party.”38 Because there does not appear to be a dispute that the materials sought are documents or that they were prepared by or for Defendant or a representative of Defendant, the Court will address only the pivotal issue presented: whether the documents were prepared in anticipation of litigation.
The work product doctrine, which is embodied in Rule 26(b)(3) of the Federal Rules of Civil Procedure, protects from discovery documents, things and mental impressions of a party or his representative, particularly his attorney, developed for or in anticipation of litigation or trial.39 The purpose of the doctrine is to permit attorneys to prepare for litigation with a “certain degree of privacy,” and without undue interference or fear of intrusion or exploitation of one’s work by an adversary.40 In other words, the doctrine is not intended to protect investigative work unless done so under the supervision of an attorney in preparation for the real and imminent threat of litigation or trial; thus, work prepared in the ordinary course of business and inserted into a protected document may still be
38Johnson v. Gmeinder, 191 F.R.D. 638, 643 (D. Kan. 2000) (citations omitted). 39Fed. R. Civ. P. 26(b)(3). 40Hickman v. Taylor, 329 U.S. 495, 510-11 (1947).
20

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subject to disclosure after redaction of any privileged material. The Advisory Committee Notes to the federal rule establishing work product protection also recognize this need: “In enforcing [the Rule 26(b)(3) protection of work product material], the courts will sometimes find it necessary to order disclosure of a document but with portions deleted.”41
Thus, the work product doctrine only applies to those documents and tangible things prepared in anticipation of litigation, and in order for the discovery limitation to apply, there must be a substantial probability that litigation will ensue at the time the documents were drafted.42 “Certainly by implication the . . . rule precludes any idea of extending the work product doctrine to reports or statements, even if written, obtained by the client or his investigators which are not prepared under the supervision of an attorney in preparation for trial.”43
The issue of whether documents were prepared in anticipation was extensively analyzed by Judge Rushfelt in Marten v. Yellow Freight System, Inc.44 The court stated:
The work product standard has two components. The first is what may be called the “causation” requirement. This is the basic requirement of the Rule that the document in question be produced because of the anticipation of litigation, i.e., to prepare for litigation or for trial. The second component is what may be termed a “reasonableness” limit on a party’s anticipation of litigation. Because litigation can, in a sense, be foreseen from the time of occurrence of almost any incident, courts have interpreted the Rule to require a higher level of anticipation in order to give a reasonable scope to the immunity. The court looks to the primary motivating purpose behind the creation of the document
41Fed. R. Civ. P. 26 advisory committee’s note, subdivision (b)(3) (1970). 42Cypress Media, Inc. v. City of Overland Park, 268 Kan. 407, 427, 997 P.2d 681 (2000); Alseike v. Miller, 196 Kan. 547, 558, 412 P.2d 1007 (1966). 43Alseike, 196 Kan. at 558. 44 No. 96-2013-GTV, 1998 WL 13244, at *10 (D. Kan. Jan. 6, 1998).
21

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to determine whether it constitutes work product. Materials assembled in the ordinary course of business or for other non-litigation purposes are not protected by the work product doctrine. The inchoate possibility, or even the likely chance of litigation, does not give rise to work product. To justify work product protection, the threat of litigation must be “real and imminent.” To determine the applicability of the work product doctrine, the court generally needs more than mere assertions by the party resisting discovery that documents or other tangible items were created in anticipation of litigation.45
2. Work Product: Category One Documents
As noted above, Defendant asserts Category One documents consist of communications
between Human Resources management and Janet Larson, an individual within the Human Resources
department who was asked by Sprint’s Law Department to assist in collecting documents responsive
to Plaintiffs’ requests. Defendant further asserts that the following Category One documents are
protected from disclosure by the work product doctrine:

Bates No. 30985-30986 46356-46357 46360-46361 46365-46389 47784-47800 47801-47817 53882-53895 54767

Type

Date

Author Recipient Subject

Priv

email

8 / 1 7 - HR

HR

8/18/04

email including legal advice re: calibration data

A/C, WP

alpha

1/15/03 HR

NA

summ ary

alpha summary of Bob McC uller w/ vision statement W P

alpha

1/15/03 HR

NA

summary

alpha summary of Bob McCuller w/ vision statement W P

alpha

2/26/03 HR

NA

alpha ration tool distribution summary

WP

rating tool

spread

10/23/04 HR

NA

Honolulu operator center final list 11-02

WP

sheet

spread

10/23/04 HR

NA

Honolulu operator center final list 11-02

WP

sheet

email

2/19/02 HR

HR

email re: E-G rade rating info with attached TS E- A/C,

Grade spreadsheets

WP

email

8 / 2 5 - HR 8/26/02

HR CA04- email re: 2002 CC calibration LT

A/C, WP

45Id. at *10 (citations and quotations omitted). 22

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 23 of 32

55408

email

55537

email

55666-55667 email

55797

email

55968

email

163678-163679 email

8 / 2 2 - HR 8/30/04
8 / 2 2 - HR 8/30/04
8/30/04 HR
8 / 2 7 - HR 8/30/04
8 / 2 7 - HR 8/30/04
11/10/02 PCS

HR CA04- email re: confidential year end ratings LT

A/C, WP

HR CA04- email re: confidential year end ratings LT

A/C, WP

HR CA04- email re: confidential/calibration LTD CSO 2002 yr A/C,

LT

end ratings

WP

HR CA04- email re: 2002 yr end ratings LT

A/C, WP

HR CA04- email re: 2002 yr end ratings LT

A/C, WP

HR, PCS email re: results of first legal review 11/5/02

A/C, WP

As a preliminary matter, the Court already has deemed the documents identified in the first and the last lines of the table (bearing bates stamps 30985-30986 and 163678 - 163679) as protected from disclosure by the attorney-client privilege; thus, it is unnecessary to determine whether the work product doctrine protects the documents from disclosure as well.
As to the rest of the documents in this table, the Court finds the descriptions provided (“lists,” “summaries,” “calibrations,” and “ratings”) are insufficient to establish work product protection. There is nothing in the descriptions to persuade the Court that these written materials were created, collected or considered in any context other than the normal course of business.
3. Work Product: Category Two Documents Defendant argues the following Category Two documents listed in the privilege log are protected from disclosure by the work product doctrine because such documents represent the communication of legal advice between non-lawyer members of Defendant’s management team:

76187619

email

11/14/02 HR

HR LINK calibration comm unicating legal advice from Donna A/C,

Crosswhite (SL) and Jill Ferrel (SL) to clients

WP

23

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 24 of 32

4447444475 4450944510 4451144512 4455244553 44554
44555
44559
4456044561 154188154197 154259154268

proprietary information spreadsheet Case Report case report case report case report case report case report email email

unknown unknown NA

unknown unknown NA

01/02/03 unknown NA

4/30 8/30/02
6/15 6/17/02
7/15/02

unknown NA unknown NA unknown NA

11/5/02 unknown NA

9/30 -

unknown NA

10/11/02

1/9/03

HR

HR,

PCS

1/9/03

HR

HR,

PCS

corporate security investigations of Jerry Batt (PCS) & executives case number key 3-38/00001
Case report for 3-38-00001 including legal advice investigation re: emails from Judy Fox to Mark Greenly
investigation re: email from concerned person sent to Ron LeMay investigation re: email from Rick W ilcox to ethics help line and Len Lauer investigation of Jerry Batt (PCS)
investigation re: Mike Miller, Tom O’D ea (PCS) and Cloene Davis (PCS) email re: follow-up with attached retirement tools and questions from the HR Network email re: follow-up with attached transition team conference call

WP
WP
AC, WP
A/C, WP
A/C, WP
A/C, WP
A/C, WP
A/C, WP
A/C, WP
A/C, WP

In section (A)(3), supra, the Court determined the documents bearing bates stamps 7618-7619

and 44511-44512 are protected from disclosure by the attorney-client privilege; accordingly, the Court

will not address whether these documents are also protected by the work product doctrine.

The rest of the documents in Category Two can be grouped into the following two

subcategories:

C

case reports regarding investigations of various employees that were drafted by an

unknown person and communicated to no one; and

C

emails within the human resources department regarding retirement tools and a

transition team conference call.

With regard to these remaining documents, the Court finds the information provided by

Defendant in its privilege log is inadequate to meet the burden of proof with regard to a claim of

24

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 25 of 32

protection based on the work product doctrine. Defendant has failed to include information in the privilege log for these documents from which the Court could find that documents were prepared under the supervision of an attorney in preparation for litigation. Again, there is nothing in the descriptions to persuade the Court that these written materials were created, collected or considered in any context other than the normal course of business.
4. Work Product: Category Three Documents Defendant claims protection by the work product doctrine for only one Category Three document within the privilege log:

4629446298

handwritten 2/12/03 notes

HR

NA

handwritten notes by Marvin Motley (HR) re: adverse impact

A/C, WP

Because the Court already deemed this document to be protected from disclosure by the attorney-client privilege in the preceding section, it is unnecessary to determine whether the work product doctrine protects the document from disclosure as well.
5. Work Product: Category Four Documents Defendant identifies the documents in Category Four as documents containing adverse impact analyses that Judge Lungstrum previously ruled were not discoverable in this matter. Given the number of documents within this category, the Court finds it helpful to group the documents into the following two subcategories: (a) documents for which Defendant claims protection by both the attorney-client privilege and the work product doctrine; and (b) documents for which Defendant claims protection by only the work product doctrine.

25

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 26 of 32

a. Subcategory (a): Category Four Documents for which Defendant Claims Protection by both the Attorney-Client Privilege and the Work Product Doctrine
Excluding those documents the Court deemed to be protected by the attorney-client privilege in the preceding section, only the following eight (8) Category Four documents remain for decision by the Court with respect to work product protection:

5456354574

email 2/19/02 HR

HR

email re 2002-CC C orp Com & BD -alpha ratings AC,

E-grades with attached alpha ratings spreadsheet WP

57214

email 2/22/02 HR

HR

email re attorney-client privileged document

AC,

WP

57305-

email 3/11/02 HR

HR

email re 2002 - CC - Finance - PF A B and C

AC,

57326

WP

57212- email 2/24/02- HR

HR

email re alpha changes

AC,

57213

2/25/02

WP

153456- email 2/24/03 HR

HR

E-Mail re ntwk svcs demographics

AC,

153458

2/25/03

WP

153915- email 2/24/03 HR 153917

HR

E-Mail re ntwk svcs demographics with attached AC,

demographics

WP

154084154095

email

12/30/02 HR

HR

E-Mail re summary of Monday’s discussion with

AC,

attached director priority list

WP

163528- email 11/5/02- PCS

HR

emails to John Shannon (HR) re Davis Al, Batt Al and AC,

163531

11/8/02

prep for reductions

WP

Upon review of the descriptions for these eight (8) emails, the Court finds Defendant has failed to meet its burden of proof with regard to a claim of protection based on work product. As noted in the preceding section, descriptions designating documents as “attorney-client privileged” with no other information are insufficient to properly make a claim of privilege. Defendant has failed to include information in the privilege log for these eight (8) documents from which the Court could find that documents were prepared under the supervision of an attorney in preparation for litigation and, again, there is nothing in the descriptions to persuade the Court that these written materials were created,

26

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 27 of 32

collected or considered in any context other than the normal course of business.

b. Subcategory (b): Category Four Documents for which Defendant Claims Protection by the Work Product Doctrine Only
Upon review of the Category Four documents for which Defendant claims protection by the work product doctrine only, the Court finds Defendant has met its burden of proof with regard to a claim of protection based on the work product doctrine for the following documents:

C

Documents identified in the “Type of Document” column as

C

“impact ratio analysis” documents

C

“adverse impact analysis” documents

C

“impact analysis” documents

C

Documents identified as “spreadsheets” in the “Type of Document” column and

described as

C

“adverse impact”

C

“impact ratio analysis”

C

“due diligence matrix”

C

Documents identified as “emails” in the “Type of Document” column and described as

communicating information regarding “adverse impact”

C

Documents identified as “Job Aid” in the “Type of Document” column and described

as “adverse impact analysis.”

More specifically, and based on Judge Lungstrum’s prior ruling as set forth in the preceding

section, the Court finds Defendant has included sufficient information in the privilege log for these

documents from which the Court could find that such documents were prepared under the supervision

of an attorney in preparation for litigation.

Eliminating these documents from the dispute, the Court finds only the following seven (7) Category 4 privilege log documents remain for determination regarding protection by the work product doctrine:

27

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 28 of 32

154097-154098 154099-154100 154101-154110 181746 181747 181748 181749

Spreadsheet Spreadsheet Spreadsheet RIF list RIF list RIF list RIF list

unknown unknown NA Demographics spreadsheet

WP

unknown unknown NA Demographics spreadsheet

WP

unknown unknown NA Networks services demographics attachment WP

unknown unknown NA riffed list by gender

WP

unknown unknown NA riffed list by ethnicity

WP

unknown unknown NA riffed list by age

WP

unknown unknown NA riffed list by age

WP

The Court finds nothing in the descriptions to persuade it that these written materials were created, collected or considered in any context other than the normal course of business. Although the information within these documents may have been used by Defendant in ultimately analyzing adverse impact, the documents are described as “lists” and “demographic spreadsheets” – descriptions that the Court finds are consistent with underlying factual information. Accordingly, the Court finds Defendant has failed to bear its burden to establish that these seven (7) documents were prepared under the supervision of an attorney in preparation for litigation.
6. Work Product: Category Five Documents Defendant argues the Category Five privilege log documents for which it claims work product protection listed below are documents that have been, or will be, produced with or without redactions.

44366-44367 Ethics Help line 3/25/02 Report

unknown NA

54487-54492 spreadsheet

unknown HR

NA

54493-54498 spreadsheet

unknown HR

NA

54500-54503 spreadsheet

unknown HR

NA

54505-54508 spreadsheet

unknown HR

NA

54509-54518 spreadsheet

unknown HR

NA

55123-55128 spreadsheet

9/18/02 HR

NA

ethics help line report re management practices/property rights of others CS over 40 ‘L’ rated employees CS over 40 M H V for consideration Min with H rating link ratings - 71-76 pc h minorities link ratings RIF data

AC, WP
WP WP WP WP WP WP

28

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 29 of 32

55259-55282 spreadsheet 55283-55284 spreadsheet

unknown unknown NA MMO sales and service matrix

WP

7/10/02 HR

NA supervisor development matrix - final version W P

In response, Plaintiffs maintain that many of these documents are not protected by the work
product doctrine and should be produced in their entirety without redaction. Upon review of the
descriptions provided, the Court finds all of these documents must be produced without redaction, as
the descriptions provided for these documents fail to establish that such documents were prepared under
the supervision of an attorney in preparation for litigation.
Conclusion
Pursuant to the discussion above, Plaintiffs’ Motion to Compel (doc. 3203) is granted in part
and denied in part as specifically set forth below:
(1) Category One
(a) The Court finds documents bearing bate stamps 30985-30986 and 163678-163679 are protected from disclosure by the attorney-client privilege;
(b) The Court finds all other documents within Category One for which a claim of attorney-client privilege was made are not protected from disclosure by such privilege and thus shall be produced within five (5) days from the date of this Memorandum and Order; and
(c) The Court finds all documents within Category One for which a claim of work product protection was made are not protected from disclosure under the doctrine and, unless alternatively protected by the attorney-client privilege, must be produced within five (5) days from the date of this Memorandum and Order.

29

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 30 of 32
(2) Category Two
(a) The Court finds documents bearing bate stamps 7618-7619, 44511-55512 [sic]46, 20513-20516, 20517-20541, 26010-26011, 35300-35302 are protected from disclosure by the attorney-client privilege;
(b) The Court finds all other documents within Category Two for which a claim of attorney-client privilege was made are not protected from disclosure by such privilege and thus shall be produced within five (5) days from the date of this Memorandum and Order; and
(c) The Court finds all documents within Category Two for which a claim of work product protection was made are not protected from disclosure under the doctrine and , unless alternatively protected by the attorney-client privilege, must be produced within five (5) days from the date of this Memorandum and Order.
(3) Category Three
(a) The Court finds handwritten portion of those documents bearing bates stamps 22230-22245 and 46294-46298 are protected from disclosure by the attorneyclient privilege;
(b) The Court finds the non-handwritten portion of those documents bearing bates stamps 22230-22245 and 46294-46298 are not protected from disclosure by the attorney-client privilege and thus shall be produced within five (5) days from the date of this Memorandum and Order; and
(c) The Court finds all other documents within Category Three for which a claim of attorney-client privilege was made are not protected from disclosure by such privilege and , unless alternatively protected by the attorney-client privilege, must be produced within five (5) days from the date of this Memorandum and Order;
46This document is erroneously listed as 44511-55512, when the privilege log actually identifies the document as 44511-44512.
30

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 31 of 32
(4) Category Four
(a) Documents identified in the “Type of Document” column as “impact ratio analysis” documents, “adverse impact analysis” documents and “adverse impact” documents are protected from disclosure by the attorney-client privilege and the work product doctrine;
(b) Documents identified as “spreadsheets” in the “Type of Document” column and described as “adverse impact,” “impact ratio analysis” and “due diligence matrix” are protected from disclosure by the attorney-client privilege and the work product doctrine;
(c) Documents identified as “emails” in the “Type of Document” column and described as documents including and/or attaching for transmittal adverse impact information, impact ratio analysis and legal advice re IT directors are protected from disclosure by the attorney-client privilege and the work product doctrine;
(d) Documents identified as “Job Aid” in the “Type of Document” column and described as “adverse impact analysis” are protected from disclosure by the work product doctrine;
(e) Documents bearing bates stamps 54563-74, 54627-28, 54629, 54630, 54769, 54874, 57214, 57215, 57236-48, 57305-26, 57327-28, 57329, 57330, 57383-84, 57429-71, 57136-47, 57212-13, 57168-89,153456-58, 153915-17, 153918-19, 153955-4001, 154084-95, 163528-31, 163667-68 are not protected from disclosure by the attorney-client privilege and thus shall be produced within five (5) days from the date of this Memorandum and Order;
(f) Documents bearing bates stamps 54563-54574, 57214, 57305-57326, 57212-57213, 153456-153458, 153915-153917, 154084-154095, 163528-163531, 154097-154098, 154099-154100, 154101-154110, 181746, 181747, 181748, 181749 are not protected from disclosure by the work product doctrine and , unless alternatively protected by the attorney-client privilege, must be produced within five (5) days from the date of this Memorandum and Order.
31

Case 2:03-cv-02200-JWL-DJW Document 3549 Filed 02/01/06 Page 32 of 32

(5) Category Five
(a) The Court shall permit Defendant to produce redacted versions of documents bearing bates stamp numbers 20456-60 and 22228-29 with regard to adverse impact analyses and advice regarding WARN; and
(b) The Court finds the remainder must be produced without redaction and Defendant shall do so within five (5) days from the date of this Memorandum and Order.
IT IS SO ORDERED.
Dated in Kansas City, Kansas on this 1st day of February, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

32

 
 Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF), that defendant engaged in a pattern and practice of age discrimination in implementing the RIF and that defendant’s forced-ranking performance review system had a disparate impact on older workers. This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiff’s pattern and practice allegations. This matter is now before the court on defendant’s motion to dismiss opt-in plaintiff Davis Shikles (doc. 3511). For the reasons explained below, the motion is granted.

Background The facts pertinent to defendant’s motion to dismiss are not disputed. Davis Shikles began
working in defendant’s billing department in 1997, when he was fifty-six years old. See Shikles

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 2 of 7
v. Sprint/United Management Co., 426 F.3d 1304, 1306 (10th Cir. 2005). In March 2002, defendant terminated Mr. Shikles’ employment as part of a reduction in force. Id. In May 2002, Mr. Shikles filed a charge with the EEOC alleging that his termination constituted unlawful age discrimination and in October 2002, he filed suit against defendant in this district asserting claims under the Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq. Id. at 1306-07. The case was assigned to Judge Vratil. Defendant moved for summary judgment, asserting that Mr. Shikles’ “failure to cooperate in the EEOC’s investigation of his charge constituted a failure to exhaust administrative remedies that deprived the district court of subject matter jurisdiction.” Id. at 1307. Judge Vratil granted defendant’s motion, concluding that the court lacked subject matter jurisdiction over Mr. Shikles’ claims as he had not cooperated with the EEOC and, thus, had not exhausted his administrative remedies. Id. On appeal, the Tenth Circuit agreed with Judge Vratil that Mr. Shikles failed to exhaust his administrative remedies because he failed to cooperate in the EEOC’s investigation of his charge. See id. at 1317. The Circuit, however, vacated the grant of summary judgment and directed the district court to dismiss Mr. Shikles’ claims for lack of subject matter jurisdiction. See id. at 1318.
While his appeal with the Tenth Circuit was pending, Mr. Shikles filed his consent to join this collective action as an opt-in plaintiff. It is undisputed that this action and Mr. Shikles’ prior action allege the same claim and arise from the same set of facts. Defendant now moves to dismiss Mr. Shikles as an opt-in plaintiff in this case.
Discussion 2

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 3 of 7
In support of its motion to dismiss, defendant contends that the court lacks subject matter
jurisdiction over plaintiff’s claims and that plaintiff is barred from relitigating the issue of jurisdiction and exhaustion of remedies.1 Defendant is correct that issue preclusion prevents Mr.
Shikles from relitigating the question of subject matter jurisdiction as that issue has been fully
litigated and decided. See Cory v. Fahlstrom, 2005 WL 1526135 (10th Cir. June 29, 2005)
(“Issue preclusion prevents a party from relitigating a jurisdictional question when the party had
a full and fair opportunity to litigate the matter in the prior case and the party is reasserting an
identical jurisdictional claim.”); see also Steele v. Federal Bureau of Prisons, 355 F.3d 1204,
1215 (10th Cir. 2003) (“[A] dismissal without prejudice for, say, lack of subject-matter
jurisdiction, would still preclude relitigation of the issue of subject-matter jurisdiction in the
absence of newly arising facts or law.”) (J. Hartz, concurring).
Mr. Shikles, however, does not seek to relitigate the issue of whether he exhausted his
administrative remedies. According to Mr. Shikles, he must be allowed to proceed as an opt-in
plaintiff in this case–regardless of his failure to exhaust–pursuant to the “single-filing rule” or the
1Defendant also asserts that dismissal is mandated based on res judicata principles. This argument is readily rejected as it is well settled that a dismissal for lack of subject matter jurisdiction is not an adjudication on the merits for purposes of res judicata. See, e.g., Cory v. Fahlstrom, 2005 WL 1526135 (10th Cir. June 29, 2005) (dismissal on res judicata grounds was improper where prior suit did not end with a judgment on the merits; instead, court dismissed prior suit for lack of subject matter jurisdiction); Hollander v. Sandoz Pharmaceuticals Corp., 289 F.3d 1193, 1216-17 (10th Cir. 2002) (court’s jurisdictional ruling did not address the merits of the plaintiffs’ claims); accord Davila v. Delta Air Lines, Inc., 326 F.3d 1183, 1188 (11th Cir. 2003) (a dismissal for lack of subject matter jurisdiction “plainly is not an adjudication on the merits that would give rise to a viable res judicata defense.”); St. Pierre v. Dyer, 208 F.3d 394, 400 (2d Cir. 2000) (a dismissal for lack of subject matter jurisdiction is not an adjudication of the merits and has no res judicata effect).
3

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 4 of 7
“piggybacking rule” as reaffirmed by the Tenth Circuit in Foster v. Ruhrpumpen, 365 F.3d 1191
(10th Cir. 2004). In Foster, the Circuit described the “piggybacking” or single filing” exception
to the EEOC individual filing requirement as follows:
Generally speaking, each plaintiff must exhaust his or her administrative remedies by filing a timely EEOC charge prior to bringing suit. However, given the widespread concern over discriminatory employment practices and the congressional intent behind Title VII and the ADEA, the federal courts have universally recognized an exception to the individual filing rule which provides that “in a multiple-plaintiff, non-class action suit, if one plaintiff has filed a timely EEOC complaint as to that plaintiff’s individual claim, then co-plaintiffs with individual claims arising out of similar discriminatory treatment in the same time frame need not have satisfied the filing requirement.” This exception to the individual filing requirement is known alternatively as the “single filing rule” or “piggybacking.”
Id. at 1197 (citations and quotation omitted). Ultimately, in Foster, the Circuit applied the single-
filing doctrine to permit four plaintiffs who had not filed charges of discrimination to “piggyback”
their claims on to the filings made by other plaintiffs and held that the district court erred in
dismissing their claims. See id. at 1198-99. Mr. Shikles asserts that he “is in no different
position” than the plaintiffs in Foster who “failed to exhaust their administrative remedies.”
As defendant highlights, however, Mr. Shikles is in a markedly different position than the
plaintiffs in Foster. Of course, in Foster, the plaintiffs who were permitted to piggyback had not
filed charges of discrimination. Mr. Shikles has filed his own charge of discrimination and this
distinction is fatal to Mr. Shikles’ attempt to piggyback on the filings of other plaintiffs in this
action. As the Circuit has clarified in other cases, the single-filing rule “allows a plaintiff, who
did not file an EEOC charge, to piggyback on the EEOC complaint filed by another person who
is similarly situated.” Thiessen v. General Elec. Cap. Corp., 267 F.3d 1095, 1110 (10th Cir.
4

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 5 of 7
2001) (citations omitted) (emphasis added). In O’Neal v. Thompson, 2002 WL 31862689 (10th Cir. Dec. 23, 2002), the Tenth Circuit, albeit in an unpublished decision, expressly declined to extend the single-filing rule to permit a plaintiff who had filed an individual charge to predicate her claim on the administrative complaint of another plaintiff. In that case, one plaintiff, Beverly Wilkins, filed an administrative complaint but did not pursue her claims in federal court until long after the 90-day period triggered by the right-to-sue notice that she had received. See id. The district court dismissed her claims for failure to exhaust administrative remedies. See id. On appeal, Ms. Wilkins argued that she should have been permitted to rely on the administrative charge of one of her co-plaintiffs. See id. The Tenth Circuit rejected this argument, stating that “a plaintiff who filed an individual charge may not invoke the single-filing rule,” and held that the district court properly dismissed Ms. Wilkins’ claims. See id. In doing so, the Circuit cited to other federal courts of appeals that had similarly concluded that a plaintiff who filed an individual charge of discrimination “should be required to rely upon his or her own . . . charge and cannot reasonably rely upon [an]other claimant’s charge.” See id. (quoting Gitlitz v. Compagnie Nationale Air France, 129 F.3d 554, 558 (11th Cir. 1997) and citing Anderson v. Unisys Corp., 47 F.3d 302, 309 (8th Cir. 1995)).
Based on the Circuit’s opinion in O’Neal, as well as the opinions of other courts addressing this issue, the court concludes that Mr. Shikles’ decision to file his own administrative charge precludes him from now relying on the administrative charges of other plaintiffs in this collective action. See Mooney v. Aramco Servs. Co., 54 F.3d 1207, 1223-24 (5th Cir. 1995) (where the party wishing to piggyback has filed his own EEOC charge, he is bound by the parameters of his
5

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 6 of 7
own charge and cannot subsequently utilize the single-filing rule); Flemming v. United Parcel Serv., 2004 WL 2314962, at *2 (N.D. Ill. Oct. 12, 2004) (predicting that the Seventh Circuit, if faced with the issue, would prohibit a claimant who had filed an administrative charge from piggybacking onto the claims of similarly situated claimants); Smith v. HealthSouth Rehabilitation Center of Memphis, Ltd., 234 F. Supp. 2d 812, 816 (W.D. Tenn. 2002) (predicting that the Sixth Circuit, if faced with the issue, would prohibit a plaintiff who had filed his or her own charge from benefitting from the single-filing rule).2 For the foregoing reasons, defendant’s motion to dismiss opt-in plaintiff Davis Shikles is granted.
IT IS THEREFORE ORDERED BY THE COURT THAT defendant’s motion to dismiss opt-in plaintiff Davis Shikles (doc. 3511) is granted.
IT IS SO ORDERED.
Dated this 3rd day of February, 2006, at Kansas City, Kansas.
2While the court recognizes that the majority of these cases, including the cases cited by the Tenth Circuit in O’Neal, stem from the plaintiff’s failure to file a lawsuit within 90 days of receiving a notice of right-to-sue on his or her own charge, the fact remains that those plaintiffs, like Mr. Shikles, failed to exhaust their administrative remedies by failing to diligently pursue their own charges. Thus, the court sees no reason why the principle espoused in those cases–that a plaintiff who has filed his own charge cannot benefit from the singlefiling rule–would not apply to the facts presented here.
6

Case 2:03-cv-02200-JWL-DJW Document 3555 Filed 02/03/06 Page 7 of 7 s/ John W. Lungstrum John W. Lungstrum United States District Judge
7

 
 Case 2:03-cv-02200-JWL-DJW Document 3749 Filed 03/21/06 Page 1 of 22

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al., Plaintiffs,
v. SPRINT/UNITED MANAGEMENT COMPANY,
Defendant.

CIVIL ACTION No. 03-2200-JWL-DJW

MEMORANDUM AND ORDER Plaintiff ShirleyWilliams filedthis suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Defendant’s Motion to Compel (doc. 3353), which seeks to compel Plaintiffs to provide responsive answers to its Fourth Set of Interrogatories and produce responsive documents to its Fourth Request for Production of Documents. For the reasons set forth below, the motion is granted in part and denied in part. I. Relevant Background

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Relevant to this motion, Defendant served its Fourth Request for Production of Documents Directed to Plaintiffs and Fourth Set of Interrogatories on June 30, 2005.1 After obtaining two extensions of time, Plaintiffs served their Responses and Objections to Defendant’s Fourth Request for Production of Documents Directed to Plaintiffs and Fourth Set of Interrogatories Directed to Plaintiffs on September 23, 2005.2 After attempting to confer with Plaintiffs to resolve the issue without court action, as required by Fed. R. Civ. P. 37(a)(2)(A) and D. Kan. Rule 37.2, Defendant filed the instant Motion to Compel with regard to Interrogatory Nos. 1 - 11, 13 - 35, and Request for Production Nos. 28 - 31. II. Discovery Requests at Issue
A. Fourth Interrogatory No. 1 Defendant’s Fourth Interrogatory No. 1 asks Plaintiffs: Do you contend that Sprint maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. If your answer to this interrogatory is in the affirmative, identify every company-wide policy, practice, or procedure that You believe Defendant used to engage in a pattern and practice of age discriminationbetweenOctober 1, 2001 and March 31, 2003. Plaintiffs assert several objections to the interrogatory. First, they object to the interrogatory on the grounds that it is and unduly burdensome in that it calls for the itemization of evidence and trial strategy which goes beyond the scope of reasonable discovery. Plaintiffs further object to the interrogatory to the extent that it would require them to disclose the opinions and conclusions of trial experts before the deadline established for such disclosures. They further object to the interrogatory to the extent that it assumes a
1See Cert. of Service (doc. 2976). 2See Cert. of Service (doc. 3299).
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burden of proof standard that does not apply, namely that Plaintiffs are required to prove “one or more
company-wide policies, practices, and procedures to engage in a pattern and practice of age
discrimination.” After asserting these objections, Plaintiffs answered Interrogatory No. 1 as follows:
Without waiving these objections, Plaintiff states that she has identified, through both investigation and through ongoing discovery, several repeated, routine, and/or generalized policies, practices, and procedures which could lead the finder of fact in this case to conclude that Sprint engaged in a pattern and/or practice of age discriminatory decisionmaking and subjective, pretextual decision-making in connection with reductions in force which occurred between October 31, 2001 and March 31, 2003. These repeated, routine, and /or generalized policies, practices, and procedures include (but are not necessarily limited to) the following:
Yes. Sprint engaged in a pattern and practice of age discrimination in connection with the RIF for this time period, including the setting up a “sham” process for displaced workers for “reapply” for open positions within Sprint, resulting in situations where applicants 40 years of age and older were not given the same consideration as younger employees and where applicants over 40 years of age were denied even the opportunity to interview for such open positions. Sprint also engaged in a pattern and practice of age discrimination in hiring new employees into positions for which recently RIF’d employees were fully qualified.
Also in connection with the RIF, Sprint engaged in a pattern or practice of age discrimination and otherwise treated younger employees more favorably than older employees, including (but not limited to) the following specific actions:
Plaintiffs’ response thereafter continues with four pages of single-spaced text identifying Defendant’s
specific actions.
In its motion to compel, Defendant requests an order compelling Plaintiffs to provide a full,
complete, and non-evasive answer to this interrogatory. Defendant claims that Plaintiffs’ response is
evasive because it identifies “repeated, routine, and/or generalized policies, practices, and procedures”
rather than responding to what the interrogatory specifically sought, i.e., identification of every “company-
wide policy, practice, or procedure.” Defendant further claims that Plaintiffs fail to identify “every” policy,
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practice, or procedure as sought by the interrogatorybecause they state in their interrogatoryresponse that their listing of Defendant’s alleged practices was “not necessarily limited” to the practices they disclosed. Lastly, Defendant points out that Plaintiffs’ response fails to state whether the “repeated, routine, and/or generalized policies, practices, and procedures” identified in the response were company-wide.
Plaintiffs’ main objection to this interrogatory, as well as all the interrogatories with references to Defendant’s “company-wide policies, practices, or procedures,” is that this language implies a burden of proof standard for Plaintiffs that does not apply at this phase of the litigation. They argue that wording of the question assumes Plaintiffs are required to prove “one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination.” Plaintiffs maintain that at the pattern and practice phase, they are only required to prove a denial of rights that consists of “something more than an isolated, sporadic incident, but [which] is repeated, routine, or of a generalized nature” as set forth by International Brotherhood of Teamsters v. United States.3 Based on this objection, after answering “yes” to the question “[d]o you contend that Sprint maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2002,” Plaintiffs qualified their response with their listing of Defendant’s alleged “repeated, routine, and/or generalized policies, practices, and procedures.” Plaintiffs argue that they have adequately responded to the interrogatory by stating their objection to the interrogatory, along with legal citations to the pattern and practice standards they believe are applicable, and by providing the principal and material facts supporting the allegations that Defendant engaged in a pattern and practice of age
3431 U.S. 324, 336 (1977). 4

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discriminationin connectionwitha RIF that took place over a twenty-one monthtime period between 2001 and 2003.
Other than Plaintiffs’ inclusion of the phrase “not limited to,” which will be discussed below, the Court finds that Plaintiffs’ answer to Interrogatory No. 1 is sufficiently responsive. Plaintiffs clearly answer the first part of the interrogation with “Yes.” With regard to the second part of the interrogatory that asks Plaintiffs to identify every “company-wide policy, practice, or procedure” that they believe Defendant used to engage in a pattern and practice ofage discrimination, Plaintiffs’listing of Defendant’s “repeated, routine, and/or generalized policies, practices and procedures” in its response rather than listing the “company-wide policies, practices, or procedures,” the language set forth in the interrogatory, does not make the answer non-responsive. Plaintiffs set out their objection that Defendant’s contention interrogatory presumes a burden that they contend they are not required to prove at the pattern and practice stage. Plaintiffs are not required to phrase their response with the exact language of the interrogatory for their answer to be considered responsive if they have indicated their objection to the language used by the contention interrogatory itself. Fed. R. Civ. P. 33(b)(1) contemplates the possibility of qualification by directing parties to answer interrogatories to the extent they are not objectionable. “Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the objecting party shall state the reasons for objection and shall answer to the extent the interrogatory is not objectionable.”4
Plaintiffs urge the Court to take a meaningful look at the substantive law regarding Plaintiffs’ burden of proof at the pattern and practice stage of this litigation in order to rule on this motion. Plaintiffs contend that their burden of proof at the pattern and practice phase governs what is and is not discoverable. The
4Fed. R. Civ. P. 33(b)(1). 5

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Court disagrees. In complex litigation, courts often phase discovery to assist with managing the large volume of discovery to be produced. This Court phased discovery in this case into two-parts: (1) discovery relating to pattern and practice, and (2) discovery relating to individual issues or “individualized discovery.” The Court finds that Defendant’s interrogatory is relevant to Plaintiffs’ pattern and practice allegations. Defendant is entitled to ask whether Plaintiffs are contending that it maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003, and to seek discovery that Plaintiffs may use to support that contention. It is entitled to ask this regardless of what the Court may ultimately determine to be Plaintiffs’ burden of proof.
Defendant further claims that Plaintiffs’ interrogatory response improperly prefaces their listing of Defendant’s alleged “repeated, routine, and/or generalized policies, practices and procedures” with the phrase “not limited to.” At least two cases have found interrogatories with similar language to be improper and constituted an insufficient answer.5 In this case, whether Plaintiffs’ response is sufficient depends on Plaintiffs’ intended meaning of the phrase. If Plaintiffs are using the phrase “not limited to” to indicate that theyare withholding disclosure of other known policies, practices, and procedures, thenPlaintiffs’response would be insufficient. On the other hand, if Plaintiffs are using the phase “not limited to” to indicate that there may be other policies, practices, and procedures of which they do not yet have knowledge and may be revealed through further discovery, then Plaintiffs’ response would be sufficient, subject to their
5See Pulsecard, Inc. v. Discover Card Servs., Inc., No. CIV. A. 94-2304-EEO,1996 WL 397567, at *7-8 (D. Kan. July 11, 1996) (prefacing interrogatory answer with the phrase “including but not limited to”); Audiotext Commc’ns Network, Inc. v. US Telecom, Civ.A. No. 94-2395-GTV, 1995 WL 625953, at *6 (D. Kan. Oct. 5, 1995) (conditioning a list of specific documents with the phrase “including not but limited to”).
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continuing duty to supplement under Fed. R. Civ. P. 26(e). Because the Court is unable to determine Plaintiffs’ intent in using the phrase “not limited to,” the Court will therefore grant Defendant’s Motion to Compel as to Interrogatory No. 1 in part and require Plaintiffs to serve a supplemental response to Interrogatory No. 1. The supplemental response shall either refrain from prefacing any listing of policies, practices, and procedures with the phrase “not limited to,” or explain its usage. Plaintiffs shall serve their supplemental response to Interrogatory No. 1 within thirty (30) days of the date of this Memorandum and Order.
B. Fourth Interrogatory No. 2 Defendant’s Fourth Interrogatory No. 2 asks Plaintiffs: For each policy, practice, or procedure identified in response to Interrogatory 1 above, identify the name of each individual who has filed a Consent to Join in this matter, and any individual who has sought to consolidate his or her case with this matter, who was terminated during a reduction in force as a direct result of the application of such policy, practice or procedure. Plaintiffs object on the grounds that the interrogatory calls for the itemization of evidence and trial strategy which goes beyond the scope of reasonable discovery, and that it assumes a burden of proof standard that does not apply, namely that they are required to prove “one or more company-wide policies, practices, and procedures to engage in a pattern and practice of age discrimination.” Plaintiffs further object to Interrogatory No. 2 as not relevant to phase one of a pattern and practice case. After asserting these objections, Plaintiffs state that all of the opt-in plaintiffs were subjected to some or all of the “repeated, routine, and/or generalized policies, practices and procedures.” Plaintiffs contend they are not required in this phase to establish any causal connection between a particular pattern or practice and all of the individual plaintiffs who were allegedly affected by such pattern
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or practice. They contend that under a pattern and practice theory they have no obligation to prove that all, or even a majority of, individuals in the protected category were subject to illegal discrimination.
The Court finds that Defendant’s interrogatory is relevant to the pattern and practice phase of this case. Defendant may properly ask Plaintiffs to identify individuals who were terminated during a RIF as a direct result of the application of the “repeated, routine, and/or generalized policies, practices and procedures” set forth in their response to Interrogatory No. 1. It is entitled to ask this regardless of what the Court may ultimately determine to be Plaintiffs’ burden of proof.
The Court finds that Plaintiffs’ response that “all of the opt-in plaintiffs were subjected to some or all of the ‘repeated, routine, and/or generalized policies, practices and procedures’” fails to adequately answer Interrogatory No. 2. For Plaintiffs’ answer to be responsive to Interrogatory No. 2, it must state that all of the opt-in plaintiffs were subjected to all of the identified “repeated, routine, and/or generalized policies, practices and procedures,” or identify which policies, practices, or procedures were applied to each opt-in plaintiff. Defendant’s Motion to Compel Interrogatory No. 2 is therefore granted. Plaintiffs shall serve their supplemental response to Interrogatory No. 2 within thirty (30) days of the date of this Memorandum and Order.
C. Fourth Interrogatory No. 3 Defendant’s Fourth Interrogatory No. 3 asks Plaintiffs: For each policy, practice or procedure identified inresponse to Interrogatory1 above, state whether such policy, practice, or procedure was applied to all persons employed by Sprint who were 40 years of age or older at the time it was applied, and if not applied to all such persons, state the identity by job classification, business unit, geographic location or other identifier each employment unit of Sprint or other such other group(s) of persons who were 40 years of age or older that was/were directly affected by the application of such policy, practice, or procedure.
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Plaintiffs again assert objections that the interrogatory is overly broad and unduly burdensome, assumes a burden of proof standard that does not apply, and seeks information not relevant to phase one of a pattern and practice case. After asserting these objections, Plaintiffs incorporate the answers to InterrogatoryNos. 1 and 2 and refer Defendant to the pleadings filed in this case, the documentsproduced, the opt-in questionnaires, depositions of opt-in plaintiffs, and declarations of more than 100 opt-in plaintiffs. The response further states that the matters inquired into are more fully addressed in the Statement of Facts submitted with Plaintiffs’ Motion for Conditional Certification. Plaintiffs further state that discovery is ongoing and they will supplement this response as appropriate.
Plaintiffs may not answer the interrogatory by generally referring Defendant to the pleadings filed in this case, documents produced, opt-in questionnaires, depositions, or declarations. Absent compliance with Rule 33(d) or attachment of the appropriate documents, a responding party may not answer an interrogatoryby directing the party propoundingthe interrogatoryto find answers frompreviouslyproduced documents or identified witness lists.6 Plaintiffs are not permitted to answer interrogatories by generically referring to the pleadings filed in this case (which currently number in excess of 3700), the documents produced, the opt-in questionnaires, opt-in deposition testimony, opt-in declarations, or other broad classes of documents with no articulation of where this information may be found. Plaintiffs must indicate with specificity where the information can be found.
Defendant’s Motion to Compel Interrogatory No. 3 is granted. Plaintiffs shall provide a supplemental response to Interrogatory No. 3 that answers the interrogatory. Plaintiffs may not answer
6DIRECTV, Inc. v. Puccinelli, 224 F.R.D. 677, 680 (D. Kan. 2004) (citing Zapata v. IBP, Inc., No. Civ. A. 93-2366-EEO, 1997 WL 50474, at *1 (D. Kan. Feb. 4, 1997)).
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the interrogatory by generally referring Defendant to the pleadings filed in this case, documents produced, opt-in questionnaires, depositions, declarations, or other general broad classes of documents, but rather must indicate with specificity where the information can be found. Plaintiffs shall serve their supplemental response to Interrogatory No. 3 within thirty (30) days of the date of this Memorandum and Order.
D. Fourth Interrogatory No. 4 Defendant’s Fourth Interrogatory No. 4 asks Plaintiffs: For each and every company-wide policy, practice or procedure You identified in responding to Interrogatory No. 1, state every fact of which You are aware that supports Your contention that Sprint maintained one or more company policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Plaintiffs assert objections that the interrogatory is overly broad and unduly burdensome because it requests that they state all facts supporting a particular contention. Plaintiffs further object to the interrogatoryon the grounds that it calls for the itemizationof evidence and trialstrategywhichgoes beyond the scope of reasonable discovery, assumes a burden of proof standard that does not apply, and seeks information not relevant to phase one of a pattern and practice case. After asserting these objections, Plaintiffs incorporates her answer to Interrogatory Nos. 1 through 3 and refers Defendant to the pleadings filed in this case, the documents produced, the opt-in questionnaires, depositions of opt-in plaintiffs, and declarations of more than 100 opt-in plaintiffs. The Court finds that this interrogatory is overly broad to the extent it asks for “every fact” that supports an identified allegations or claim. As a general rule in this District, the court will find interrogatories overly broad and unduly burdensome to the extent that they ask for “every fact” which supports identified
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allegations or defenses.7 Interrogatories should not require the answering party to provide a narrative account of its case.8 Interrogatories may, however, properly ask for the “principal or material” facts that support an allegation or defense.9 Interrogatories which do not encompass every allegation, or a significant number of allegations, of the Complaint, reasonably place upon the answering party “the duty to answer them by setting forth the material or principal facts.”10 In addition, interrogatories “which seek underlying facts or the identities of knowledgeable persons and supporting exhibits for material allegations” may possibly survive objections that they are overly broad or unduly burdensome.11
Interrogatory No. 4 requests that Plaintiffs state every fact of which they are aware that supports their contention that Defendant maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. This constitutes an example of the type of interrogatory which has been held to be objectionable. It is overbroad and unduly burdensome on its face to the extent it seeks “all facts” that support Plaintiffs’ contention that Defendant maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Plaintiffs’ overly broad and unduly burdensome objection to this interrogatory is sustained. Plaintiffs, nevertheless,
7Hiskettev. Wal-Mart Stores, Inc., 180 F.R.D. 403, 405 (D. Kan. 1998); Hilt v. SFC Inc., 170 F.R.D. 182, 186 (D. Kan.1997); IBP, Inc. v. Mercantile Bank, 179 F.R.D. 316, 321 (D. Kan.1998); Lawrence v. First Kan. Bank & Trust, 169 F.R.D. 657, 661-2 (D. Kan. 1996).
8Hiskette, 180 F.R.D. at 404 (citing Hilt, 170 F.R.D. at 186; Lawrence, 169 F.R.D. at 662). 9Id. at 405 (citing Lawrence, 169 F.R.D. at 664; IBP, Inc., 179 F.R.D. at 320). 10Id. (citing IBP, Inc., 179 F.R.D. at 321-22). 11Id. (citing Hilt, 170 F.R.D. at 188).
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have a duty to answer the interrogatory to the extent it is not objectionable, i.e., by providing the principal or material facts that support their contention. Defendant’s Motion to Compel Interrogatory No. 4 is therefore granted in part and denied in part. Plaintiffs shall provide a supplemental response to Interrogatory No. 4 that provides the principalor materialfactsthat support their contentionthat Defendant maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. As stated previously, Plaintiffs’supplementalresponse maybe phrased interms of “repeated, routine, and/or generalized policies, practices and procedures” rather than “company-wide policies, practices, or procedures.” Plaintiffs shall serve their supplemental response to Interrogatory No. 4 within thirty (30) days of the date of this Memorandum and Order.
E. Fourth Interrogatory No. 5 Defendant’s Fourth Interrogatory No. 5 asks Plaintiffs: For each and every company-wide policy, practice or procedure You identified in responding to Interrogatory No. 1, identify by name, home address, business address and telephone number all persons with knowledge relating to Your contention that Sprint maintained one or more company policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Plaintiffs again assert objections that the interrogatory is overly broad and unduly burdensome in that it requests that Plaintiffs identify all persons with any knowledge relating to their contentions. Plaintiffs further object that it calls for the itemization of evidence and trial strategy which goes beyond the scope of reasonable discovery, assumes a burden of proof standard that does not apply, and seeks information not relevant to phase one of a pattern and practice case. After asserting these objections, Plaintiffs incorporates their answer to Interrogatory Nos. 1 and 5 and refer Defendant to the pleadings filed in this
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case, the documents produced, the opt-in questionnaires, depositions of opt-in plaintiffs, and declarations of more than 100 opt-in plaintiffs.
On its face, this interrogatory appears to seek the type of information that Plaintiffs already provided in their initial and voluntary disclosures pursuant to Rule 26(a)(1). The court has held that interrogatories should not duplicate the initialdisclosures required by Rule 26(a)(1).12 Upon closer review of Plaintiffs’ Fifth Supplemental Voluntary Disclosures Pursuant (doc. 3467-3), however, the Court notes that Plaintiffs’ listing of the persons who are likely to have information relevant to the facts alleged in the First Amended Complaint does not indicate whether the person listed would have any knowledge relating the specific contention that Defendant maintained one or more company policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Defendant’s Motion to Compel Interrogatory No. 5 is thereforegrantedinpart and denied in part. Within thirty (30) days of the date of this Memorandum and Order, Plaintiffs shall provide a supplemental response to Interrogatory No. 5 that specifically identifies all persons, along with their contact information, with knowledge relating to their contention that Defendant maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003.
F. Fourth Interrogatory No. 6 Defendant’s Fourth Interrogatory No. 6 asks Plaintiffs: For each and every company-wide policy, practice or procedure You identified in responding to Interrogatory No. 1, identify with the reasonable particularity required by Rule 34, Fed. R. Civ. P. all documents you contend support Your contention that Sprint
12Hilt, 170 F.R.D. at 187-88; Lawrence, 169 F.R.D. at 662, 664. 13

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maintained one or more company policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Identification by Bates number of documents, including those produced by Sprint during the course of this litigation, will satisfy this interrogatory. Plaintiffs object to the interrogatory on the grounds that it is overly broad and unduly burdensome in that it requests all documents supporting an allegation. Plaintiffs further object that it calls for the itemization of evidence and trial strategy which goes beyond the scope of reasonable discovery, assumes a burden of proof standard that does not apply, and seeks information not relevant to phase one of a pattern and practice case. After asserting these objections, Plaintiffs state that discovery is ongoing and they are unable to identify all documents evidencing the “repeated, routine, and/or generalized policies, practices, and procedures.” Their response refers Defendant to the pleadings filed in this case, the documents produced, the opt-in questionnaires, depositions of opt-in plaintiffs, and declarations of more than 100 opt-in plaintiffs. In addition, Plaintiffs’ response refers Defendant to their original and supplemental voluntary disclosures under Rule 26(a)(1). On its face, this interrogatoryappears seeks the type of informationthat Plaintiffs already provided in their initial and voluntary disclosures pursuant to Rule 26(a)(1). As stated previously, interrogatories should not duplicate the initial disclosures required by Rule 26(a)(1).13 As noted by Judge Rushfelt in Lawrence v. First Kansas Bank & Trust Co., compliance with Fed. R. Civ. P. 26(a)(1)(A) and (B) for initial disclosures of identities of persons with discoverable information and documents relevant to disputed
13Hilt, 170 F.R.D. at 187-88; Lawrence, 169 F.R.D. at 662, 664. 14

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facts alleged in the pleadings, along with Rule 26(e) supplemental disclosures, should reduce the need for redundant interrogatories about the same subject matter.14
Plaintiffs have previously provided their listing of documents that may be relevant to their claims in their original and supplemental voluntary disclosures under Rule 26(a)(1). Plaintiffs’ original and supplemental disclosures, however, do not indicate whether the documents identified support the specific contention that Defendant maintained one or more company policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Defendant’s Motion to Compel Interrogatory No. 6 is therefore granted to the extent that Plaintiffs shall provide a supplemental response to Interrogatory No. 6 that identifies documents that support the contention that Defendant maintained one or more company-wide policies, practices, or procedures to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Plaintiffs may not answer the interrogatory by generally referring Defendant to the pleadings filed in this case, documents produced, opt-in questionnaires, depositions, or declarations. Plaintiffs may, however, answer the interrogatory with specific references to the documents listed in their original and supplemental Rule 26 disclosures. Plaintiffs shall serve their supplemental response to Interrogatory No. 6 within thirty (30) days of the date of this Memorandum and Order.
G. Fourth Interrogatory No. 7 Interrogatory No. 7 asks that, for each document identified in Interrogatory No. 6 that was not disclosed or produced by Defendant during this litigation, Plaintiffs identify the individual from whom such documents were received, whentheywere received, and whether received in hard copy or electronic form.
14Lawrence, 169 F.R.D. at 662. 15

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Plaintiffs’ objections and response to this interrogatory are virtually the same as asserted to Interrogatory No. 6 above. After asserting these objections, Plaintiffs state that they are not aware of any documents that are within their possession, custody, or control supporting their claims which have not been appropriately disclosed and produced. The response further states that documents produced by Plaintiffs have been Bates numbered with the name of the opt-in plaintiff or independent witness included.
The Court finds that Plaintiffs’ response - - - that they are not aware of any documents in their possession, custody, or control supporting their claims which have not been appropriately disclosed and produced - - - adequately answers this interrogatory. Defendant’s Motion to Compel Interrogatory No. 7 is therefore denied.
H. Fourth Interrogatory Nos. 8 - 11 Interrogatory Nos. 8 and 10 ask whether Plaintiffs contend that one or more of Defendant’s executives, officers, directors, board of directors, or members of management engaged in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Interrogatory Nos. 9 and 11 ask whether Plaintiffs contend that one or more of Defendant’s officers, directors, board members, or members of management directed any employee to engage in a pattern and practice of age discrimination. After inquiring into Plaintiffs’ contentions,the interrogatoriesthenrequest that Plaintiffs identify by name and job title each executive, officer, director, board member, or manager who engaged in or directed an employee to engage in a pattern and practice of age discrimination, along with the name and job title of each employee who was directed. Plaintiffs object to these interrogatories on the grounds that they are overly broad and unduly burdensome in that they request identification of all persons with any knowledge. Plaintiffs further object
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that the interrogatories call for the itemization of evidence and trial strategy which goes beyond the scope of reasonable discovery and assume a burden of proof standard that does not apply. After asserting these objections, Plaintiffs state that numerous officers and directors or managers of Sprint directed, endorsed or engaged in the repeated, routine, and/or generalized policies, practices and procedures identified in response to Interrogatory No. 1.
The Court finds Plaintiffs’ responses to these interrogatories - - - that numerous officers and directors or managers of Sprint directed, endorsed or engaged in the repeated, routine, and/or generalized policies, practices and procedures - - - are insufficient. If Plaintiffs have knowledge of a specific executive, officer, director, or member of management who engaged in or directed an employee to engage in a pattern and practice of age discrimination, then their interrogatory responses should include this information, along with the other information requested by the interrogatories. Defendant’s Motion to Compel Interrogatory Nos. 8- 11 is granted. Within thirty (30) days of the date of this Memorandum and Order, Plaintiffs shall serve their supplemental responses to Defendant’s Fourth Interrogatory Nos. 8 - 11, which identify by name and job title each executive, officer, director, board member, or manager who engaged in or directed an employee to engage in a pattern and practice of age discrimination, along with the name and job title of each employee who was directed.
I. Fourth Request for Production Nos. 28 - 31 Similar to Interrogatory Nos. 8-11, Defendant’s Fourth Request for Production Nos. 28 and 29 seek all documents Plaintiffs contend evidence that one or more of Defendant’s officers or executives, or members of management engagedina patternand practice of age discriminationbetween October 1, 2001 and March 31, 2003. Requests Nos. 30 and 31 seek all documents Plaintiffs contend evidence that
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Defendant’s officers or executives, or members of management directed any employee to engage in a pattern and practice of age discrimination between October 1, 2001 and March 31, 2003. Plaintiffs object to these requests on the grounds that: (1) they are overly broad and unduly burdensome, (2) they call for Plaintiffs to “itemize its evidence and trial strategy [which] goes beyond the scope of reasonable discovery,”(3) theyassume Plaintiffs are required to prove “one or more company-widepolicies,practices, or procedures to engage in a pattern and practice of age discrimination.”
Afterassertingthese objections, Plaintiffs state that they are notaware ofanydocumentsresponsive to these requests, that are within their possession, custody, or control, supporting their claims which have not been appropriately disclosed and produced. Documents produced by Plaintiffs have been Bates numbered with the name of the opt-in plaintiff or independent witness included.
The Court finds that Plaintiffs’s responses - - - that they are not aware of any documents in their possession, custody, or control supporting their claims which have not been appropriately disclosed and produced - - - adequately respond to these requests for production. Defendant’s Motion to Compel Request for Production Nos. 28 - 31 is therefore denied.
J. Fourth Interrogatory Nos. 13 - 34 Defendant’s Interrogatory No. 13 requests that Plaintiffs: Identify all documents You have from any source concerning Sprint’s “Corporate organization and structure” as referenced in paragraph 1, p. 7 of Plaintiff’s Fifth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1): June 20, 2005. Identification by Bates number of documents, including documents produced by Sprint during the course of this litigation will satisfy this interrogatory. Interrogatory Nos. 14 through 34 similarly ask Plaintiffs to identify, by Bates number, documents referenced in their Fifth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1), including
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documents produced by Defendant during the course ofthis litigation. Plaintiffs object to the interrogatories on the grounds that they are overly broad and unduly burdensome in that the interrogatories request “all documents.” They further object to identifying by Bates number documents produced by Defendant. Plaintiffs assert that they have adequately identified the requested documents. They claim they have no obligation under the discovery rules to identify, by Bates number or otherwise, documents produced by Defendant which they believe support their contentions.
Defendant states thatPlaintiffs’FifthSupplementalVoluntaryDisclosuresPursuant to Rule 26(a)(1) failed to specifically identify any of the documents about which it now inquires. It contends that it is entitled to know what specific documents Plaintiffs are referencing in their Rule 26(a)(1) disclosures.
The Court agrees with Defendant that it is entitled to know what specific documents Plaintiffs are referencing in their Fifth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1). Plaintiffs’ cite to Hiskette v. Wal-Mart15 for the proposition that interrogatories “should not duplicate disclosures” is unavailing. Defendant is not, like in the Hiskette case,16 asking Plaintiffs to identify documents that they may use to support their claims and allegations, which would duplicate the information required to be provided under Rule 26(a)(1)(B), but rather is requesting that Plaintiffs provide a more specific identification of those general categories of documents referenced in their Fifth Supplemental Disclosures. Plaintiffs’ overly broad and unduly burdensome objection to the interrogatories on the grounds that they
15180 F.R.D. at 405. 16In Hiskette, the interrogatory at issue asked plaintiff to “state all facts and identify each and every witness and document that supports [her] allegation” that she “was denied the position because of her sex and pregnancy in violation of Title VII of the Civil Rights Act of 1964 and the Kansas Act of Discrimination,” as set out in paragraph 26 of her Complaint. Id. at 404.
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request identification of “all documents” and objection that they duplicate initial disclosures are therefore overruled.
Interrogatory Nos. 13-34 further state that “[i]dentification by Bates number of documents, including documents produced by Sprint during the course of this litigation, will satisfy this interrogatory.” Plaintiffs vigorously object to the interrogatoryto the extent it requires themto identify documents produced by Defendant during the course of this litigation. They claim they have no obligation under the discovery rules to identify, by Bates number or otherwise, documents produced by Defendant which they believe support their contentions. The Court disagrees. Although presumably Defendant knows what documents it has previously produced during this litigation, it is entitled to know what specific documents Plaintiffs are referencing, even those produced by Defendant during the course of this litigation, in their supplemental disclosures.
Defendant’s Motion to Compel Plaintiffs to provide responsive answers to Fourth Interrogatory Nos. 13 through 34 is therefore granted. Within thirty (30) days of the date of this Memorandum and Order, Plaintiffs shall serve their supplemental responses to Defendant’s Fourth Interrogatory Nos. 13 through 34, which identify all documents, including those produced by Defendant in this litigation, referenced in their Fifth Supplemental Disclosures Pursuant to Rule 26(a)(1).
K. Fourth Interrogatory No. 35 Defendant’s Interrogatory No. 35 requests that Plaintiffs: Identify all documents You have from any source regarding “produced by defendant in the case called Jolinda Vega v. Sprint Corporation, No. 03-2589-KHV. These include, but are not limited to Documents Marked in Summary Judgment papers as Plaintiff’s Exhibits N, R, S, T, U, V, W, X” as referenced in paragraph 27, p. 9 of Plaintiff’s Fifth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1): June 20, 2005.
20

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Identification by Bates number of documents, including documents produced by Sprint during the course of this litigation will satisfy this interrogatory. Plaintiffs object to the interrogatories on the grounds that it is vague and confusing. Plaintiffs state that they simply do no understand what Defendant is seeking in this interrogatory and do not understand the phrase “regarding produced by defendant . . . .” Without waiving these objections, Plaintiffs state that all documents believed to be responsive to this interrogatory have been properly identified in Plaintiffs Disclosures. The Court finds this interrogatory requires Plaintiffs to identify documents that are already sufficiently identified in Plaintiffs’ Fifth Supplemental Disclosures. The Court will therefore deny Defendant’s Motion to Compel Interrogatory No. 35. IT IS THEREFORE ORDERED that Defendant’s Motion to Compel (doc. 3353) is granted in part and denied in part. Defendant’s Motion to Compel is granted as to Defendant’s Fourth Interrogatory Nos. 2, 3, 8-11, and 13-34, and granted in part and denied in part as to Fourth Interrogatory Nos. 1, 4 - 6. Defendant’s Motion to Compel is denied as to Fourth Interrogatory Nos. 7, 35, and Fourth Request for Production Nos. 28-31. Plaintiffs shall serve their supplemental responses within thirty (30) days of the date of this Memorandum and Order. IT IS FURTHER ORDERED the circumstances of this motion make an award of expenses unjust, and therefore each party is to bear their own expenses in relation to this motion. IT IS SO ORDERED. Dated in Kansas City, Kansas on this 21st day of March, 2006.
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cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

22

 
 Case 2:03-cv-02200-JWL-DJW Document 4211 Filed 06/30/06 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of plaintiffs’ pattern and practice allegations. This matter is presently before the court on plaintiffs’ motion to review and objections to paragraph 11 of the magistrate judge’s April 25, 2006 order (doc. 4100) in which the judge denied plaintiffs’ motions for protective order to prevent the taking of the depositions of those opt-in plaintiffs who had been removed from plaintiffs’ list of potential witnesses for the pattern and practice trial and those opt-in plaintiffs who had never been listed as witnesses for the pattern and practice trial. As set forth in more detail below, plaintiffs’ motion is denied as the magistrate judge did not abuse his discretion in denying plaintiffs’ motions for these protective orders.

Case 2:03-cv-02200-JWL-DJW Document 4211 Filed 06/30/06 Page 2 of 7
Background In early 2006, defendant began noticing the depositions of opt-in plaintiffs who were at one
time identified by plaintiffs in their Rule 26 disclosures as anticipated witnesses at the pattern and practice trial but have since been removed from that list by plaintiffs as well as several opt-in plaintiffs who had never been identified as anticipated witnesses at the pattern and practice trial. On March 28, 2006, plaintiffs filed a motion for protective order under Rule 26(c), seeking to preclude defendant from taking these depositions until after the pattern and practice phase of this litigation. According to plaintiffs, a protective order is appropriate because defendant has already deposed more than 300 opt-in plaintiffs1 and the opt-in plaintiffs who are the subject of the motions for protective order will not be “witnesses” at the pattern and practice trial. To the extent the magistrate judge permitted defendant to go forward with these depositions, plaintiffs requested that the depositions of those opt-in plaintiffs who reside outside the Kansas City area proceed by telephone. According to plaintiffs, these plaintiffs should not have to choose between the hardships of traveling to Kansas City and dismissing their claims.
On April 25, 2006, the magistrate judge denied plaintiffs’ motions for protective order and concluded that plaintiffs had not shown good cause” for those orders and that defendant “has a right to depose these opt-in Plaintiffs on pattern and practice issues.” While the judge also rejected
1To the court’s recollection, plaintiffs have never asked this court to review any rulings concerning the total number of opt-in plaintiffs defendant may appropriately depose in this phase of the litigation and plaintiffs do not suggest in their present motion to review that defendant has exceeded the number of depositions contemplated by the magistrate judge and the parties. Thus, the fact that defendant has deposed a significant number of opt-ins is not pertinent to the court’s resolution of this motion to review.
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plaintiffs’ general request that these depositions take place via telephone, he emphasized that he would consider exceptions to this ruling–and possibly permit specific plaintiffs to be deposed via telephone–based on a particularized showing of hardship by plaintiffs. Indeed, plaintiffs have since filed several motions for protective orders tied to the individual circumstances of particular plaintiffs.
Plaintiffs now object to the magistrate judge’s order, contending that defendants should not be permitted in this phase of the litigation to take the depositions of persons who are not listed as witnesses for the pattern and practice trial. In the alternative, plaintiffs request this court to require that the depositions of out-of-town plaintiffs take place via telephone.
Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district courts
review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a).
In the context of nondispositive discovery disputes, including the decision to grant or deny a protective order pursuant to Federal Rule of Civil Procedure 26(c), a district court will review the magistrate judge’s order for an abuse of discretion. See Microsoft v. MBC Enterprises, 2004 WL 3007078, at *8 (10th Cir. Dec. 29, 2004) (district court reviews magistrate judge’s discovery order for abuse of discretion; expressing “some concern whether the district court afforded the
3

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proper degree of deference to the magistrate judge’s discovery order”) (citing 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069 (2d ed. 1997) (noting that discovery disputes “might better be characterized as suitable for an abuse-of-discretion analysis”)); Cummings v. General Motors Corp., 365 F.3d 944, 954 (10th Cir. 2004) (“It is the unusual or exceptional case where the reviewing court will vacate a protective order entered by a trial court under Fed. R. Civ. P. 26(c).”); LaFleur v. Teen Help, 342 F.3d 1145, 1152-53 (10th Cir. 2003) (reviewing magistrate judge’s grant of discovery protective order for abuse of discretion).
Discussion As stated above, the magistrate judge found that plaintiffs had failed to establish good cause
for precluding the depositions of those opt-in plaintiffs who had been removed from plaintiffs’ list of potential witnesses for the pattern and practice trial and certain opt-in plaintiffs who had never been identified by plaintiffs as potential witnesses for the pattern and practice trial. Nothing in the objections filed by plaintiffs suggests that the magistrate judge abused his discretion in so deciding.
With respect to those opt-in plaintiffs who were initially identified by plaintiffs as having knowledge relevant to pattern and practice issues but were later removed from that list, plaintiffs do not contend that these opt-in plaintiffs, in fact, do not have information concerning pattern and practice issues and the record reveals that plaintiffs conceded before Judge Waxse that these plaintiffs have information pertinent to the pattern and practice claims. Rather, plaintiffs contend
4

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that these opt-in plaintiffs were removed from the list based on the cumulative nature of their testimony, scheduling difficulties and travel and expense problems. In such circumstances, defendant has the right to depose these individuals–individuals who are plaintiffs in this action and are seeking damages from defendant–regarding pattern and practice issues. See Ashby v. McKenna, 331 F.3d 1148, 1150 (10th Cir. 2003) (“It seems unfair and abusive for a plaintiff to file a lawsuit and then refuse to make himself available for reasonable questioning regarding his claims.”).2
With respect to those opt-in plaintiffs who have never been identified by plaintiffs as having knowledge pertinent to pattern and practice issues, defendant asserts that the employment histories and/or prior discovery responses of these opt-in plaintiffs indicate that these individuals are likely to have discoverable information helpful to defendant’s anticipated decertification motion. The mere fact that plaintiffs have not identified these individuals in their Rule 26 disclosures has little relevance to the issue of whether these opt-in plaintiffs possess facts pertinent to the very issue that permits these plaintiffs to participate in this collective action–whether defendant engaged in a pattern and practice of unlawful discrimination based on age. Judge Waxse did not abuse his discretion in this regard.
The court also finds that the magistrate judge acted well within his discretion in denying plaintiffs’ request for a general order requiring that all depositions of out-of-town opt-in plaintiffs
2While plaintiffs make much of the fact that they have decided not to call these particular plaintiffs at trial, that decision does not preclude defendant, if it so desired, from calling these plaintiffs to support its theory that no pattern and practice of age discrimination existed.
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Case 2:03-cv-02200-JWL-DJW Document 4211 Filed 06/30/06 Page 6 of 7
occur via telephone, instead inviting plaintiffs to file particularized motions for protective orders depending on a given plaintiff’s circumstances. “As a general rule, a plaintiff will be required to make himself or herself available for examination in the district in which suit was brought. Since plaintiff has selected the forum, he or she will not be heard to complain about having to appear there for a deposition.” Stubbs v. McDonald’s Corp., 2005 WL 375662, at *1 (D. Kan. Jan. 26, 2005); accord 8A Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 2112 at 75-77 (2nd ed. 1994). Absent a specific showing of hardship tied to an individual’s circumstances, a general order requiring that the depositions of out-of-town plaintiffs be taken telephonically is not warranted. See United States v. Rock Springs Vista Dev., 185 F.R.D. 603, 603-04 (D. Nev. 1999) (in the absence of a showing of extreme hardship, denying intervenors’ request that their depositions be taken by telephone where intervenors sought substantial compensatory and punitive damages from defendant); Clem v. Allied Van Lines International Corp., 102 F.R.D. 938, 940 (S.D.N.Y.1984) (plaintiff failed to show requisite “extreme hardship” and was not entitled to have his deposition taken telephonically; financial burden of $3000 to appear for deposition was not extreme in light of “substantial” claims involved of over $130,000 plus attorneys’ fees).3
For the foregoing reasons, the court concludes that the magistrate judge properly exercised
3While plaintiffs rely extensively on Jahr v. IU Int’l Corp., 109 F.R.D. 429, 431 (M.D.N.C. 1986) to support their argument that telephonic depositions are appropriate in this case, the court finds Jahr unpersuasive in this context, as Jahr dealt with “a nonparty witness, not a plaintiff who was seeking monetary and other benefits from the litigation.” See Rock Springs Vista Dev., 185 F.R.D. at 603-04 (distinguishing Jahr).
6

Case 2:03-cv-02200-JWL-DJW Document 4211 Filed 06/30/06 Page 7 of 7 his discretion in denying plaintiffs’ motions for protective order.
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion to review and objections to the magistrate judge’s April 25, 2006 order (doc. 4100) is denied.
IT IS SO ORDERED. Dated this 30th day of June, 2006, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4213 Filed 07/01/06 Page 1 of 27

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al., Plaintiffs,
v. SPRINT/UNITED MANAGEMENT CO.,
Defendant.

Case No. 03-2200-JWL-DJW

MEMORANDUM AND ORDER

Pending before the Court is a Motion filed by Plaintiffs (doc. 3542) specifically requesting

the following relief (“Motion for Relief”):

C

An in camera review of sixty-five documents inadvertently disclosed by Defendant, all of

which Defendant claims are protected from disclosure by the attorney-client privilege;

C

A determination that the sixty-five documents inadvertently disclosed by Defendant are not

privileged and thus do not need to be returned to Defendant; and

C

An Order requiring all similar documents withheld by Defendant on grounds of privilege be

produced to Plaintiffs.

After consideration of the evidence presented at the March 2, 2006 and March 10, 2006

closed evidentiary hearing, as well as all pleadings submitted in conjunction with the issue, and for

the reasons stated below, the Court finds the sixty-five inadvertently disclosed documents are

protected by the attorney-client privilege.

Given the extensive procedural history with regard to this motion, as well as the large number

of factual contentions set forth by the parties, a brief outline of the opinion follows:

Case 2:03-cv-02200-JWL-DJW Document 4213 Filed 07/01/06 Page 2 of 27
********************************* I. Procedural Background With Respect to Motion at Issue II. Relevant Facts and Issue Presented III. Findings of Fact and Conclusions of Law
A. Findings of Fact B. Conclusions of Law
1. The Attorney-Client Privilege a. Adverse Impact/Due Diligence Documents i. Communications Made to Obtain Legal Advice ii. Communications Made in Confidence iii. Privilege Has Not Been Waived a) Inadvertent Production i) Precautions Taken ii) Time to Rectify iii) Scope of Discovery iv) Extent of Disclosure v) Fairness b) Waiver as a Result of Winkler’s Deposition Testimony c) Waiver By Affirmative Defense of “Good Faith” b. Two Other Documents at Issue i. Document 1205499 (Exhibit YY) ii. Document 1329540 (Exhibit AAA)
2. Work Product Protection IV. Conclusion
*********************************
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Case 2:03-cv-02200-JWL-DJW Document 4213 Filed 07/01/06 Page 3 of 27

I. Procedural Background With Respect to Motion at Issue

During the January 19, 2006 status conference, Plaintiffs submitted:

C

Written correspondence dated January 9, 2006 from Defendant to Plaintiffs

identifying documents inadvertently produced and requesting Plaintiffs return such

documents; and

C

Written correspondence dated January 18, 2006 from Plaintiffs to the Court

requesting an in camera review and subsequent determination of Defendant’s claim

of privilege for the inadvertently disclosed documents.

Notably, the inadvertently disclosed documents at issue primarily consist of identically formatted

mathematical spreadsheets – most of which bear the title of “due diligence matrix” and almost all

of which include a statement at the bottom of the document regarding “adverse impact” (hereafter

“adverse impact/due diligence documents”).

The Court construed the two letters as Plaintiffs’ Motion for Relief (doc. 3542) seeking

(1) an in camera review of sixty-five documents inadvertently disclosed and claimed to be privileged

by Defendant; (2) a determination that the sixty-five documents inadvertently disclosed by Defendant

are not privileged and thus do not need to be returned to Defendant; and (3) an Order requiring all

similar documents withheld by Defendant on grounds of privilege be produced to Plaintiffs. As

directed by the Court, Defendant filed a response under seal on January 24, 2006 (doc. 3552) and

Plaintiffs filed a reply under seal on January 31, 2006 (doc. 3553).

On February 1, 2006, the Court issued a Memorandum and Order (doc. 3549) ruling on a

Motion to Compel (doc. 3203) previously filed by Plaintiffs. In that Motion, and relevant to the

issues currently before the Court, Plaintiffs sought, among other things, to compel production of all

documents in Defendant’s privilege log that

C

failed to identify an attorney as the sender or the recipient; and

3

Case 2:03-cv-02200-JWL-DJW Document 4213 Filed 07/01/06 Page 4 of 27

C

were described as “adverse impact,” “due diligence,” or “impact ratio” documents.

Defendant opposed this Motion to Compel on grounds that the referenced documents

contained confidential and privileged adverse impact analyses that District Judge Lungstrum

previously ruled were not discoverable in this matter. Plaintiffs disagreed, arguing that Judge

Lungstrum’s ruling was applicable only to the two particular adverse impact documents involved

in Judge Lungstrum’s in camera review, and not to every “adverse impact” or “due diligence”

document.

In the February 1, 2006 Memorandum and Order, the Court reviewed Judge Lungstrum’s

previous ruling on the issue, which was transcribed as follows:

[A]lthough my earlier ruling was limited to certain documents specifically that I reviewed and said these are clearly within the ambit of attorney/client privilege, I have seen nothing that leads me to believe that age impact documents generated as a specific request in connection with a specific RIF by the legal department of the defendant would be anything other than attorney/client privileged documents …. It appears to me that this case in that sense is garden variety, and so therefore if all there is are documents – no matter how helpful or interesting they would be if I were the plaintiff in this case – that were generated in response to defendant’s lawyers saying, We would like to look at this so that we can give you some advice about what you ought to do in connection with that RIF, that’s just not something the plaintiffs are going to be able to get to.1

With Judge Lungstrum’s ruling in mind, and upon a review of the privilege log, the Court

found in the February 1, 2006 Memorandum and Order that Defendant met its burden of proof with

regard to a claim of protection based on the attorney-client privilege for the various documents

described in the privilege log as “adverse impact” and “due diligence.”2

1March 31, 2005 Transcript of Proceedings before the Honorable John W. Lungstrum, Exhibit C to Defendant’s Index of Exhibits (doc. 3419) at pp. 11-12.
2February 1, 2006 Memorandum and Order (doc. 3549).
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On February 20, 2006, Plaintiffs filed with District Judge Lungstrum a Motion to Review (doc. 3605) that portion of the February 1, 2006 Memorandum and Order dealing with documents identified as adverse impact analyses in the privilege log. Plaintiffs later requested Judge Lungstrum defer the review until after the undersigned Magistrate had the chance to conduct an in camera review and determine whether the representative sample of actual adverse impact/due diligence documents inadvertently produced are protected from disclosure by the attorney-client privilege. Judge Lungstrum granted (doc. 3804) Plaintiffs’ request and took the Motion to Review under advisement.
Thus, the Court then addressed the currently pending Motion, which not only deals with documents described as “adverse impact” and “due diligence” on a privilege log, but in addition deals with actual documents inadvertently produced. After reviewing the pleadings filed in conjunction with this Motion, the Court issued an Order on February 23, 2006 (doc. 3617) finding that the information submitted by the parties was insufficient to determine the applicability of the attorney-client privilege and/or the work product doctrine to the inadvertently disclosed documents at issue. More specifically, the Court determined it was not feasible to ascertain from the arguments of counsel and the face of the documents whether the documents qualified as (a) compilations of underlying data; or (b) statistical analyses undertaken at the direction of attorneys.
Based on the Court’s need for more information regarding creation and use of the documents in dispute, the Court conducted a closed evidentiary hearing, which commenced on March 2, 2006 and was resumed and concluded on March 10, 2006. At the hearing, Defendant introduced the sixtyfive inadvertently disclosed documents at issue, each of which were individually identified by bates stamp number as a one-page document within the following multi-page exhibits:
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Case 2:03-cv-02200-JWL-DJW Document 4213 Filed 07/01/06 Page 6 of 27

Bates #
1205499 1235522 1235539 1235567 1235583 1235596 1235641 1235671 1235686 1235716 1235724 1235768 1235830 1235883 1235916 1236088

Ex. #
YY A B C D E F G H I J K L M N O

Bates #
1236138 1236175 1236211 1236219 1236236 1236239 1236242 1236245 1236892 1236898 1236902 1236905 1236908 1236911 1236933 1236966

Ex. #
P Q R S T U V W X Y Z AA BB CC DD EE

Bates #
1237023 1237030 1237036 1237040 1237043 1237046 1237049 1237059 1237068 1237072 1259888 1329540 1335479 1339401 1339402 1339403

Ex. #
FF GG HH II JJ KK LL MM NN OO ZZ AAA BBB PP PP PP

Bates #
1339546 1339547 1339551 1339552 1339589 1339590 1339594 1339595 1340435 1340436 1340437 1340438 1345994 1346031 1347314 1356404 1356684

Ex. #
QQ QQ QQ QQ RR RR RR RR SS SS SS SS TT UU VV CCC XX

II. Relevant Facts and Issue Presented Beginning in the fourth quarter of 2001, and extending approximately through the end of the
first quarter of 2003, Defendant engaged in a large scale reduction of its work force (“RIF”). As part of this reorganization process, Defendant maintains it conducted a statistical analysis comparing the demographic data (gender, race and age) of employees targeted for lay off to the demographic data of those who would be retained. Defendant further maintains this “adverse impact” or “due diligence” analysis was performed at the specific request of its attorneys for the purpose of obtaining legal advice regarding the statistical impact on the various groups under the discrimination laws. Defendant maintains that the sixty-one of the inadvertently produced documents are such statistical analyses undertaken at the direction of attorneys. Accordingly, Defendant argues the “adverse impact” and “due diligence” documents and information inadvertently produced are protected from disclosure by the attorney-client privilege and thus must be returned.
6

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Plaintiffs disagree, arguing the “adverse impact” and “due diligence” documents are not protected from disclosure by the attorney-client privilege because they are not analyses undertaken at the direction of attorneys but instead are merely data compilations independently generated and utilized by employees within Defendant’s Human Resource Department. III. Findings of Fact and Conclusions of Law
A. Findings of Fact At all times relevant to the issue presented, Jill Ferrel (“Ferrel”) was employed by Defendant as an attorney in its Law Department. In her capacity as Defendant’s attorney, Ferrel issued a Memorandum dated October 5, 2001 (“Ferrel Memo”) to various personnel within the Human Resources (“HR”) department.3 More specifically, the Ferrel Memo directs HR to gather designated information so that the Law Department can provide legal advice regarding the statistical impact of the RIF on various personnel groups under the discrimination laws.4 The Ferrel Memo is stamped “Privileged Attorney-Client Advice” and the RE: line designates the subject matter of the written communication as “Adverse Impact Analysis.”5 At the evidentiary hearing, Defendant provided evidence regarding the process used by the HR Department to gather and present the information requested by the Law Department. For each department or subgroup, an HR person assigned to that department or subgroup prepared three spreadsheets. The first spreadsheet by HR personnel is referred to by the parties as the “Master List.”
3The Ferrel Memo was submitted to the Court in camera at the closed evidentiary hearing and has been filed under seal at Defendant’s Exhibit FFF.
4Id. 5Id.
7

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The Master List contains the names of all employees in the relevant subgroup, as well as associated demographic information for these employees.6
The second of the three spreadsheets created by HR personnel is referred to by the parties as the “RIF List.” The RIF List contains the names of the employees on the Master List who have been selected for termination as part of the RIF.7 Both the Master List and the RIF List are created by HR personnel with data obtained from Defendant’s database and from Defendant’s managers.8 These two spreadsheets were used for a variety of purposes during the RIF, such as organizing information and comparing candidates; thus, Defendant does not claim attorney-client privilege protection for the Master List or the RIF List.9
The third spreadsheet prepared by HR is the “adverse impact” or “due diligence” document.10 To generate the adverse impact or due diligence spreadsheet for each subgroup, HR personnel drew information from the other two spreadsheets using the methodology outlined by Jill Ferrel in her October 5, 2001 Memorandum.11 The methodology outlined by the Ferrel Memo included data entry
6Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at p.26, lines 14-19 (doc. 3742); Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp.5-6.
7Id. 8Testimony of Scott Winkler, Sealed Transcript of Proceedings Held 3/10/2006 at p.57, line 24 through p.58, line 8 (doc. 3820); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held 3/10/2006 at p.76, lines 4-10 (doc. 3820). 9Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at p.36, line 25 through p.37, line 3; p.66, lines 7-10 (doc. 3742); Testimony of Scott Winkler, Sealed Transcript of Proceedings Held 3/10/2006 at p.57, line 24 through p.58, line 14 (doc. 3820). 10Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at p.26, lines 3-19 (doc. 3742). 11The Ferrel Memo, Sealed Hearing Exhibit FFF.
8

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in various combinations utilizing a formula provided by the Law Department.12 The formula automatically generated the adverse impact document in a specific format devised by counsel.13
The adverse impact documents were transmitted and/or delivered to Defendant’s Legal Department for the purpose of rendering legal advice.14 Although sixteen of the sixty-one
inadvertently disclosed adverse impact spreadsheets were not explicitly marked with a “Sprint –
Internal Use Only Confidential” designation, Defendant presented evidence that these adverse impact
spreadsheets were kept confidential by being distributed only to those individuals who had some
stated purpose in receiving them and were available only to legal counsel and HR personnel upon entry of a confidential password.15
B. Conclusions of Law
1. The Attorney-Client Privilege
The purpose of the attorney-client privilege “is to encourage full and frank communication
12Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/10/2006 at p.54, lines 14-22 (doc. 3820); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held on 3/10/2006 at p.71, line 18 through p.72, line 23; p.76, lines 11-20 (doc. 3820).
13Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held on 3/10/2006 at p.72, line 24 through p.73, line 6 (doc. 3820).
14At the hearing, Defendant submitted Exhibit GGG to the Court in camera. More specifically, Exhibit GGG is a binder containing privileged e-mails establishing that the majority of the adverse impact documents were e-mailed directly to Defendant’s counsel. Defendant presented further evidence at the hearing that adverse impact documents often were personally delivered during meetings with counsel on Defendant’s campus. Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/10/2006 at p.57, lines 6-21 (doc. 3820); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held on 3/10/2006 at p.73, lines 7-22 (doc. 3820); Testimony of Deborah Sprayberry, Sealed Transcript of Proceedings Held on 3/10/2006 at p.131, line 3 through p.132, line 7 and p.165, lines 3-11 (doc. 3820); Excerpt from Eric Rice Deposition, Sealed Hearing, Exhibit DDD at pp.6-7.
15The Ferrel Memo, Sealed Hearing Exhibit FFF at p.4; Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp.24-25.
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between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice.”16 The privilege serves the client’s need for legal advice, but it also serves the attorney’s need to receive complete information in order to give the proper advice. The privilege protects communications with in-house, as well as outside, counsel.17
“Not every communication between an attorney and client is privileged, only confidential communications which involve the requesting or giving of legal advice.”18 “The focal point of the protection afforded by the attorney-client privilege lies with ‘communications’ between attorneys and their clients” related to legal advice.19 Legal advice must predominate for the communication to be protected.20 The privilege does not apply where the legal advice is merely incidental to business advice.21 And, although the privilege protects disclosure of substantive communication between attorney and client, “it does not protect disclosure of the underlying facts by those who communicated with the attorney.”22
In Upjohn,23 the United States Supreme Court distinguished between disclosure of underlying
16Upjohn Co. v. United States, 449 U.S. 383, 389 (1981). 17Id. at 390. 18Burton v. R.J. Reynolds Tobacco Co.,, 175 F.R.D. 321, 327 (D. Kan. 1997) (citing Fisher v. United States, 425 U.S. 391, 403 (1976); United States v. Olano, 62 F.3d 1180 (9th Cir. 1995)). 19IMC Chemicals, Inc. v. Niro, Inc., No. 98-2348, 2000 WL 1466495, at *8-9 (D. Kan. July 19, 2000) (quoting Upjohn Co., 449 U.S. at 395-96). 20Burton v. R.J. Reynolds Tobacco Co., Inc., 170 F.R.D. 481, 484 (D. Kan. 1997)(citation omitted). 21Id. 22Upjohn, 449 U.S. at 395-96. 23Id.
10

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facts and disclosure of privileged communications. The Court held that “[t]he protection of the privilege extends only to communications and not to facts. A fact is one thing and a communication concerning that fact is an entirely different thing.”24 The Court explained: “The client cannot be compelled to answer the question, ‘What did you say or write to the attorney?’ but may not refuse to disclose any relevant fact within his knowledge merely because he incorporated a statement of such fact into his communication with his attorney.”25
Because this action arises under a federal statutory scheme, federal law provides the rule of decision as to application of the attorney-client privilege.26 Under federal common law, the essential elements of the attorney-client privilege are: (1) Where legal advice is sought (2) from a professional legal advisor in his or her capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or by the legal advisor, (8) except the protection be waived.27 The party seeking to invoke the attorney-client privilege bears the burden of establishing its applicability.28 Applying these factors to the privilege issues disputed by the parties here, the Court finds Defendant must establish – for
24Id. (emphasis in original) (quoting Philadelphia v. Westinghouse Elec. Corp., 205 F. Supp. 830, 831 (E.D. Pa. 1962).
25Id. at 396.
26See Sprague v. Thorn Americas, Inc., 129 F.3d 1355, 1368-69 (10th Cir. 1997) (federal privilege law applies to federal claim). No real conflict between federal and Kansas law regarding attorney-client privilege exists. See Hiskett v. Wal-Mart Stores, Inc., 180 F.R.D. 403, 405 (D. Kan. 1998).
27Great Plains Mut. Ins. Co. v. Mutual Reinsurance Bureau, 150 F.R.D. 193, 196 (D. Kan. 1993).
28In re Foster, 188 F.3d 1259, 1264 (10th Cir. 1999). 11

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both the adverse impact/due diligence document and the other “non-adverse impact” documents – that first, the communications at issue were made for the purpose of obtaining legal advice from the lawyer; second, the communications were made in confidence; and third, the privilege was not waived.
a. Adverse Impact/Due Diligence Documents Applying these legal standards to the facts presented, the Court concludes the adverse impact documents inadvertently disclosed by Defendant and submitted for in camera review by the Court are protected from disclosure by the attorney-client privilege. In other words, the evidence presented by Defendant sufficiently demonstrates that the adverse impact/due diligence documents were generated at the direction of counsel – pursuant to the Ferrel Memo – for the purpose of rendering legal advice and, after such generation, were then provided to counsel for analysis.29
29For the evidence relating to inadvertently disclosed documents within Exhibits A, B, C, D, E, F, G, H and I, see Winkler Testimony from 3/02/2006 at pp. 28-30, 32-33, 40-43, 48 and 52 (doc. 3742).
For the evidence relating to inadvertently disclosed documents within Exhibits J-N and TT-XX, see Winkler Testimony from 3/02/2006 at pp. 44-52 (doc. 3742) and Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp. 7-15.
For the evidence relating to inadvertently disclosed documents within Exhibits O-OO, see Winkler Testimony from 3/02/2006 at pp.52-57 (doc. 3742) and Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp.16-18.
For the evidence relating to inadvertently disclosed documents within Exhibits PP, QQ and RR, see Sprayberry Testimony from 3/10/2006 at pp.129-132, 134, 160 and 165 (doc. 3820).
For the evidence relating to inadvertently disclosed documents within Exhibit SS, see Eisler Testimony from 3/10/2006 at pp.166-169 (doc. 3820).
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i. The Communications Were Made For the Purpose of Obtaining Legal Advice
The Court finds Defendant’s due diligence matrices and adverse impact spreadsheets were made at the direction of Defendant’s Law Department in order to secure legal advice from counsel and were not mere compilations of non-privileged business data and underlying facts. In support of this finding, the Court relies on the October 5, 2001 Ferrel Memo submitted in camera and filed under seal, which specifically directs Defendant’s HR Department to gather designated information so that its Law Department can perform adverse impact analyses in connection with Defendant’s RIF. The evidence establishes that Defendant’s HR personnel followed the specific methodology outlined by Ferrel in her October 5, 2001 memo in creating these documents. More specifically, the methodology outlined by the Ferrel Memo included data entry in various combinations utilizing a formula and format provided by the Law Department.
In addition to the Ferrel Memo, Defendant also submitted evidence demonstrating that the adverse impact documents were forwarded to counsel via email – or in person – for the purpose of obtaining legal advice. More specifically, Sprint submitted a binder at the hearing that contains privileged e-mails for in camera review by the Court. These e-mails establish that the majority of the adverse impact documents were e-mailed directly to Sprint’s counsel. Moreover, Defendant presented further evidence at the hearing that adverse impact documents often were personally delivered during meetings with counsel on the Sprint campus.
Plaintiffs’ argument that the calculations necessary for adverse impact analysis are not privileged or confidential, but instead are readily available in the public domain, does not defeat the privilege. The Court agrees that the commonly accepted, longstanding benchmark for evaluating
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disparate impact is the “four-fifths rule” of the Uniform Guidelines on Employee Selection Procedures30 adopted by the Equal Opportunity Commission (“EEOC Guidelines”), which provides a selection rate that “is less than [80%] of the rate for the group with the highest rate will generally be regarded” as evidence of adverse impact. Whether this information is in the public domain, however, is simply immaterial to Defendant’s claim of attorney-client privilege for the adverse impact/due diligence documents. As the United States Supreme Court explains, “[a] fact is one thing and a communication concerning that fact is an entirely different thing.”31 The Court further explains: “The client cannot be compelled to answer the question, ‘What did you say or write to the attorney?’ but may not refuse to disclose any relevant fact within his knowledge merely because he incorporated a statement of such fact into his communication with his attorney.”32
As Plaintiffs assert, the “four-fifths rule” is in the public domain and, thus, the “four-fifths rule” is a discoverable underlying fact. As the United States Supreme Court admonishes, however, “a communication concerning that fact is an entirely different thing.” Here, Defendant provides sufficient evidence for the Court to find that the adverse impact/due diligence analyses are such a communication and thus are protected from disclosure by the attorney-client privilege.
Plaintiffs also argue that the documents are not privileged because the privileged information was exchanged among various HR personnel prior to forwarding the information to legal counsel. The Court is not persuaded by this argument. The essential elements of the privilege as defined
3029 C.F.R. § 1607.4(D) (2005). 31Upjohn, 449 U.S. at 395-96 (emphasis in original) (quoting Philadelphia v. Westinghouse Elec. Corp., 205 F. Supp. 830, 831 (E.D. Pa. 1962). 32Id. at 396.
14

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above do not require an attorney to have either authored or received the document at issue in order to maintain the privilege. A party may successfully demonstrate applicability of the privilege to written communication between corporate management employees by establishing that the communication was made in confidence for the primary purpose of obtaining legal advice.33 Organizational clients and business entities often are personified by a number of employees. In preparation for, or in the midst of, consultations with an attorney, employees of the client will often consult one another to ensure that the attorney’s advice is based on full knowledge of all relevant facts. With regard to the attorney-client privilege, the United States Supreme Court specifically acknowledges that “sound legal advice or advocacy serves public ends and that such advice or advocacy depends upon the lawyer being fully informed by the client.”34 The Court goes on to say that “[t]he lawyer-client privilege rests on the need for the advocate and counselor to know all that relates to the client’s reasons for seeking representation if the professional mission is to be carried out.”35
Simply put, the evidence demonstrates that the written communications here – the due diligence matrices and adverse impact spreadsheets – were made at the direction of the Law Department in order to secure legal advice from counsel and were not mere compilations of non-
33See Lintz v. American Gen. Fin., Inc., Civ. 98-2213-JWL, 1999 WL 450197, at *4 (D. Kan. June 24, 1999) (holding that although written communication between management employees of defendant is not necessarily protected by the attorney-client privilege, defendant successfully demonstrated applicability of privilege by establishing that written communication was confidential in nature and contained legal advice obtained from counsel for defendants).
34Upjohn, 449 U.S. at 389 (quoting Trammel v. United States, 445 U.S. 40, 51 (1980)). 35Id.
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privileged business data and underlying facts.36 Notably, Defendant has not made a claim of privilege for – and, in fact, has produced – the relevant, underlying data (e.g., Master List and RIF List) from which Plaintiffs may make their own adverse impact analysis using the “four-fifths rule” included within the EEOC Guidelines. And, even if – as a result of legal advice – an employee was added or deleted from the RIF list, Plaintiffs still are free to inquire of the actual decision makers as to the basis of their termination decisions.
ii. Communications Were Made in Confidence Under the common law, a critical component of the privilege “is whether the communication between the client and the attorney is made in confidence of the relationship and under circumstances from which it may reasonably be assumed that the communication will remain in confidence.”37 Because confidentiality is key to the privilege, “[t]he attorney-client privilege is lost if the client discloses the substance of an otherwise privileged communication to a third party.”38 The Tenth Circuit has admonished that “the confidentiality of communications covered by the privilege must be jealously guarded by the holder of the privilege lest it be waived. The courts will grant no greater
36See Motley v. Marathon Oil Co., 71 F.3d 1547, 1550-51 (10th Cir. 1995) (court found no abuse of discretion in the district court’s decision to protect as privileged multiple lists prepared at the request of counsel in order to provide legal advice about a corporate restructuring); McDonnell Douglas Corp. v. EEOC, 922 F. Supp. 235 (E.D. Mo. 1996) (court held documents containing adverse impact analyses on employees of reduction in force, which were prepared at request of counsel for purposes of rendering legal advice and were kept confidential, were protected by attorney-client privilege).
37In re Qwest Communications Intern. Inc., -- F.3d --, 2006 WL 1668246 at *5 (10th Cir. June 19, 2006) (citing United States v. Lopez, 777 F.2d 543, 552 (10th Cir.1985)).
38Id. (citing United States v. Ryans, 903 F.2d 731, 741 n.13 (10th Cir.1990)). 16

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protection to those who assert the privilege than their own precautions warrant.”39 “Any voluntary disclosure by the client is inconsistent with the attorney-client relationship and waives the privilege.”40
Plaintiffs argue Defendant failed to treat the adverse impact documents confidentially, which as noted above is an essential element to maintaining the privilege. The Court disagrees.
As a preliminary matter, the evidence establishes that all of the adverse impact documents were protected by a password available only to HR and Legal Department personnel. Moreover, most of the adverse impact matrices inadvertently disclosed were marked “Sprint - Internal Use Only Confidential” directly under the tables. Contrary to Plaintiffs’ assertion, the Court finds this marking readily distinguishable from the “PRIVILEGED CONFIDENTIAL” marking associated with this lawsuit, the font of which is identical to the bates stamp and “REDACTED” markings.
Also contrary to Plaintiffs’ assertions, there is ample evidence to demonstrate that recipients of the privileged adverse impact information were aware of the confidential nature of such information, as well as the purpose for which the information was to be used: obtaining legal advice.41 Plaintiffs have submitted no conflicting evidence. Plaintiffs’ argument that adverse impact documents were disseminated to employees who had no purpose for receiving them is not supported
39Id. 40Id. (citing United States v. Bernard, 877 F.2d 1463, 1465 (10th Cir.1989)). 41The Ferrel Memo, Sealed Hearing Exhibit FFF at p.4; Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp.24-25; Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at pp.28, 38-39, 42, 45 and 52 (doc. 3742); Testimony of Scott Winkler, Sealed Transcript of Proceedings Held 3/10/2006 at pp. 57 and 59 (doc. 3820); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held 3/10/2006 at p.73 (doc. 3820); Testimony of Deborah Sprayberry, Sealed Transcript of Proceedings Held 3/10/2006 at pp.131 and 165 (doc. 3820).
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by the record.

To that end, Plaintiffs make reference to the testimony of two of Defendant’s employees.

First, Plaintiffs maintain Deborah Sprayberry stated at the hearing that although she was sent the

adverse impact matrices, “she had no use for them whatsoever, and that she simply kept the final

matrices in her files.”42 What Ms. Sprayberry’s actually states, however, is that during the relevant

time period,

C

she was the manager of Regional HR operations and supported the field HR

managers from headquarters;43 and

C

she received the adverse impact documents for the purpose of creating employee

separation packages and permanently retaining the data.44

As their second example, Plaintiffs allege Gina Eisler received the adverse impact documents

and had no need for them. Again, what Ms. Eisler actually states is that during the relevant time,

C

she was the HR manager supporting PCS sales and marketing;45

C

she was working directly with in-house attorney Stephany Newport in conjunction

with the RIF;46 and

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she received the adverse impact documents for the purpose of transmitting them to

her liaison in the Legal Department, Stephany Newport.47

42Plaintiffs’ Brief at p.38. (doc. 3847). 43Testimony of Deborah Sprayberry, Sealed Transcript of Proceedings Held 3/10/2006 at p.128, lines 10-21 (doc. 3820). 44Id. at p.150, lines 17-19 (doc. 3820). 45Testimony of Gina Eisler, Sealed Transcript of Proceedings Held 3/10/2006 at p.166, lines 20-23 (doc. 3820). 46Id. at p.169, lines 10-19. 47Id. at p.171, lines 21-23.
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Plaintiffs presents no other evidence to support their proposition; thus, the Court finds the adverse impact analyses were disseminated only to those individuals who had some stated purpose in receiving them.
iii. The Privilege Has Not Been Waived With respect to the attorney-client privilege, one of the essential elements that must be established is that the privilege has not been waived.48 The burden to establish that waiver has not occurred remains with the party who is asserting the attorney-client privilege.49 “It has long been the law that a client may waive protection of the [attorney-client] privilege, either expressly or impliedly.”50 With respect to a corporation, such as Defendant, “the power to waive the corporate attorney-client privilege rests with the corporation’s management and is normally exercised by its officers and directors.”51 A mere employee “cannot waive the corporation’s privilege.”52 Plaintiffs assert they are not required to return the adverse impact documents because: (1) Defendant waived the privilege by its inadvertent production of the documents; (2) Defendant waived the privilege as a result of Scott Winkler’s deposition testimony; and (3) Defendant waived the privilege by asserting an affirmative defense of “good faith.” The Court is not persuaded by any of these assertions.
48Johnson v. Gmeinder, 191 F.R.D. 638, 642- 43 (D. Kan. 2000); ERA Franchise System, Inc. v. Northern Ins. Co. of New York, 183 F.R.D. 276, 278 (D. Kan. 1998) (citations omitted).
49Gmeinder, 191 F.R.D. at 643. 50United States v. Stewart, 51 F.Supp.2d 1147,1151 n. 3 (D. Kan. 1999). 51Commodity Futures Trading Comm'n v. Weintraub, 471 U.S. 343, 348-49 (1985). 52Sprague v. Thorn Americas, Inc., 129 F.3d 1355, 1371 (10th Cir.1997) (quoting United States v. Chen, 99 F.3d 1495, 1502 (9th Cir.1996)).
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a) Inadvertent Production Plaintiffs claim that Defendant waived the attorney-client privilege when it inadvertently produced the adverse impact documents to Plaintiffs. Courts in this district apply a five-factor test to determine whether the inadvertent disclosure of a document constitutes a waiver of the attorney-client privilege or of work-product protection.53 These five factors include: (1) the reasonableness of the precautions taken to prevent inadvertent disclosure; (2) the time taken to rectify the error; (3) the scope of discovery; (4) the extent of disclosure; and (5) the overriding issue of fairness.54 Thus, the Court will consider each of these five factors to determine whether Defendant has waived the attorney-client privilege for the inadvertently produced documents.
i) Precautions Taken With regard to this first factor, the Court finds Defendant’s efforts to prevent inadvertent disclosure were reasonable. Defendant maintains in its briefing that prior to production, all the adverse impact documents were converted to TIFF images and were reviewed on the computer screen by attorneys in an effort to avoid production of privileged documents.55 Defendant further maintains that it implemented document production software (1) to label as “privileged” all privileged documents and portions thereof; and (2) to earmark such documents and portions thereof
53Employer's Reinsurance Corp. v. Clarendon Nat. Ins. Co., 213 F.R.D. 422, 428 (D. Kan. 2003) (citing Zapata v. IBP, Inc., 175 F.R.D. 574, 576-77 (D. Kan. 1997)).
54Id. (citing Wallace v. Beech Aircraft Corp., 179 F.R.D. 313, 314 (D. Kan. 1998); Zapata, 175 F.R.D. at 577; Kansas City Power & Light Co. v. Pittsburg & Midway Coal Mining Co., 133 F.R.D. 171, 172 (D. Kan. 1989)).
55Sprint’s Sealed Post-Evidentiary Hearing Reply Brief at pp.19-20 (doc. 3863). 20

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for inclusion within the privilege log.56 Defendant has produced tens of thousands of documents, and literally hundreds of thousands
of pages in this case, both in hard copy and electronically. With regard to such a production, the Court finds it instructive to consider the advisory committee’s comment to the proposed amendment to Fed. R. Civ. P. 26(f), which acknowledges that privilege waiver issues “often become more acute when discovery of electronically stored information is sought.” The committee goes on to explain that “[t]he volume of such data, and the informality that attends use of e-mail and some other types of electronically stored information, may make privilege determinations more difficult, and privilege review correspondingly more expensive and time consuming. Other aspects of electronically stored information pose particular difficulties for privilege review.”57
Based on the circumstances presented, the Court finds that the precautions taken by Defendant to prevent inadvertent disclosure were reasonably adequate.58 Accordingly, this factor weighs against waiver.
56Id. at 20. 57Comment to proposed amendment to Fed. R. Civ. P. 26(f) at p.24 (effective December 1, 2006), accessed on June 30, 2006 at http://www.uscourts.gov/rules/EDiscovery_w_Notes.pdf. 58See, e.g., Kansas City Power & Light, 133 F.R.D. at 172 (holding the precautions were adequate where plaintiff's counsel reviewed each document and retained the withheld documents in its files); Wallace, 179 F.R.D. at 314 (holding the precautions were adequate where all documents were reviewed by counsel and a legal assistant before making them available for review by opposing counsel).
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ii) Time to Rectify The relevant time frame for rectifying the inadvertent disclosure begins when a party discovers, or with reasonable diligence should have discovered, the inadvertent disclosure. 59 In this case, Plaintiffs do not dispute that Defendant sought to rectify the disclosure promptly after actually discovering it. Accordingly, this factor also weighs against waiver.
iii) Scope of Discovery In light of the hundreds of thousands of pages of documents produced by Defendant in this case, the Court has no difficulty concluding that Defendant produced a sufficient number of documents for the Court to find that this third factor weighs against waiver.60
iv) Extent of Disclosure The fourth factor considers the extent to which the documents were disclosed. Although “[m]eaningful use of the documents disclosed is often sufficient to find extensive disclosure,”61 the facts here establish that Defendant only has produced the documents to Plaintiffs and, as ordered by the Court, Plaintiffs have not utilized or disseminated the documents inadvertently produced. Accordingly, this factor also weighs against waiver.62
59Zapata, 175 F.R.D. at 577; Kansas City Power & Light, 133 F.R.D. at 172. 60See, e.g., Zapata, 175 F.R.D. at 577 (D. Kan.1997) (finding document production was extensive where 40,000 documents were produced in discovery and 1,000 were produced with the privileged document); Monarch Cement Co. v. Lone Star Indus., 132 F.R.D. 558, 560 (D. Kan.1990) (finding document production was extensive where 9,000 documents were produced). 61Employer's Reinsurance Corp. v. Clarendon Nat. Ins. Co., 213 F.R.D. at 429 (citations omitted). 62See, e.g., Monarch, 132 F.R.D. at 560 (finding disclosure was not extensive where the document was only disseminated to opposing counsel); Wallace, 179 F.R.D. at 315 (same).
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v) Fairness Lastly, the fifth factor is fairness. Ordinarily, the “[k]ey to the court’s consideration of this factor is the relevancy of the documents.”63 Although the Court has no difficulty concluding that the adverse impact documents inadvertently disclosed are relevant to this litigation, the Court again acknowledges that Defendant has produced the relevant, underlying data (e.g., Master List and RIF List) from which Plaintiffs may make their own adverse impact analysis. And, even if – as a result of legal advice – an employee was added or deleted from the RIF list, Plaintiffs still are free to inquire of the actual decision makers as to the basis of their termination decisions. In sum, fairness requires that Plaintiffs not be allowed to make use of the adverse impact documents. Accordingly, this fifth factor weighs against finding a waiver. Because all five factors weigh against a finding of waiver, the Court finds Defendant has not waived the attorney-client privilege with respect to the inadvertently disclosed adverse impact documents.
b) Waiver as a Result of Scott Winkler’s Deposition Testimony
Plaintiffs assert Defendant waived the attorney-client privilege when it permitted Scott Winkler to testify, without objection, regarding the Ferrel Memo during his deposition. Defendant disagrees, arguing that the testimony provided by Winkler did not waive the privilege because Winkler did not disclose the content of any privileged communication but instead only discussed the Ferrel Memo in terms of its general directive to run the adverse impact at different levels. The Court agrees with Defendant.
63Wallace, 179 F.R.D. at 315. 23

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For the testimony of Winkler to constitute a waiver of the attorney-client privilege, it had to have disclosed the substance of privileged communications.64 Underlying facts are not protected by the privilege.65 Furthermore, revealing the “general topic of discussion” between attorney and client does not waive the privilege, unless such revelation also reveals the substance of a protected communication.66
Applying the facts to the law here, the Court finds that Winkler’s reference to the Ferrel Memo reveals information only about the general topic of the memo and did not reveal the substance of an attorney-client privileged protected communication. Accordingly, the Court finds no waiver as a result of Scott Winkler's deposition testimony.
c) Waiver By Asserting Affirmative Defense of “Good Faith”
In support of this argument, Plaintiffs assert Defendant waived the attorney-client privilege with respect to the inadvertently produced adverse impact documents by putting in issue Defendant’s intent to discriminate, which Defendant allegedly did by denying Plaintiffs’ allegations of wilful discrimination and asserting a good faith affirmative defense. The Court finds Plaintiffs’ argument to be without merit.
As a preliminary matter, asserting an affirmative defense of good faith does not automatically
64See Aquinaga v. John Morrell & Co., 112 F.R.D. 671, 683 (D. Kan. 1986) (applying Kansas law).
65Upjohn, 449 U.S. at 396. 66Burton v. R.J. Reynolds Tobacco Co., 177 F.R.D. 491, 499 (D. Kan. 1997).
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place advice of counsel at issue.67 In fact, the Court finds that in alleging wilful – and thus intentional – discrimination, it is Plaintiffs who introduced into this lawsuit the issue of whether Defendant acted in “good faith.” Thus, it is Plaintiffs who bear the burden of proof on that subject. Defendant’s affirmative assertion of good faith in answer to the Complaint does not alter these facts.
b. Two Other Documents at Issue68 i. Document 1205499 (Exhibit YY)
This documents is a RIF list for “Parkinson 7/15" with handwritten notations on it. In support of its claim of privilege with regard to selected portions of the handwritten notes, Defendant provides a “Declaration of Faith Palmer,”69 within which Ms. Palmer avers under oath that the selected portions of the handwritten notes reflect legal advice given to her by Sprint in-house attorney Pat Hulla. Based on Ms. Palmer’s affidavit and a review of the handwritten notes, the Court finds Defendant has carried its burden of establishing that the selected notations referenced by Ms. Palmer are protected from disclosure by the attorney-client privilege.70 In so finding, the Court rejects Plaintiffs’ claim that Defendant asserts only work product protection with regard to this
67SmithKline Beecham Corp. v. Apotex Corp., No. 99-CV-4304, 2005 WL 2436662 (E.D. Pa. Sept. 28, 2005) (citing Paul R. Rice, Attorney-Client Privilege in the United States § 9.48, at 182 (2d ed. 1999) (“Only if the defendant elects to offer evidence to disprove the claim, and relies upon the attorney's advice to do so, will the plaintiff be given access to protected communications.”).
68Although there originally were four “other” (e.g., non-“adverse impact”) documents inadvertently produced for which Defendant claimed a privilege, the parties were able to come to an agreement with regard to two of the four documents.
69Affidavit of Faith Palmer, Sealed Hearing Exhibit YY. 70See Burton v. R.J. Reynolds Tobacco Co., 170 F.R.D. at 484 (the attorney-client privilege protects confidential communications between an attorney and client which occur in the course of giving or requesting legal advice.).
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document. This is because Plaintiffs have provided no evidence supporting such a claim. ii. Document 1329540 (Exhibit AAA)
This document is one-half page of handwritten notes. In support of its claim of privilege, Defendant submits the “Affidavit of Beth Forwalder,”71 who at all relevant times has been employed by Defendant as an attorney. In the affidavit, Ms. Forwalder avers under oath that the handwritten notes reflected on document 1329540 are consistent with legal advice she provided to HR personnel during a presentation she made at a meeting on or about January 8, 2003. Ms. Forwalder further avers under oath that the purpose of her presentation to this group was to provide legal advice concerning adverse impact and risk analysis regarding the RIF process and the handwritten notes reflect the advice given. Based on Ms. Forwalder’s affidavit and a review of the handwritten notes, the Court finds Defendant has carried its burden of establishing that the handwritten notes referenced by Ms. Forwalder are protected from disclosure by the attorney-client privilege.72 In so finding, the Court rejects Plaintiffs’ claim that Defendant asserts only work product protection with regard to this document. This is because, again, Plaintiffs have provided no evidence supporting such a claim.
2. Work Product Protection Because the Court finds the sixty-five inadvertently disclosed documents are protected from disclosure by the attorney-client privilege, there is no need for the Court to determine whether the documents at issue are also protected from disclosure by the work product doctrine.
71Affidavit of Beth Forwalder, Sealed Hearing Exhibit EEE. 72See Burton v. R.J. Reynolds Tobacco Co., 170 F.R.D. at 484 (the attorney-client privilege protects confidential communications between an attorney and client which occur in the course of giving or requesting legal advice.).
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IV. Conclusion

For the reasons stated above, the Motion for Relief filed by Plaintiffs (doc. 3542) is granted

in part and denied in part to the extent that

C

The Court has conducted an in camera review of the sixty-five documents

inadvertently disclosed by Defendant;

C

The Court hereby determines the adverse impact/due diligence documents

inadvertently disclosed by Defendant are protected from disclosure by the attorney-

client privilege and thus must be returned to Defendant;

C

The Court hereby determines that the inadvertently disclosed handwritten notes at

issue within documents bearing bates stamps 1205499 (Exhibit YY) and 1329540

(Exhibit AAA) are protected from disclosure by the attorney-client privilege; and

C

Plaintiffs’ request for production of all documents similar to the inadvertently

produced adverse impact/due diligence documents is denied.

Accordingly, it is hereby ORDERED that Plaintiffs shall return the documents at issue, and

all copies thereof, within five (5) days from the date of this Memorandum and Order. It is further

ORDERED that Plaintiffs shall be prohibited from using these documents in any manner.

IT IS SO ORDERED.

Dated in Kansas City, Kansas on this 1st day of July, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4221 Filed 07/10/06 Page 1 of 5

DJW/byk

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,
Defendant.

CIVIL ACTION No. 03-2200-JWL-DJW

ORDER

This Order is in response to Chief District Judge John W. Lungstrum’s June 30, 2006

Memorandum and Order (doc. 4212), which remands Plaintiffs’ underlying Motion to Compel

Discovery (doc. 3580) to the Magistrate Judge for factual findings based on the lack of a sufficient

record to review the decision.

On February 15, 2006, Plaintiffs filed a multi-part motion which sought: (1) to amend some

of the current scheduling order deadlines; (2) to compel Defendant to produce all Reduction In Force

(“RIF”) spreadsheet documents in native format; (3) to compel Defendant to produce transmittal and

other RIF-related e-mails in native format; (4) to compel Defendant to provide Plaintiffs’ counsel and

experts with access to Defendant’s computer system, hard-drives, and all other computer back-up

tapes to locate and retrieve RIF spreadsheets and e-mails that they claim Defendant has failed to

produce in native format; (5) sanctions against Defendant for its conduct in failing to produce

spreadsheet materials in native format and the re-production of more than 200,000 pages of

spreadsheet materials that had already been produced in native format; (6) sanctions against

Case 2:03-cv-02200-JWL-DJW Document 4221 Filed 07/10/06 Page 2 of 5

Defendant for failing to timely produce spreadsheet materials as required by the Court’s May 5, 2005

Show Cause Order and other Show Cause Orders; and (7) to appeal the Magistrate Judge’s

February 8, 2006 Order.1

The undersigned Magistrate Judge orally ruled on Plaintiffs’ motion at the April 20, 2006

discovery/status conference, whichwas recorded electronically by the Court and bythe court reporter

retained by the parties.2 The Order memorializing and supplementing the rulings from the April 20,

2006 discovery/status conference was entered on April 25, 2006 (doc. 3865). Subparagraph eight

of the April 25, 2006 Order set forth the rulings on Plaintiffs’ Motion to Amend, Motion to Compel

Discovery, Motion for Sanctions:

For the general reasons stated on the record, Plaintiffs’ Motion to Amend

Scheduling Order, Motionto Compel Discovery, Motion for Sanctions (doc. 3580)

is denied in part and moot in part.

*

*

*

Plaintiffs’ Motion to Compel Discovery of RIF spreadsheets and emails in their

native format is denied with caveat that Plaintiffs may file a new motion specifically

identifying what they continue to contend Defendant should be compelled to

produce. Plaintiffs’ Motion for Sanctions is denied.

On May 9, 2006, Plaintiffs filed a Motion for Review and Objections to Portions of

Paragraph 8 of Magistrate’s Order of April 25, 2006 (doc. 4102).

1This portion of the motion was denied without prejudice to refiling as a separate motion. See doc. 3615.
2Beginning in early 2005, Plaintiffs began bringing their own court reporter to record the discovery/status conferences instead of obtaining CDs of the court’s electronic recording system. Apparently, no transcript from the April 20, 2006 discovery conference was provided to the District Judge in conjunction with the motion for review. The transcript of that discovery conference is attached as Exhibit A to this Order.
2

Case 2:03-cv-02200-JWL-DJW Document 4221 Filed 07/10/06 Page 3 of 5
On June 30, 2006, Judge Lungstrumissued a Memorandum and Order (doc. 4212) retaining Plaintiffs’ Motion for Review under advisement and remanding the underlying Motion to Compel Discovery to the magistrate judge based on the lack of a sufficient record. The Memorandum and Order directs the Magistrate Judge to render factual findings sufficient to enable the District Judge to perform a meaningful review of the decision on the Motion to Compel Discovery.
In accordance with this directive, the undersigned Magistrate Judge respectfully submits the following factual findings that were made at the April 20, 2006 discovery/status conference but were regrettably not included in the April 25, 2006 Order.
During the April 20, 2006 discovery/status conference, the Magistrate Judge took up Plaintiffs’ requests to compel Defendant to produce all RIF spreadsheet documents in native format; to compel Defendant to produce transmittal and other RIF-related e-mails in native format; for sanctions against Defendant for its conduct in failing to produce spreadsheet materials in native format and the re-production of more than 200,000 pages of spreadsheet materials that had already been produced in native format; and for sanctions against Defendant for failing to timely produce spreadsheet materials as required by the Court’s May 5, 2005 Show Cause Order and other Show Cause Orders. In considering these requests, the Magistrate Judge asked defense counsel whether Defendant had produced the RIF spreadsheets and e-mails in native format. Defense counsel responded as follows:
We have produced - - at the time of the pleading, we had produced all decisionmaking type RIF spreadsheets in native format that we were aware of. As I have
3

Case 2:03-cv-02200-JWL-DJW Document 4221 Filed 07/10/06 Page 4 of 5
advised Plaintiffs, we found a few more. We’re planning on producing those, as well. But the answer is, yes.3
Based onthis representation, the Magistrate Judge found that Defendant had met itsobligation
unless Plaintiffs had a specific issue with a specific spreadsheet or e-mail that they believed Defendant
had not produced in native format. At this point in the conference, Plaintiffs’ counsel asserted that
Defendant had not produced transmittal e-mails in native format and had not produced other e-mail
attachments at all. Counsel stated:
The e-mails have never been produced in native format. So our motion was acknowledging the spreadsheets, but the e-mails have never been produced in native format. We were addressing some of the difficulties in matching up, and we’ve shown you some of those. So the two things in the motion that have not been produced yet electronically that Defendant contests, are the transmittal e-mails, No. 1; and No. 2, there are all these other attachment spreadsheets and attachment documents that we talked about in the motion, that are listed on the spreadsheet reports. Besides the one spreadsheet, there’s like nine others. And we’ve listed and attached those that show there’s - - -
So the two issues are, transmittal e-mails, and other attachments that were never produced, electronically or otherwise. So that would be the only two things. And I think that would require a glancing at the motion, now that I’ve added some complications there, so - - -.4
Notwithstanding Plaintiffs’ assertion that Defendant had never produced transmittal e-mails
in native format or other e-mail attachments at all, the Magistrate Judge found that Plaintiffs’ Motion
to Compel Discovery was too generic and overly broad, and ordered Plaintiffs to file a new motion
that addresses with specificity what they claim still needs to be produced by Defendant. After
effectively denying without prejudice Plaintiffs’ motion to compel, the Magistrate Judge denied
3Transcript of April 20, 2006 Discovery/Status Conference (“Tr.”) p. 17-18, l. 23-25, 1-4. 4Tr. p. 18-19, l. 21-25, 1-15.
4

Case 2:03-cv-02200-JWL-DJW Document 4221 Filed 07/10/06 Page 5 of 5

Plaintiffs’ request for sanctions, advising the parties that “I think the best approach so far is to avoid those when we can.”5
RESPECTFULLY SUBMITTED, Dated in Kansas City, Kansas on this 10th day of July, 2006.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

5Tr. p. 20, l. 12-13. 5

 
 Case 2:03-cv-02200-JWL-DJW Document 4314 Filed 09/13/06 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al., Plaintiffs,
v. SPRINT/UNITED MANAGEMENT CO.,
Defendant.

Case No. 03-2200-JWL-DJW

MEMORANDUM AND ORDER Plaintiff Shirley Williams brings this lawsuit on behalf of herself and others similarly situated asserting that her age was a determining factor in Defendant’s decision to terminate her employment during a reduction-in-force (“RIF”). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. The matter is currently before the Court on Plaintiffs’ Motion for Reconsideration (doc. 4235). Plaintiffs move the Court for an Order reconsidering and/or clarifying its July 10, 2006 Order (doc. 4221) by adding further findings of fact. For the reasons set forth below, the motion is denied. I. Standard for a Motion for Reconsideration Pursuant to D. Kan. Rule 7.3(b), motions seeking reconsideration of non-dispositive orders must be based on “(1) an intervening change in controlling law, (2) the availability of new evidence, or (3) the need to correct clear error or prevent manifest injustice.”1 A motion to reconsider is not a second chance for the losing party to ask the Court to revisit

1The Tenth Circuit has adopted the same standard. See, e.g., Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000).

Case 2:03-cv-02200-JWL-DJW Document 4314 Filed 09/13/06 Page 2 of 5
issues already addressed or to consider new arguments and facts that could have been presented originally.2 Nor is a motion to reconsider to be used as “a second chance when a party has failed to present it strongest case in the first instance.”3 Reconsideration may, however, be appropriate “where the court has misapprehended the facts, a party’s position, or the controlling law.”4 II. Facts Relevant to this Motion
On February 15, 2006, Plaintiffs filed a multi-part motion titled Plaintiffs’ Motion to Amend Scheduling Order, Motion to Compel Discovery, Motion for Sanctions, and Appeal From Paragraph (3) of Judge Waxse’s 2/8/06 Order, which sought, inter alia, to compel Defendant to produce all RIF spreadsheet documents and transmittal and RIF-related emails in native format. The motion also requested sanctions against Defendant for its conduct in failing to produce spreadsheet materials in native format and the re-production of more than 200,000 pages of spreadsheet materials that had already been produced in native format and for failing to timely produce spreadsheet materials as required by the Court’s May 5, 2005 Show Cause Order and other Show Cause Orders.
The undersigned Magistrate Judge orally ruled on Plaintiffs’ motion at the April 20, 2006 discovery/status conference. The Order memorializing and supplementing the rulings from the April 20, 2006 discovery/status conference was entered on April 25, 2006 (doc. 3865). Subparagraph eight of the April 25, 2006 Order set forth the rulings on Plaintiffs’ Motion to Amend Scheduling Order, Motion to Compel Discovery, Motion for Sanctions:
For the general reasons stated on the record, Plaintiffs’ Motion to Amend
2Servants, 204 F.3d at 1012; Sonnino v. Univ. of Kan. Hosp. Auth., 221 F.R.D. 661, 664 (D. Kan. 2004).
3Sonnino, 221 F.R.D. at 664 (citations omitted). 4Id.; Servants, 204 F.3d at 1012.
2

Case 2:03-cv-02200-JWL-DJW Document 4314 Filed 09/13/06 Page 3 of 5

Scheduling Order, Motion to Compel Discovery, Motion for Sanctions (doc.

3580) is denied in part and moot in part.

*

*

*

Plaintiffs’ Motion to Compel Discovery of RIF spreadsheets and emails in their

native format is denied with caveat that Plaintiffs may file a new motion

specifically identifying what they continue to contend Defendant should be

compelled to produce. Plaintiffs’ Motion for Sanctions is denied.

Plaintiffs filed a Motion for Review and Objections to Portions of Paragraph 8 of

Magistrate’s Order of April 25, 2006 (doc. 4102).

On June 30, 2006, Judge Lungstrum issued a Memorandum and Order (doc. 4212) retaining

Plaintiffs’ Motion for Review under advisement and remanding the underlying Motion to Compel

Discovery to the magistrate judge based on the lack of a sufficient record. The Memorandum and

Order directed the Magistrate Judge to render factual findings sufficient to enable the District Judge

to perform a meaningful review of the decision on the Motion to Compel Discovery.

In accordance with this directive, the Magistrate Judge entered an Order on July 10, 2006,

that set forth additional factual findings that were made orally at the April 20, 2006 discovery/status

conference, but were not included in the April 25, 2006 Order.

III. Relief Sought

In their Motion for Reconsideration, Plaintiffs request that the Court reconsider and/or clarify

its July 10, 2006 Order by making further specific findings of fact with regard to certain discovery

conduct of Defendant in this case. Plaintiffs propose forty-three additional findings of fact for the

Court to incorporate into its July 10, 2006 Order. Plaintiffs’ proposed additional findings of fact set

forth Plaintiffs’ version of the history of discovery in this case and of Defendant’s alleged discovery

abuses.

Defendant urges the Court to deny Plaintiffs’ motion. It argues that the Court’s July 10,

3

Case 2:03-cv-02200-JWL-DJW Document 4314 Filed 09/13/06 Page 4 of 5
2006 Order contains no decision to reconsider – it simply finds additional facts to support the decisions in the April 25, 2006 Order. It asserts that Plaintiffs have offered no authority that requesting additional findings of fact is an appropriate use of a motion to reconsider. Defendant further claims that Plaintiffs have waived the right to ask for any reconsideration of the Court’s April 25, 2006 decision. It also claims that reconsideration is not a vehicle to rehash old arguments or raise new ones. Finally, it argues that the Magistrate Judge’s original decision to deny sanctions was the correct one.
The standard for motions seeking reconsideration of non-dispositive orders is wellestablished. Motions seeking reconsideration of non-dispositive orders must be based on one of three grounds: “(1) an intervening change in controlling law, (2) the availability of new evidence, or (3) the need to correct clear error or prevent manifest injustice.”5 Although Plaintiffs’ instant motion correctly recites this legal standard, Plaintiffs fail to move for reconsideration based on any of these grounds. Even had Plaintiffs argued that the additional factual findings were necessary to correct clear error or prevent manifest injustice, Plaintiffs have not explained how these proposed findings of facts, even if the Court accepted them as true, are necessary to correct clear error or prevent manifest injustice of the Court’s July 10, 2006 Order. The July 10, 2006 Order merely further memorialized the oral rulings made by the Magistrate Judge at the April 20, 2006 discovery/status conference.
Moreover, the findings of fact proposed by Plaintiffs appear directed toward the Court’s denial of their motion for sanctions at the April 20, 2006 discovery/status conference. The Court’s
5The Tenth Circuit has adopted the same standard. See, e.g., Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000).
4

Case 2:03-cv-02200-JWL-DJW Document 4314 Filed 09/13/06 Page 5 of 5

subsequent Order denying their motion for sanctions was entered on April 25, 2006. Thus, to the extent Plaintiffs are seeking reconsideration of the Magistrate Judge’s ruling on their motion for sanctions, they are out of time to do so. For these reasons, the Court therefore finds that Plaintiffs’ Motion for Reconsideration, which proposes additional findings of fact with regard to the denial of sanctions, contains no decision to reconsider but merely seeks for the Court to add Plaintiffs’ proposed findings of facts to a prior order. The Court therefore rejects Plaintiffs’ request to reconsider its July 10, 2006 Order to make further findings of fact.
IT IS THEREFORE ORDERED that Plaintiffs’ Motion for Reconsideration (doc. 4235) is denied.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 13th day of September, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

5

 
 Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO.,

Defendant.

MEMORANDUM AND ORDER Plaintiff Shirley Williams brings this lawsuit on behalf of herself and others similarly situated asserting that her age was a determining factor in Defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. In a Memorandum and Order dated July 1, 2006, and after a full evidentiary hearing on the

issue, this Court held that sixty-five adverse impact/due diligence documents inadvertently disclosed by Defendant to Plaintiffs are protected from disclosure by the attorney-client privilege. The matter is currently before the Court on Plaintiffs’ Motion for Reconsideration (doc. 4234). For the reasons stated below, Plaintiffs' Motion will be denied.

Standard for a Motion to Reconsider Pursuant to D. Kan. Rule 7.3, motions seeking reconsideration of non-dispositive orders must be based on “(1) an intervening change in controlling law, (2) the availability of new evidence, or (3) the need to correct clear error or prevent manifest injustice.”1

1The Tenth Circuit has adopted the same standard. See, e.g., Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000).

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 2 of 17
A motion to reconsider is not a second chance for the losing party to ask the Court to revisit issues already addressed or to consider new arguments and facts that could have been presented originally.2 Nor is a motion to reconsider to be used as “a second chance when a party has failed to present it strongest case in the first instance.”3 Reconsideration may, however, be appropriate “where the court has misapprehended the facts, a party’s position, or the controlling law.”4
To that end, Plaintiffs seek reconsideration on the following grounds: I. Reconsideration is necessary to correct clear error or prevent manifest injustice in that
A. The Court failed to consider the following arguments presented by Plaintiffs: 1. Portions of the adverse impact documents found to be attorney-client privileged contain only non-privileged underlying facts. 2. Many documents found by the Court to be protected by attorney-client privilege were created before Jill Ferrel’s October 5, 2001 Memo. 3. Many documents found by the Court to be protected by attorney-client privilege had a business purpose independent of any legal purpose. 4. Defendant claims only work product protection in their privilege log for documents found by the Court to be protected by the attorney-client privilege. 5. Testimony regarding three of the adverse impact documents was not based on personal knowledge of the witness who testified about those documents.
B. There is insufficient evidence to support the Court's factual finding that 1. adverse impact documents ("the communications") were made in confidence; 2. adverse impact documents ("the communications") were sent to counsel.
C. The Court failed to apply the correct legal standard regarding attorney-client privilege.
II. Reconsideration is necessary due to availability of new evidence.
2Servants, 204 F.3d at 1012 3Sonnino v. Univ. of Kan. Hosp. Auth., 221 F.R.D. 661, 664 (D. Kan. 2004). 4Id.; Servants, 204 F.3d at 1012.
2

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 3 of 17
Analysis I. Reconsideration in Order to Correct Clear Error or Prevent Manifest Injustice
A. Plaintiffs’ Claim that the Court Failed to Address Selected Arguments 1. Plaintiffs' assertion that portions of the adverse impact documents found to be attorney-client privileged contain only non-privileged facts.
Plaintiffs assert the July 1, 2006 Order does not address Plaintiffs’ argument that a portion of each adverse impact document found by the Court to be protected from disclosure by the attorneyclient privilege contains non-privileged data compilations gathered from non-privileged documents; thus, those portions of the privileged documents should be deemed discoverable regardless of whether other portions of the page are privileged.
As a preliminary matter, the Court notes this particular argument -- that selected portions of the inadvertently disclosed documents do not contain adverse impact analyses, but only underlying factual data -- is inappropriately made by Plaintiffs for the first time on reconsideration and will be denied for that reason.
With that said, however, the Court finds the July 1, 2006 Memorandum and Order adequately addresses the broader issue of attorney-client privileged communications to find that the information within the adverse impact documents -- whether extracted from the Master and RIF Lists or calculated utilizing a formula provided by counsel -- consists of a communication made in confidence for the purpose of obtaining legal advice:
Defendant maintains it conducted a statistical analysis comparing the demographic data (gender, race and age) of employees targeted for lay off to the demographic data of those who would be retained. Defendant further maintains this “adverse impact” or “due diligence” analysis was performed at the specific request of its attorneys for the purpose of obtaining legal advice regarding the statistical impact on the various groups under the discrimination laws. Defendant maintains that sixty-one of the
3

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 4 of 17
inadvertently produced documents are such statistical analyses undertaken at the direction of attorneys. Accordingly, Defendant argues the “adverse impact” and “due diligence” documents and information inadvertently produced are protected from disclosure by the attorney-client privilege and thus must be returned.
Plaintiffs disagree, arguing the “adverse impact” and “due diligence” documents are not protected from disclosure by the attorney-client privilege because they are not analyses undertaken at the direction of attorneys but instead are merely data compilations independently generated and utilized by employees within Defendant’s Human Resource Department.5
* * * * *
Applying [the] legal standards to the facts presented, the Court concludes the adverse impact documents inadvertently disclosed by Defendant and submitted for in camera review by the Court are protected from disclosure by the attorney-client privilege. In other words, the evidence presented by Defendant sufficiently demonstrates that the adverse impact/due diligence documents were generated at the direction of counsel – pursuant to the Ferrel Memo – for the purpose of rendering legal advice and, after such generation, were then provided to counsel for analysis.6
* * * * *
The Court finds Defendant’s due diligence matrices and adverse impact spreadsheets were made at the direction of Defendant’s Law Department in order to secure legal advice from counsel and were not mere compilations of non-privileged business data and underlying facts. In support of this finding, the Court relies on the October 5, 2001 Ferrel Memo submitted in camera and filed under seal, which specifically directs Defendant’s HR Department to gather designated information so that its Law Department can perform adverse impact analyses in connection with Defendant’s RIF. The evidence establishes that Defendant’s HR personnel followed the specific methodology outlined by Ferrel in her October 5, 2001 memo in creating these documents. More specifically, the methodology outlined by the Ferrel Memo included data entry in various combinations utilizing a formula and format provided by the Law Department.7
* * * * *
5July 1, 2006 Memorandum and Order at pp. 6-7 (doc. 4213).
6Id. at p. 12.
7Id. at p. 13.
4

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 5 of 17
Simply put, the evidence demonstrates that the written communications here – the due diligence matrices and adverse impact spreadsheets – were made at the direction of the Law Department in order to secure legal advice from counsel and were not mere compilations of non-privileged business data and underlying facts [citations omitted]. Notably, Defendant has not made a claim of privilege for – and, in fact, has produced – the relevant, underlying data (e.g., Master List and RIF List) from which Plaintiffs may make their own adverse impact analysis using the “four-fifths rule” included within the EEOC Guidelines. And, even if – as a result of legal advice – an employee was added or deleted from the RIF List, Plaintiffs still are free to inquire of the actual decision makers as to the basis of their termination decisions.8 It makes no difference that portions of these attorney-client privileged written communications contain non-privileged data extracted from the Master List and the RIF List. First of all, there is no dispute that the Master and RIF Lists – and thus the entirety of the non-privileged data at issue – already have been produced to Plaintiffs. Moreover, the evidence shows the information at issue was extracted from the Master and RIF Lists and thereafter placed in the adverse impact analyses document in order to facilitate the giving of legal advice by counsel. As noted in the Court’s July 1, 2006 Order, “[T]he protection of the privilege extends only to communications and not to facts. A fact is one thing and a communication concerning that fact is an entirely different thing.”9 More specifically, “[t]he client cannot be compelled to answer the question, ‘What did you say or write to the attorney?’ but may not refuse to disclose any relevant fact within his knowledge merely because he incorporated a statement of such fact into his communication with his attorney.”10
8Id. at pp. 15-16. 9Upjohn Co. v. United States, 449 U.S. 383, 395-96 (1981) (emphasis in original) (quoting Philadelphia v. Westinghouse Elec. Corp., 205 F. Supp. 830, 831 (E.D. Pa. 1962). 10Id. at 396.
5

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 6 of 17

2. Many documents found by the Court to be protected by attorney-client privilege were created before Jill Ferrel’s October 5, 2001 Memo

Plaintiffs request reconsideration of the Court’s finding on grounds that the Court did not

discuss evidence submitted by Plaintiffs regarding creation dates for some of the documents at issue.

More specifically, Plaintiffs argue the following evidence indisputably establishes some of the

adverse impact documents were created before the October 5, 2001 Ferrel memorandum:

C

the metadata reflects that some of the documents at issue were created prior to the

October 5, 2001 Ferrel Memo;

C

reconciling the "employee start date" information with the "years of service"

information for each employee reflects that some of the documents were created prior

to the October 5, 2001 Ferrel Memo; and

C

privilege log entries reflect that many of the documents were created prior to the

October 5, 2001 Ferrel Memo.

The Court is not persuaded by Plaintiffs’ argument. As a preliminary matter, the adverse

impact documents at issue were created as “tabs” or sub-documents of the same, larger electronic

document, which also contained the Master List and the RIF List.11 Thus, these three separate Excel

worksheets (Master List, RIF List and Adverse Impact Matrix) were merely pages within one larger

electronic document. Witnesses testified it was only after being directed by counsel to create the

adverse impact analyses that HR personnel used the Master Lists and the RIF Lists to create the

adverse impact documents.12

11Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at p. 26, lines 7-19 (doc. 3742); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held 3/10/2006 at p. 114, line 2 through 115, line 2 (doc. 3820).
12Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at p. 26, lines 7-19, p. 30, line 11 through p. 31, line 10, and p. 52 (doc. 3742); Testimony of Jim Kissinger, Sealed Transcript of Proceedings Held 3/10/2006 at p. 114, line 25 through 115, line 15 (doc. 3820); Testimony of Deborah Sprayberry, Sealed Transcript of Proceedings Held 3/10/2006 at p. 131 (doc. 3820).
6

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 7 of 17
Thus, although metadata, employee “start” dates and various privilege log entries reflect a pre-Ferrel memorandum creation date for the larger electronic document, such evidence does not persuade the Court that the actual adverse impact “sub-document” at issue was created prior to the Ferrel memo. Plaintiffs offer no evidence that the Master and RIF Lists were created at the same time as the adverse impact documents. Conversely, there is a great deal of evidence demonstrating that the Master List and the RIF List had numerous uses separate and apart from the adverse impact documents and thus were created before the adverse impact matrices.13
3. Many documents found by the Court to be protected by attorney-client privilege had a business purpose independent of any legal purpose.
In their Motion for Reconsideration, Plaintiffs also argue the Court failed to address their argument that many of the documents found by the Court to be protected by attorney-client privilege had a business purpose within the human resources department independent of any legal purpose. The Court disagrees, finding that the July 1, 2006 Memorandum and Order specifically addresses this issue. First of all, the Ferrel Memo is quite explicit about the legal purposes for which the adverse impact documents are being requested.14 Moreover, there were several witnesses at the hearing who testified that the adverse impact documents were generated for the purpose of counsel’s
13Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at pp. 26, 28-29, 30-31, 32-33, 36-37, 40-42, 44-45, 57-66 (doc. 3742); Excerpt from Eric Rice Deposition, Sealed Hearing Exhibit DDD at pp. 7-18; Testimony of Scott Winkler, Jim Kissinger, Deborah Sprayberry and Gina Eisler, Sealed Transcript of Proceedings Held 3/10/2006 at pp. 8-9, 57-59, 74, 114-115, 129-133, 160, 165-169 (doc. 3820); Sealed Hearing Exhibit GGG (binder containing privileged emails submitted to the Court for in camera review).
14The Ferrel Memo, Sealed Hearing Exhibit FFF. 7

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 8 of 17
rendering legal advice.15 Finally, the Court found that adverse impact documents ultimately were transmitted and/or delivered to Defendant’s Legal Department for the purpose of rendering legal advice.16
Conversely, Plaintiffs offer no evidence that the adverse impact documents at issue were generated for any purpose other than rendering legal advice. Instead, Plaintiffs offer testimony that Defendant sometimes give business decisions a preliminary “sore thumb” review and attempts, as a good business practice, to make sure that business decisions do not appear discriminatory. The Court finds that this evidence is immaterial to the issue presented: whether the adverse impact documents at issue were communications made in confidence for the purpose of obtaining legal advice.
4. Defendant claims only work product protection in their privilege log for documents found by the Court to be protected by the attorney-client privilege
Plaintiffs next claim the Court erred in finding all adverse impact documents protected from disclosure by the attorney-client privileged when the evidence presented by Plaintiffs showed that some of the documents were never listed on a privilege log and, out of those that were, some were designated by Defendant in the log to be protected only by the work product doctrine. Plaintiffs
15Testimony of Scott Winkler, Sealed Transcript of Proceedings Held on 3/02/2006 at pp. 28, 38-39, 42, 45, 52 (doc. 3742); Testimony of Scott Winkler, Jim Kissinger, Deborah Sprayberry, Sealed Transcript of Proceedings Held 3/10/2006 at pp. 57, 59, 73, 131, 165 (doc. 3820).
16At the hearing, Defendant submitted Exhibit GGG to the Court in camera. More specifically, Exhibit GGG is a binder containing privileged e-mails establishing that the majority of the adverse impact documents were e-mailed directly to Defendant’s counsel. Defendant presented further evidence at the hearing that adverse impact documents often were personally delivered during meetings with counsel on Defendant’s campus. Testimony of Scott Winkler, Jim Kissinger, Deborah Sprayberry, Sealed Transcript of Proceedings Held on 3/10/2006 at pp. 57, 73, 131-132, 165 (doc. 3820); Excerpt from Eric Rice Deposition, Sealed Hearing, Exhibit DDD at pp. 6-7.
8

Case 2:03-cv-02200-JWL-DJW Document 4315 Filed 09/13/06 Page 9 of 17
make this claim of error with regard to two categories of adverse impact documents: first, those specific and identifiable adverse impact documents that were part of the inadvertent disclosures at issue; and second, those documents similar to the inadvertently produced adverse impact/due diligence documents that are currently being withheld by Defendant.
Although not specifically addressed in its July 1, 2006 Memorandum and Order, the Court notes that it did consider -- and ultimately reject -- Plaintiffs' claims here. The Court further notes, however, that the Court did not explain its conclusions on the issue. Thus, while the Court finds that there is no reason to grant reconsideration of this issue, the Court will explain its reasoning in an effort to be thorough.
The starting point is Fed. R. Civ. P. 26(b)(5), which sets forth the rule regarding notification when a claim of privilege is asserted:
When a party withholds information that is otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.17
a. Inadvertently Disclosed Documents As a preliminary matter, the Court notes that the Rule 26(b)(5) privilege notification requirements are not applicable to the inadvertently disclosed documents here because the documents at issue were not withheld pursuant to claim of privilege but, instead, were actually produced. Moreover, although privilege logs are the manner in which most litigants provide required information about allegedly privileged documents, Rule 26(b)(5) does not specifically require a privilege log. The rule requires only that the claim of privilege or protection be made expressly and
17Fed. R. Civ. P. 26(b)(5). 9

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that it “describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. or which a privilege is claimed withheld pursuant.”18 Here, the adverse impact documents at issue were actually produced to Plaintiffs by Defendant. Because the documents were inadvertently produced and then recalled on grounds of privilege, and because Plaintiffs were thus able to review the allegedly protected documents in their entirety, the Court finds that all of the disclosure requirements of Rule 26(b)(5) have been satisfied with regard to the inadvertently produced documents.
b. Documents “Similar” to Inadvertently Produced Documents In its July 1, 2006 Memorandum and Order, and in conjunction with its finding that the inadvertently disclosed documents were protected from disclosure by the attorney-client privilege, the Court denied Plaintiffs’ request for production of all documents similar to the inadvertently produced adverse impact/due diligence documents.19 Plaintiffs assert this decision was erroneous because Defendant asserts only work product protection – and not protection based on the attorneyclient privilege – for many of the “document[s] similar to the inadvertently produced adverse impact/due diligence documents.” Thus, Plaintiffs argue Defendant has waived the attorney-client privilege for these documents. Although the Court acknowledges that there may be some adverse impact documents listed in the privilege log for which Defendant did not designate protection based on the attorney-client privilege, the Court finds -- given the circumstances presented -- a sanction of waiver is too harsh.
18Id. 19July 1, 2006 Memorandum and Order at p. 27 (doc. 4213).
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It is true that Fed. R. Civ. P. 26(b)(5) requires a party to categorically describe the privilege asserted20. It is also true that failure to comply with Fed. R. Civ. P. 26(b)(5) may result in waiver of the attorney-client privilege and/or work-product protection.21 Although this result is not mandated by the federal rules, the Advisory Committee contemplated the sanction: “[t]o withhold materials without [providing notice as described in Rule 26(b)(5) ] is contrary to the rule, subjects the party to sanctions under Rule 37(b)(2), and may be viewed as a waiver of the privilege.”22 Acknowledging the harshness of a waiver sanction, however, courts have reserved such a penalty for only those cases where the offending party committed unjustified delay in responding to discovery. Minor procedural violations, good faith attempts at compliance and other such mitigating circumstances bear against finding waiver.23
Here, the issue of whether adverse impact/due diligence documents are protected from disclosure has long been a highly disputed issue subject to literally hundreds of pages of briefing over the course of the last two years. Based on the circumstances presented, the Court finds a sanction of waiver too harsh; thus, Defendant is not deemed to have waived any protection for documents listed in its privilege log based on its designation of adverse impact/due diligence documents as protected by only work product and not attorney-client privilege.
20Fed. R. Civ. P. 26(b)(5). 218 Charles Alan Wright, Federal Practice and Procedure § 2016.1, at 228-29 (2d ed.1994). 22Fed. R. Civ. P. 26(b)(5) advisory committee’s note (1993). 23See First Sav. Bank, F.S.B. v. First Bank Sys., Inc., 902 F. Supp. 1356, 1361-63 (D.Kan.1995) (collecting cases), rev'd on other grounds, 101 F.3d 645 (10th Cir.1996).
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5. Testimony regarding three of the adverse impact documents was not based on personal knowledge of the witness who testified about those documents
Plaintiffs next contend the Court erred in failing to address their argument that the testimony regarding three of the adverseimpact documents was not based on the witnesses' personal knowledge of those documents. The Court rejects Plaintiffs’ contention.
As the parties noted to the Court at the outset of this review process, the Court's decision regarding whether the sixty-one inadvertently disclosed adverse impact documents are protected from disclosure by the attorney-client privilege is a decision that would likely be applied to the additional 1000+ adverse impact documents not inadvertently disclosed.24 The parties never requested, nor did the Court ever intend to require, that an evidentiary foundation be established for each and every document at issue. The purpose of the hearing was to establish whether Defendant could prove the elements of the attorney-client privilege for the adverse impact/due diligence documents.
The fact that some of the witnesses who testified may not personally have created or received the documents at issue does not equate to a lack of knowledge regarding the purpose of the documents. The Court considered the Ferrel Memo itself (which mirrors the documents at issue) and the testimony regarding other adverse impact documents in concluding that all of the adverse impact documents inadvertently disclosed were protected from disclosure by the attorney-client privilege. Simply put, Plaintiffs’ argument here is without merit.
24Transcript of February 16, 2006 Hearing, (doc. 3629) at pp. 5-9. 12

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B. Plaintiffs' Claim of Insufficient Evidence to Support the Court's Factual Findings 1. Plaintiffs' claim of insufficient evidence to support the Court's finding that the adverse impact documents ("the communications") were made in confidence
Plaintiffs assert the Court factually erred in finding that Defendant treated the adverse impact documents as confidential. First, Plaintiffs claim the Court’s citation to pages 24 and 25 within Eric Rice’s deposition transcript does not support the proposition for which it was cited – that the confidentiality of the adverse impact documents was protected by a password available only to legal counsel and human resources personnel. Upon review of the referenced citation, however, the Court notes the Memorandum and Order cites to pages 24 and 25 of Exhibit DDD, which is not the deposition transcript, but instead is a summary of the Eric Rice’s deposition submitted as evidence at the hearing. Accordingly, the evidence cited by the Court fully supports the Court’s finding that the confidentiality of the adverse impact documents was protected by a password available only to legal counsel and human resources personnel.
Next, Plaintiffs claim the confidential marks on most of the documents should not be taken into account because they appear in an Excel footer as opposed to the body of the document. The Court rejects this new argument – raised for the first time in conjunction with the pending motion – on grounds that it is not an appropriate argument for reconsideration. A motion to reconsider is not to be used as “a second chance when a party has failed to present it strongest case in the first instance.”25 With that said, the Court would reject the argument even if it was not new; in other words, such argument in and of itself does not negate the Court’s original finding that most of the documents were marked confidential – regardless of whether the marking was in the footer.
25Sonnino, 221 F.R.D. at 664 (citations omitted). 13

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Plaintiffs next claim the Court erred in its confidentiality finding given evidence presented that the adverse impact documents were received by two human resources employees who may have been part of the legal process but did not specifically “need” to receive them in order for counsel to give legal advice. The Court rejects this claim. The Court supported its finding of confidentiality with substantial evidence, including the use of a password available only to the legal and human resources departments, “confidential” markings, the Ferrel Memo and various witnesses who testified about the information’s confidential nature.26 Even if, as Plaintiffs argue, it was not categorically imperative for these two particular human resources managers working on the RIFs to transmit the privileged documents to counsel, this is not enough to reject the conclusion that these two individuals received the documents during the course of giving or receiving of legal advice. The facts presented by Plaintiffs are not enough to overcome the Court’s finding, supported by evidence, that Defendant kept the documents confidential.
2. Plaintiffs' claim of insufficient evidence to support the Court's finding that the adverse impact documents ("the communications") were sent to counsel
In this point, Plaintiffs assert the Court erred in specifically finding that every single adverse impact document was ultimately provided to counsel. Upon reconsideration and review of the hearing transcripts, the Court agrees and finds that there may not have been testimony to establish that each and every one of the sixty-one identical adverse impact documents was forwarded to counsel. For the reasons stated below, however, the Court finds adequate evidence to demonstrate that these adverse impact documents are protected from disclosure by the attorney-client privilege.
Almost identical to an issue thoroughly discussed in the Court’s February 1, 2006
26July 1, 2006 Memorandum and Order at p. 17 (doc. 4213). 14

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Memorandum and Order, the question presented here is the extent to which legal counsel must be involved in a communication in order to establish the elements required to invoke the attorney-client privilege. After a thorough discussion of the facts presented and the applicable law, this Court specifically held in the February 1, 2001 opinion that the essential elements of the attorney-client privilege do not necessarily require an attorney to have received the document at issue in order to maintain the privilege. “What is vital to the privilege is that the communication be made in confidence for the purpose of obtaining legal advice from the lawyer.”27
Thus, the Court finds that, although there may not have been testimony to establish that each and every one of the adverse impact documents was forwarded to counsel, Defendant presented adequate evidence – as specifically described in this Court’s July 1, 2006 Memorandum and Order – to demonstrate that these adverse impact documents reflect communications made in confidence for the purpose of obtaining legal advice from a lawyer.
C. Plaintiffs' General Claim that the Court Failed to Apply the Correct Legal Standard regarding the Attorney-Client Privilege
The Court rejects Plaintiffs’ general claim that the Court failed to recognize several legal principles of the attorney-client privilege. More specifically, the Court finds it explicitly and repeatedly considered, explained, and otherwise discussed (a) that the privilege protects only confidential communications made for the purpose of legal advice; (b) that the privilege protects communications, not the underlying facts; and (c) that Defendant has the burden of establishing all elements of the privilege.
The Court also rejects Plaintiffs claim that they are entitled to reconsideration of the Court’s finding that Defendant’s good faith defense does not waive the attorney-client privilege. Plaintiffs
27United States v. Kovel, 296 F.2d 918, 922 (2d Cir. 1961). 15

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provide no authority to support their claim that an assertion of good faith by Defendant in its pleadings waives the attorney-client privilege. This claim is identical to the argument previously made by Plaintiffs, an argument the Court already has considered and rejected. II. Plaintiffs' Claim that Reconsideration is Necessary Due to Availability of New Evidence
Plaintiffs’ final argument in support of reconsideration is that they have new evidence to support their position. Although it is true that new evidence may be appropriate in a motion to reconsider, Plaintiffs’ argument here must fail. First and foremost, there is no indication that the “new evidence” is actually new. Plaintiffs admittedly have had the email at issue since December 2005. The new evidence rule does not apply to evidence that was previously available, but not presented in the original briefing.28
Second, even if Plaintiffs had originally presented the email, the Court finds the context of the email in question refers to feedback by human resources regarding a manager’s evaluation of employee performance. That Defendant attempted, one day prior to the day the Ferrel Memo was distributed, to make sure that a business decision did not appear discriminatory is immaterial to the actual issue presented: whether the actual adverse impact documents at issue were created at the direction of the legal department for the purpose of rendering legal advice.
Conclusion Based on the discussion set forth above, it is hereby ordered that Plaintiffs’ Motion for Reconsideration (doc. 4234) is denied.
28Sonnino, 221 F.R.D. at 664 (“It is well settled that a motion to reconsider is not a second chance for the losing party to ask the Court to revisit issues already addressed or to consider new arguments and supporting facts that could have been presented originally.”) (citations omitted).
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IT IS SO ORDERED. Dated in Kansas City, Kansas on this 13th day of September, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

17

 
 Case 2:03-cv-02200-JWL-DJW Document 4326 Filed 09/25/06 Page 1 of 20

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,

CIVIL ACTION No. 03-2200-JWL-DJW

Defendant.

MEMORANDUM AND ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant's decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Plaintiffs’ Motion to Compel Responses to Plaintiffs’ Eighth and Ninth Requests for Production of Documents (doc. 3652). For the reasons set forth below, the motion is granted in part and denied in part. I. History of the Discovery Dispute A. Plaintiffs’ Eighth Request for Production of Documents Relevant to this motion, Plaintiffs served their Eighth Request for Production of Documents

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Directed to Defendant on March 4, 2005.1 Defendant served its responses and objections to Plaintiffs’ Eighth Request for Production of Documents on April 21, 2005.2 At the May 19, 2005 discovery conference, counsel for Plaintiffs advised the Court that he sent Defendant a golden rule letter with respect to Plaintiffs’ Eighth Requests on May 11, 2005.3 Plaintiffs’ counsel reported to the Court that the parties had insufficient time to address Defendant’s objections to Plaintiffs’ Eighth Requests, but planned on discussing them in the near future. The parties proposed additional briefing on Defendant’s objections to Plaintiffs’ Seventh Interrogatories and Eighth Requests. This additional briefing was submitted to the Court on May 26, 2005, and then supplemented on June 1 and 2, 2005.
At the June 6, 2005 discovery conference, the Court addressed Plaintiffs’ Eighth Request Nos. 28 and 29.4 It sustained Defendant’s overly broad objections to both requests, sustained Defendant’s objection to producing the contracts requested by No. 28, and overruled Defendant’s relevancy objection to Request No. 29. After ruling on these objections, the Court ordered Defendant to provide Plaintiffs with certain information.
The parties continued to report the status of their conferring efforts on the remaining unresolved Eighth Requests during discovery conferences with the Court on August 2, 2005. At the August 18, 2005 discovery conference, the Court set a September 1, 2005 deadline for the parties to advise the Court whether they had completed their conferring process with regard to Plaintiffs’
1See Certificate of Service (doc. 2737). 2See Certificate of Service (doc. 2822). 3See May 19, 2005 Transcript (doc. 2915) at p. 39. 4See June 9, 2005 Transcript at p. 55-56, and June 16, 2005 Order (doc. 2953) ¶ 4-5.
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Eighth Requests.5 Plaintiffs updated the Court with the parties’ conferring efforts on Plaintiffs’ Eighth Requests at subsequent discovery conferences with the Court on September 1, September 19, October 6, October 20, November 17, December 15, 2005, and January 5, 2006.
At the January 19, 2006 discovery conference, Plaintiffs requested that they be allowed to February 28, 2006 to file any motions to compel with regard to all documents and discovery responses of Defendant from June 2005 until that time. The Court granted Plaintiffs’ request for an extension of time to February 28, 2006 to file their motion to compel.6
B. Plaintiffs’ Ninth Request for Production of Documents Plaintiffs served their Ninth Request for Production of Documents on Defendant on May 18, 2005.7 After requesting and receiving an extension of time to respond, Defendant served its responses and objections to Plaintiffs’ Ninth Request for Production of Documents on June 27, 2005.8 On August 2, 2006, Plaintiffs reported in their listing of issues for the August 3, 2005 discovery conference that they had received Defendant’s responses to Plaintiffs’ Eighth Interrogatories and Ninth Requests for Production beginning on June 29, 2005, and a supplemental compact disk on July 1, 2005. Counsel for Plaintiffs advised the Court he sent Defendant a golden rule letter on August 1, 2005, and the parties were in the very early stages of the meet and confer process. Plaintiffs sought to discuss with the Court a timetable and process for ultimate resolution. At the August 3, 2005 discovery conference, the Court set an August 17, 2005 deadline for parties
5See August 19, 2005 Order (doc. 3174). 6See Order extending Plaintiffs’ time to file motions to compel (doc. 3541) and Jan. 19, 2006 Transcript (doc. 3546) at p. 85. 7See Certificate of Service (doc. 2903). 8See Certificate of Service (doc. 2973).
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to complete their conferring on this issue.9 At the next eight discovery conferences with the Court, held between August 18, 2005 and
January 5, 2006, Plaintiffs updated the Court with the parties’ progress, or lack thereof, as to their conferring efforts on Plaintiffs’ Ninth Requests. At the January 19, 2006 discovery conference, Plaintiffs requested that they be allowed to February 28, 2006 to file any motions to compel with regard to all documents and discovery responses of Defendant from June 2005 until that time. The Court granted Plaintiffs’ request for an extension of time to February 28, 2006 to file their motion to compel.10 II. Duty to Confer
Defendant urges the Court to deny Plaintiffs’ Motion to Compel based on Plaintiffs’ noncompliance with their duty to confer. Defendant claims that Plaintiffs filed the instant Motion to Compel with regard to the discovery requests without attempting to confer to resolve the issue extrajudicially, as required by Fed. R. Civ. P 37(a)(2)(A) and D. Kan. Rule 37.2.
Federal Rule of Civil Procedure 37 requires the movant to make a good faith attempt to resolve the discovery dispute before filing a motion to compel discovery responses. The motion to compel must include a certification of the effort to resolve the dispute.11
In conjunction with Fed. R. Civ. P. 37, District of Kansas Rule 37.2 provides: The court will not entertain any motion to resolve a discovery dispute pursuant to Fed. R. Civ. P. 26 through 37, . . . , unless counsel for the moving party has conferred or has made reasonable effort to confer with opposing counsel concerning the matter
9See Aug. 3, 2005 Transcript at p. 16-18. 10See Order extending Plaintiffs’ time to file motions to compel (doc. 3541) and Jan. 19, 2006 Transcript (doc. 3546) at p. 85. 11Id.
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in dispute prior to the filing of the motion. Every certification required by Fed. R. Civ. P. 26(c) and 37 and this rule related to the efforts of the parties to resolve discovery or disclosure disputes shall describe with particularity the steps taken by all counsel to resolve the issues in dispute. A “reasonable effort to confer” means more than mailing or faxing a letter to the opposing party. It requires that the parties in good faith converse, confer, compare views, consult and deliberate, or in good faith attempt to do so.12 When the dispute involves objections to requested discovery, parties do not satisfy the conference requirements simply by requesting or demanding compliance with the requested discovery.13 The parties must make genuine efforts to resolve the dispute by determining precisely what the requesting party is actually seeking; what responsive documents or information the discovering party is reasonably capable of producing; and what specific, genuine objections or other issues, if any, cannot be resolved without judicial intervention.14 Plaintiffs contemporaneously filed their Certificate of Consultation in Compliance with Local Rule (doc. 3654) along with the instant Motion to Compel. Plaintiffs state in their Certificate of Consultation that upon receipt of Defendant’s responses to Plaintiffs’ Eighth and Ninth Requests for Production of Documents, counsel for Plaintiffs immediately communicated with counsel for Defendant regarding Defendant’s refusal to provide complete responses to many of the requests. They further state that “[o]ver the course of the next several months, the parties exchanged correspondence, discussed the issues at various ‘meet and confer’ sessions and in telephone conferences. In spite of their best efforts, counsel for the parties were unable to resolve this
12D. Kan. Rule 37.2 (2006). 13Cotracom Commodity Trading Co. v. Seaboard Corp., 189 F.R.D. 456, 459 (D. Kan. 1999). 14Id.
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discovery dispute without court involvement.” Defendant argues that Plaintiffs filed the present Motion to Compel in lieu of responding to
Defendant’s invitation to discuss the requests. Defendant claims most of Plaintiffs’ discovery requests at issue were mentioned only in an August 1, 2005 letter and not spoken about until their appearance six months later in Plaintiffs’ Motion to Compel, despite the fact that Plaintiffs’ counsel acknowledged that additional discussion was required. Defendant claims it has produced documents pursuant to some of Plaintiffs’ requests and that counsel for Plaintiffs refused to discuss the requests at meet and confer sessions, even though they were on the agenda. Defendant notes that Plaintiffs made a specific attempt to resolve a small minority of the requests in December 2005, but then failed to respond to Defendant’s invitation to further discuss the matter.
Plaintiffs argue that they have satisfied their meet and confer obligations because they continually tried to discuss their discovery requests with Defendant and the only option following Defendant’s repeated refusal to produce was to file the instant Motion to Compel.
The Court determines that Plaintiffs have satisfied their meet and confer obligations required by D. Kan. Rule 37.2 and Federal Rule of Civil Procedure 37. In addition to attending twice monthly status conferences with the Court, counsel met every other week in meet and confer sessions to address their various discovery disputes. Defendant argues that Plaintiffs placed the requests at issue in the instant Motion to Compel on the agenda of their meet and confer sessions, but never addressed them in the sessions. Even if true, this does not dissuade the Court from its finding that Plaintiffs made reasonable efforts to confer with opposing counsel concerning the matter in dispute prior to the filing of the motion. Furthermore, in light of the parties’ history of bringing their discovery disputes to the Court for resolution, it is unlikely this motion would have been
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avoided even had counsel for the parties discussed at length every single disputed discovery request at the meet and confer sessions. The Court finds that Plaintiffs have sufficiently satisfied their duty to confer as set forth by Fed. R. Civ. P. 37 and D. Kan. Rule 37.2. III. Specific Discovery Requests at Issue
A. Plaintiffs’ Eighth Request Nos. 20 and 28-29 Plaintiffs move the Court for an order compelling Defendant to produce documents responsive to Plaintiffs’ Eighth Request Nos. 20, 28-29. As Defendant correctly points out, the Court has already ruled on Plaintiffs’ Eighth Request Nos. 28 and 29 in its June 16, 2005 Order (doc. 2953). In that Order, the Court sustained Defendant’s overly broad objections to Plaintiffs’ Eighth Request Nos. 28 and 29, sustained Defendant’s objection to producing the contracts requested by No. 28, and overruled Defendant’s relevancy objection to Request No. 29. The Court ordered Defendant to produce the following information responsive to Request Nos. 28 and 29: (1) the names of any employment agency, recruiter, headhunter, or executive job placement firm that it used; (2) a list of names of any employment agency, recruiter, headhunter, or executive job placement firm it used in lieu of having to produce the documents that would contain these names; and (3)any job descriptions that it provided to these employment agencies, recruiters, headhunters, executive job placement firms for any open position in any department within Sprint where any of the Class Member opt-ins and Plaintiffs had worked for the period October 1, 2001 through March 31, 2003. As the Court determines it has previously ruled on Plaintiffs’ Eighth Request Nos. 28 and 29, the Court need not rule on these requests again. Plaintiffs’ Motion to Compel Defendant to produce documents responsive to Plaintiffs’ Eighth Request Nos. 28 and 29 is denied.
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With regard to Plaintiffs’ Eighth Request No. 20, which seeks documentation of Defendant’s After Action Review (or similar reviews) following the 2003 LINK ratings for its 2002 performance evaluations, the Court determines that it has not previously ruled on this particular request. Upon review, the Court notes that Defendant has failed to re-assert any of its objections to this request in its response in opposition to Plaintiffs’ motion. Because Defendant fails to reassert and rely upon its objections in its response in opposition to Plaintiffs’ motion, the Court deems Defendant’s objections to this request abandoned.15 Plaintiffs’ Motion to Compel Defendant to produce documents responsive to Plaintiffs’ Eighth Request No. 20 is granted. If it has not already done so, Defendant shall produce documents responsive to Plaintiffs’ Eighth Request No. 20 within thirty (30) days of the date of this Memorandum and Order.
B. Plaintiffs’ Ninth Request Nos. 10, 12-14, 16, 40, 45-59, and 64-66 Plaintiffs also request an order compelling Defendant to produce documents responsive to Plaintiffs’ Ninth Request Nos. 10, 12-14, 16, 27-36, 40, 41-42, 45-59, 60-63, and 64-66. Defendant asserted objections to all of these requests in its discovery responses, but only reasserted its objections to Plaintiffs’ Ninth Request Nos. 27-36, 41-42, and 60-63 in its response in opposition to Plaintiffs’ Motion to Compel. Because Defendant fails to reassert and rely upon its objections in its response in opposition to Plaintiffs’ Motion to Compel as to Plaintiffs’ Ninth Request Nos. 10, 12-14, 16, 40, 45-59, and
15When ruling upon a motion to compel, the Court will consider only those objections that have been (1) timely asserted, and (2) relied up in response to the motion to compel. Sonnino v. University of Kan. Hosp. Auth., 221 F.R.D. 661, 670 (D. Kan. 2004); Cotracom, 189 F.R.D. at 662. Objections initially raised but not relied upon in response to the motion to compel will be deemed abandoned. Sonnino, 221 F.R.D. at 670.
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64-66, the Court deems Defendant’s objections to these requests abandoned.16 Plaintiffs’ Motion

to Compel Defendant to produce documents responsive to Plaintiffs’ Ninth Request Nos. 10, 12-14,

16, 40, 45-59, 64-66 is granted. If it has not already done so, Defendant shall produce documents

responsive to Plaintiffs’ Ninth Request Nos. 10, 12-14, 16, 40, 45-59, and 64-66 within thirty (30)

days of the date of this Memorandum and Order.

C. Plaintiffs’ Ninth Request Nos. 27-36

Plaintiffs also seek to compel Defendant to produce documents responsive to Plaintiffs’

Ninth Request Nos. 27-36, a series of requests seeking documents regarding Defendant’s purchase,

distribution, and use of a book titled, “Jack Straight From the Gut,” authored by Jack Welch, former

chief executive officer of General Electric. The requests also seek discovery regarding meetings and

correspondence between Jack Welch and William T. Esrey, who was Defendant’s chief executive

officer from 1988 to March 2003. Specifically, Plaintiffs’ Ninth Request Nos. 27-36 ask Defendant

to produce the following:

C

any and all documents reflecting monies expended by Sprint for the purchase

of any and all copies of the book “[Jack] Straight from the Gut,” by Jack

Welch (Ninth Request No. 27).

C

any and all documents containing the names of any employee(s) to whom

Sprint, its agents, employees or representatives provided a copy of the book

marked in Ron Focht’s deposition as Ex. 1002 (Ninth Request No. 28)

C

any and all accounting records, receipts, or other documents showing any

meal or other entertainment expense relating to Jack Welch or any function

at which Jack Welch was entertained by any Sprint employee (Ninth Request

No. 29)

C

any and all memos or directives from Sprint, its agents, employees or

16See Sonnino, 221 F.R.D. at 670 (objections initially raised but not relied upon in response to the motion to compel will be deemed abandoned).
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representatives disclaiming any aspect or portion of the book, “[Jack] Straight from the Gut,” by Jack Welch. (Ninth Request No. 30)

C

any and all documents, including e-mails and information stored on-line in

any form whatsoever, that mention Jack Welch’s book, “[Jack] Straight from

the Gut,” and/or any portions thereof (Ninth Request No. 31)

C

all entries on Bill Esrey’s computer and/or calendar, scheduler/planner, diary,

log journal or other document that relate to or mention the name Jack Welch

(Ninth Request No. 32)

C

any and all documents reflecting any and all communication, including but not

limited to e-mails from supervisory, and/or other employees, quoting or

making references to any principles or contents found within “[Jack] Straight

from the Gut,” by Jack Welch (Ninth Request No. 33)

C

all e-mails sent to or from Bill Esrey to Jack Welch, or vice versa, from

January 1, 2000 through March 31, 2003 (Ninth Request No. 34)

C

any and all Sprint documents and/or records tha[t] mention the term “runway”

(Ninth Request No. 35)

C

any and all documents purporting to define or explain the meaning of the term

“runway” or any phrase that includes the word “runway” (Ninth Request No.

36)

Defendant objects to these requests on the basis they are not reasonably calculated to lead

to the discovery of admissible evidence. Defendant further objects on the grounds that the requests

seek documents that are not relevant to Plaintiffs’ claim that Defendant engaged in a pattern and

practice of age discrimination by terminating their employment during RIFs. Defendant also objects

to the requests because they are not reasonably limited in scope as to time by presumably seeking

documents outside the time period relevant to this case, i.e., October 1, 2001 through March 31,

2003. Defendant further objects to some of the requests on the basis they seek information from

third parties and information regarding employees of entities other than Defendant.

1. Relevancy objections

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Federal Rule of Civil Procedure 26(b)(1) provides that “[p]arties may obtain discovery regarding any matter, not privileged, that is relevant to the claim or defense of any party . . . . Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.”17 “Relevancy is broadly construed at the discovery stage of litigation and a request for discovery should be considered relevant if there is “any possibility” that the information sought may be relevant to the claim or defense of any party.18 When the discovery sought appears relevant, the party resisting the discovery has the burden to establish the lack of relevance by demonstrating that the requested discovery (1) does not come within the scope of relevance as defined under Fed. R. Civ. P 26(b)(1), or (2) is of such marginal relevance that the potential harm occasioned by discovery would outweigh the ordinary presumption in favor of broad discovery.19 Conversely, when relevancy is not readily apparent on the face of the request, the party seeking the discovery has the burden of showing the relevancy of the discovery request.20
Applying these principles, the Court finds that the relevancy of Plaintiffs’ Ninth Request Nos. 27-36 is not readily apparent on their face. Plaintiffs, as the party seeking the discovery, thus have the burden of showing the relevancy of these discovery requests.
Plaintiffs argue that these requests are relevant because they seek documentation of a meeting on Defendant’s campus in the fall of 2001, shortly before Defendant’s Alpha rating system
17Fed. R. Civ. P. 26(b)(1). 18Smith v. MCI Telecomms. Corp., 137 F.R.D. 25, 27 (D. Kan. 1991). 19Cory v. Aztec Steel Bldg., Inc., 225 F.R.D. 667, 672-673 (D. Kan. 2005). 20Pulsecard, Inc. v. Discover Card Servs., Inc., 168 F.R.D. 295, 309 (D. Kan. 1996).
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was designed and implemented, where GE Chairman Jack Welch spoke about his book, “Jack Straight From the Gut.” Plaintiffs assert that Mr. Welch discussed his business philosophies included in the book, one of which is a business philosophy they argue favors younger employees. Plaintiffs contend that Defendant adhered to this business philosophy. Plaintiffs argue in their motion that “it is well documented that the book espouses an ageist philosophy, and contains advice, for example, to seek and/or retain employees ‘with a long runway,’ and to eliminate the ‘bottom 10%’ of the workforce.”21 According to Plaintiffs, it is also documented that the chief executive officer of Sprint at the time of the RIFs, William Esrey, championed the philosophies of Welch, invited Welch to speak on the campus, and distributed copies of Welch’s book. Plaintiffs allege that certain phrases from the book, including the “long runway” comment, were subsequently used by Defendant’s management because documents produced by Defendant use the “runway” expression. Plaintiffs assert that their discovery requests are thus relevant in showing that an ageist environment not only existed but was encouraged by Defendant.
As the Court understands Plaintiffs’ argument, their requests are relevant to show that, at the time of the RIFs, Defendant’s top-level management promoted and encouraged the business philosophies set forth in the Jack Welch book, and one of those business philosophies favors younger employees. The promotion and encouragement of this allegedly ageist business philosophy by Defendant’s top-level management supports Plaintiffs’ claim that Defendant engaged in a pattern and practice age discrimination.
The Court agrees that Plaintiffs have generally shown why discovery into Defendant’s adoption and promulgation of an allegedly ageist business philosophy, if true, might support their
21Mem. in Supp. of Pls.’ Mot. to Compel (doc. 3653), p. 7. -12-

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claim that Defendant engaged in a pattern and practice of age discrimination. Thus, the Court finds that Plaintiffs have met their burden of showing relevancy. Although some of the requests may not be directly related to Plaintiffs’ pattern and practice claim, the Courts’ finding comports with the general policy that discovery should be considered relevant if there is “any possibility” that the information may be relevant to the claim or defense of any party.22 Defendant’s relevancy objections are therefore overruled.
2. Overly broad objections Defendant also objects to Plaintiffs’ Ninth Request Nos. 27-36 on the grounds the requests are overly broad. Specifically, Defendant contends that the requests are not reasonably limited in scope as to time by seeking documents outside the time relevant to this case, i.e. October 1, 2001 through March 31, 2003. Defendant further contends that the requests seek information from third parties other than Defendant, and information regarding employees of entities other than Defendant. Fed. R. Civ. P. 34(b) provides that requests shall set forth, either by individual item or by category, the items to be inspected, and describe each with reasonable particularity. Moreover, requests should be reasonably specific, allowing the respondent to readily identify what is wanted.23 Courts may find requests overly broad when they are “couched in such broad language as to make arduous the task of deciding which of numerous documents may conceivably fall within [their] scope.”24 A party objecting to a discovery request on the basis of overbreadth must support its
22MCI Telecomms. Corp., 137 F.R.D. at 27. 23General Elec. Capital Corp. v. Lear Corp, 215 F.R.D. 637, 641 (D. Kan. 2003). 24Id. (citing Audiotext Commc’ns v. U.S. Telecom, Inc., No. 94-2395-GTV, 1995 WL 18759, at *1 (D. Kan. Jan.17, 1995)).
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objection, unless the request appears overly broad on its face.25 The Court has reviewed Plaintiffs’ Ninth Request Nos. 27-36 and finds that these requests
are overly broad on their face. First, the requests are overly broad in temporal scope because they are not limited to any reasonable time period. None of the requests, except Request No. 34, contains any temporal limitation. The Court realizes that the timing of the publication of the book in 2001 does inherently place a beginning time restriction on a few of the requests. However, none of these requests include an end time restriction. Moreover, not all of the requests have such an inherent limitation, such as Request No. 32, which seeks “all entries on Bill Esrey’s computer and/or calendar, scheduler, planner, diary, log journal or other documents that relate to or mention the name Jack Welch.” Presumably, Plaintiffs are only interested in the dates Bill Esrey met with Jack Welch in the years immediately prior to and during the RIFs at issue. However, the request is not limited to that time frame. The Court therefore finds that Plaintiffs’ Request Nos. 27- 33, and 35-36 are overly broad in temporal scope because they do not limit the requests to any reasonable time period.
Second, many of the requests are overly broad on their face because they apply to every employee of Defendant. Specifically, Request Nos. 28, 30, 31, 33, and 35-36 all lack any limitation as to the employees who would fall within the scope of the requests. These requests are unlimited and would require Defendant to ask every employee whether he or she had documents responsive to the requests. Perhaps if these requests were limited to management-level employees or employees responsible for making the RIF decisions, or even limited in geographic scope or appropriate business unit or department, would the Court not find them so overly broad. Without any such limitation, the Court finds Plaintiffs’ Request Nos. 28, 30, 31, 33, and 35-36 to be overly broad.
25Cory, 225 F.R.D. at 672. -14-

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Third, some of the requests fail to even limit the information sought to the business philosophy described in the Welch book that Plaintiffs allege favors younger employees. For example, Ninth Request No. 31 seeks “any and all documents, including e-mails and information stored on-line in any form whatsoever, that mention Jack Welch’s book, ‘[Jack] Straight from the Gut,’ and/or any portions thereof.” This request is overly broad in that it asks for all documents that mention the book in any context and is not limited to the allegedly ageist philosophy. Ninth Request Nos. 35 and 36 respectively seek “any and all Sprint documents and/or records tha[t] mention the term ‘runway’” and “any and all documents purporting to define or explain the meaning of the term ‘runway’ or any phrase that includes the word ‘runway’.” These requests are overly broad in that they do not limit the term “runway” to the context used in the Jack Welch book. Ninth Request No. 34 seeks “all e-mails sent to or from Bill Esrey to Jack Welch, or vice versa, . . . .” This request also fails to limit its scope to the business philosophy described in the Welch book that Plaintiffs allege favors younger employees. Because these requests fail to limit their scope to the business philosophy described in the Welch book that Plaintiffs allege favors younger employees, the Court finds that Plaintiffs’ Request Nos. 31 and 34-36 are overly broad.
In summary, the Court determines that Plaintiffs’ Ninth Request Nos. 27-36 are overly broad on their face. Here, the Court will not compel further response from Defendant because inadequate guidance exists to determine the proper scope of the requests.26 Defendant’s overly broad objections to these discovery requests are sustained. Plaintiffs’ Motion to Compel Defendant to produce documents responsive to Plaintiffs’ Ninth Request Nos. 27-36 is denied.
26See Cotracom, 189 F.R.D. at 666 (the court will not compel further response when inadequate guidance exists to determine the proper scope of a discovery request).
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D. Plaintiffs’ Ninth Request Nos. 41-42 Plaintiffs’ Ninth Request Nos. 41-42 seek production of “documents from, and statements ascribed to, Gary Forsee [Sprint’s Chief Executive Officer] commenting on Sprint’s Performance Management System and/or Sprint’s Employee Evaluation system” and “documents from any source, announcing or concerning any changes to ‘Alpha’ LINK after Gary Forsee re-joined Sprint in April 2003.” Defendant objects to these requests on the grounds they are not reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects on grounds that the documents are not relevant to Plaintiffs’ claim that it engaged in a pattern and practice of age discrimination by terminating their employment during RIFs during the relevant time period relevant to this case, i.e., October 1, 2001 through March 31, 2003. Defendant argues that its evaluation system was not age discriminatory, but even if it was, comments about or changes made to the system after the relevant time frame of Plaintiffs’ claim cannot be reasonably calculated to discovery of evidence of pattern and practice of age discrimination. Plaintiffs disagree, contending that their requests seeking information on comments made by Defendant’s chief executive officer regarding its evaluation system are relevant because this evaluation system is one of the means by which Plaintiffs claim Defendant engaged in a pattern and practice of age discrimination. They maintain they are entitled to discover whether Mr. Forsee either criticized or embraced the system, or whether changes were made in response to suggestions or criticisms of Mr. Forsee. The Court finds that these requests, which seek statements ascribed to, Defendant’s new chief executive officer commenting on the company’s Performance Management System and/or
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Employee Evaluation system and documents announcing or concerning any changes to Alpha LINK

after he re-joined Sprint in April 2003 appear to seek discovery relevant to Plaintiffs’ claim that

Defendant engaged in a pattern and practice of age discrimination. Plaintiffs allege that Defendant

utilized its Performance Management System and/or Employee Evaluation system in order to

effectuate its policy of discriminating against older employees. Discovery into criticism or

endorsement of Defendant’s evaluation system by its new chief executive officer would thus be

relevant toward establishing whether Defendant’s evaluation system had been internally criticized

as age discriminatory and changed as a result of this criticism. Defendant’s relevancy objections

to these requests are therefore overruled. Plaintiffs’ Motion to Compel Defendant to produce

documents responsive to their Ninth Request Nos. 41 and 42 is granted. Defendant shall produce

documents responsive to Plaintiffs’ Ninth Request Nos. 41 and 42 within thirty (30) days of the

date of this Memorandum and Order.

E. Plaintiffs’ Ninth Request Nos. 60-63

Plaintiff’s Ninth Request Nos. 60-63 generally seek documents relating to Defendant’s use

of contract employees, and whether Sprint issued a new identification badge to employees who were

terminated as part of the RIFs, but who were subsequently rehired as contract employees.

Specifically, Plaintiffs’ Ninth Request Nos. 60 - 63 asks Defendant to produce the following:

C

any and all databases containing information on the specific employees who

have worked at Sprint at any time between June 1, 2001 to March 31, 2003,

who were “re-badged” and otherwise employed by another firm (such as IBM)

while continuing to work at Sprint. This request will include databases

maintained by any Sprint department (such as Security or Facilities or IT

department used in part to determine badge numbers and/or who has access to

Sprint facilities and/or Sprint’s computer systems (Request No. 60)

C

any and all documents and databases which would provide the identity by

name, job title, job description, department, job code, cost center, mail stop,

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Case 2:03-cv-02200-JWL-DJW Document 4326 Filed 09/25/06 Page 18 of 20

region code, department code, supervisor, supervisory no., and date of birth, of all Sprint employees who were “re-badged” at any time during the period January 1, 2001 through December 31, 2003 (Request No. 60a)

C

any database, list or other document which refers to or reflects the companies

that have provided contract employees to Sprint from 2001 to date, including

documents that describe the number and/or identity of employees provided

(Request No. 61)

C

any and all documents relating to and/or consisting of any contract with IBM

and/or third-party vendors for the “re-badging” of Sprint employees, during the

period January 1, 2001 through December 31, 2003 (Request No. 62)

C

any and all documents and databases that would show employees who were

hired as a Sprint employee and/or contractor, and/or “re-badged” employee for

any position within a business unit from which any Class member was

terminated, and in which the rehire took place within one (1) year of such Class

member’s termination (Request No. 63)

Defendant objected that these discovery requests are unnecessarily cumulative and

duplicative with prior discovery, improperly seek individualized discovery, seek information outside

the relevant time period, are overly broad, are not reasonably particular, and are not reasonably

calculated to lead to the discovery of admissible evidence.

1. Relevancy objections

Defendant argues in opposition to Plaintiffs’ motion that Plaintiffs’ Ninth Request Nos.

60-63 are not reasonably calculated to lead to the discovery of admissible evidence. Defendant

states these requests amount to a misguided fishing expedition based on Plaintiffs’ unfounded

assumption that Defendant discriminated against its older workers by terminating its younger

employees, and then secretly re-hiring the younger workers “under the guise” of third-party

contracts with other companies.

Plaintiffs argue that their Ninth Request Nos. 60-63 are relevant to their claims that

Defendant engaged in a pattern and practice of age discrimination because this is one of the alleged

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methods by which Defendant terminated older employees and kept or rehired younger employees. Upon consideration of Plaintiffs’ arguments presented, the Court finds that Plaintiffs have established the relevancy of these requests to their claim Defendant engaged in a pattern and practice of age discrimination. Defendant’s relevancy objections to these requests are overruled.
2. Other objections Defendant further objects to Plaintiffs’ Ninth Request Nos. 60-63 on the grounds the requests improperly seek individualized discovery, are duplicative of other discovery, seek information outside the relevant time period, are overly broad, and are not reasonably particular. In addition, Defendant states it does not maintain most of the requested materials as Plaintiffs have specifically requested them. The Court finds that Defendant has not sufficiently supported any of its remaining objections to these discovery requests, including how these requests improperly seek individualized discovery, are duplicative of other discovery, seek information outside the relevant time period, are overly broad, and are not reasonably particular. The Court therefore overrules these objections. Defendant also states it does not maintain most of the requested materials as Plaintiffs have specifically requested them. To the extent that Defendant is claiming that it does not have the requested documents in its possession, custody, or control, Rule 34(a) provides that Defendant is only required to produce documents that are within its “possession, custody or control.”27 Plaintiffs’ Motion to Compel Defendant to produce documents responsive to their Ninth Request Nos. 60-63 is granted. If it has not already done so, Defendant shall produce documents
27Fed. R. Civ. P. 34(a) (a party upon whom a request for production of document is served need only produce matters within the scope of 26(b) and which are within its “possession, custody or control”).
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within its possession, custody, or control and responsive to Plaintiffs’ Ninth Request Nos. 60-63 within thirty (30) days of the date of this Memorandum and Order.
IT IS THEREFORE ORDERED that Plaintiffs’ Motion to Compel Responses to Plaintiffs’ Eighth and Ninth Requests for Production of Documents (doc. 3652) is granted in part and denied in part. Plaintiffs’ Motion to Compel is granted as to Plaintiffs’ Eighth Request Nos. 20, and Ninth Request Nos. 10, 12-14, 16, 40, 45-59, 64-66, 41-42 and 60-63. Plaintiffs’ Motion to Compel is denied as to Plaintiffs’ Eighth Request Nos. 28-29, and Ninth Request Nos. 27-36. If it has not already done so, Defendant shall produce documents responsive to Plaintiffs’ Eighth Request No. 20, and Ninth Request Nos. 10, 12-14, 16, 40, 45-59, 64-66, 41-42, and 60-63 within thirty (30) days of the date of this Memorandum and Order.
IT IS FURTHER ORDERED the circumstances of this motion make an award of expenses unjust, and therefore each party is to bear their own expenses in relation to this motion.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 25th day of September, 2006.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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 Case 2:03-cv-02200-JWL-DJW Document 4343 Filed 10/05/06 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO.,

Defendant.

MEMORANDUM AND ORDER

Pending before the Court is Defendant’s Motion for Protective Order Prohibiting Discovery

Relating to Adverse Impact Analyses (doc. 3417). More specifically, Defendant requests that the

Court issue an order precluding Plaintiff from continued questioning of deponents regarding

Defendant’s RIF-related adverse impact analyses, which Defendant claims is protected from

disclosure by the attorney-client privilege and/or work product doctrine. Upon consideration of the

request, the Court will grant Defendant’s Motion to the extent specifically set forth below.

History of Discovery Disputes Related to Adverse Impact Analyses

On February 20, 2004, Plaintiffs filed a motion to compel production of documents and data

relating to adverse impact analyses performed by Defendant in connection with any terminations or job transfers in 2001-2002.1 In the motion, Plaintiffs also argued they should be allowed to take the

deposition of a designated Sprint representative to describe in detail the adverse impact analyses procedure.2 Defendant objected to these requests on the basis of the attorney-client privilege and the

1Plaintiffs’ Motion to Compel Regarding Adverse Impact Analyses (doc. 111). 2Id.

Case 2:03-cv-02200-JWL-DJW Document 4343 Filed 10/05/06 Page 2 of 7
work-product doctrine, and filed a memorandum in opposition to Plaintiffs’ motion to compel.3 On March 4, 2004, the District Judge denied Plaintiff’s motion to compel regarding adverse
impact analyses.4 While denying the motion on waiver grounds, the District Judge stated he “would have absolutely no difficulty denying the motion on substantive grounds” because the material at issue “is clearly and unmistakably . . . subject to lawyer/client privilege.”5 The District Judge further characterized the adverse impact analyses and related materials as “core lawyer/client privileged information.”6
On October 20, 2004, Plaintiff filed another motion to compel adverse impact analyses information and documents.7 On March 15, 2005, the Magistrate Judge denied part of Plaintiff’s motion to compel adverse impact information on procedural grounds and, based upon a potential compromise, denied without prejudice another part of Plaintiffs’ motion requesting adverse impact documents.8
On March 31, 2005, the District Judge held a hearing upon Plaintiffs’ motion to review a portion of the Magistrate Judge’s March 15, 2006 Memorandum and Order. With regard to discovery of adverse impact analyses, the District Judge stated as follows:
3Defendant’s Memorandum in Opposition to Plaintiff’s Motion to Compel (doc. 123). 4Order denying Motion to Compel (doc. 162). 5See Transcript of Telephonic Proceedings before Honorable John W. Lungstrum on March 2, 2004, at p. 6 (attached as Exhibit B to Defendant’s Index of Exhibits to Motion for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses) (doc. 3419). 6Id. 7Plaintiffs’ Motion to Compel and Memorandum in Support (doc. 2592 and 2593). 8Order denying Plaintiffs’ Motion to Compel Discovery (doc. 2754).
2

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[A]lthough my earlier ruling was limited to certain documents specifically that I reviewed and said these are clearly within the ambit of attorney/client privilege, I have seen nothing that leads me to believe that age impact documents generated as a specific request in connection with a specific RIF by the legal department of the defendant would be anything other than attorney/client privileged documents …. It appears to me that this case in that sense is garden variety, and so therefore if all there is are documents – no matter how helpful or interesting they would be if I were the plaintiff in this case – that were generated in response to defendant’s lawyers saying, We would like to look at this so that we can give you some advice about what you ought to do in connection with that RIF, that’s just not something the plaintiffs are going to be able to get to.9 On September 1, 2005, Plaintiffs submitted for the Magistrate Judge’s review a document entitled “List of Documents Withheld by Defendant Despite No Involvement of Legal Department or Counsel.”10 In this document, Plaintiffs requested that the Magistrate Judge compel Defendant to produce, among other things, adverse impact documents withheld by Defendant pursuant to a privilege log “despite no involvement of legal department or counsel.11 The Magistrate Judge ultimately construed this request to be a Motion to Compel.12 This motion became fully briefed on December 22, 2005. On November 4, 2005 – before Plaintiffs’ Motion to Compel adverse impact documents on the “List” was fully briefed – Defendant filed the motion currently pending before the court: a motion for protective order seeking to preclude Plaintiffs from questioning deponents regarding Defendant’s RIF-related adverse impact analyses, which Defendant asserts are protected from
9March 31, 2005 Transcript of Proceedings before the Honorable John W. Lungstrum, Ex. C to Defendant’s Index of Exhibits (doc. 3419) at pp. 11-12.
10See September 6, 2005 Court Order at ¶6 (doc. 3203). 11Id. 12Id.
3

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disclosure by the attorney-client privilege and/or work product doctrine.13 This motion became fully briefed on January 3, 2006.
On February 1, 2006, the Magistrate Judge granted in part and denied in part Plaintiffs’ motion to compel adverse impact documents withheld by Defendant pursuant to a privilege log “despite no involvement of legal department or counsel.”14 Notably, the February 1, 2006 Memorandum and Order was limited to the narrow issue of whether Defendant had failed in its privilege log to establish the elements required to invoke protection for the adverse impact documents identified in the privilege log.15 With respect to those documents in the privilege log concerning Defendant’s adverse impact analyses, the Magistrate Judge relied on the District Judge’s previous ruling to find that those privilege log entries specifically identifying the documents as adverse impact analyses satisfied Defendant’s burden of proof as to the applicability of the attorney-client privilege.16
In the meantime, Defendant inadvertently produced to Plaintiffs sixty-five adverse impact analyses documents. After reviewing the documents concerning adverse impact analyses, Plaintiffs urged that these documents – despite being specifically identified as adverse impact analyses documents in Defendant’s privilege log – were simply not privileged, and that Defendant would not be able to meet its burden of establishing that privileged nature of the adverse impact analyses
13Defendant’s Motion for Protective Order (doc. 3417). 14Memorandum and Order granting in part and denying in part Plaintiffs’ Motion to Compel Documents Withheld by Defendant Despite No Involvement of Legal Department (doc. 3549). 15Id. 16Id.
4

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documents. The parties agreed that these sixty-five documents qualified as a representative sample of the pool of adverse impact analyses documents and Plaintiffs requested the Magistrate Judge conduct an in camera review of this representative sample in order to determine if the documents were protected from disclosure. Because it was not possible to determine from the face of the documents whether the materials were (a) compilations of underlying data; or (b) adverse impact analyses undertaken at the direction of attorneys, the Magistrate Judge ultimately conducted an evidentiary hearing in March 2006 to determine applicability of the attorney-client privilege and/or the work product doctrine.
On July 1, 2006, the Magistrate Judge ruled that the representative sample of sixty-five adverse impact analyses documents were protected from disclosure by the attorney client privilege.17 More specifically, the Magistrate Judge found that the evidence presented by Defendant sufficiently demonstrated that the adverse impact/due diligence documents were confidential communications generated at the direction of counsel for the purpose of rendering legal advice. This decision was issued with the understanding that the parties would attempt to extrapolate from the Magistrate Judge’s ruling the privileged nature of the remaining documents and information concerning adverse impact analyses.18 On September 13, 2006, the Court issued a Memorandum and Order denying Plaintiffs’ Motion for Reconsideration of this July 1, 2006 Memorandum and Order.19
17July 1, 2006 Memorandum and Order (doc. 4213). 18Id. 19September 13, 2006 Memorandum and Order (doc. 4315). A motion for review of the Magistrate Judge’s July 1, 2006 and September 13, 2006 Memorandum and Orders is currently pending before the district court judge.
5

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Discussion In its Motion, Defendant requests the Court issue an order precluding Plaintiffs from continued questioning of deponents regarding confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. In their briefing of this Motion, the parties argue back and forth about whether the adverse impact analyses are attorneyclient privileged communications made in confidence for the purpose of securing legal advice or whether the adverse impact analyses are merely non-privileged underlying facts with a independent business purpose. Notably, the parties’ arguments are essentially identical to the arguments considered by the Court in its July 1, 2006 and September 13, 2006 Memorandum and Orders, both of which held that the representative sample of sixty-five adverse impact analyses documents were attorney-client privileged communications made in confidence for the purpose of securing legal advice and, thus, protected from disclosure by the attorney-client privilege. Based on this intervening decision, and because the intervening decision was issued with the understanding that the parties would attempt to extrapolate from the ruling the privileged nature of the remaining adverse impact analyses, the Court finds that, to the extent any of Plaintiffs’ deposition questions require Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice, such questions improperly seek information protected from disclosure by the attorney-client privilege. In so finding, the Court notes that this determination applies only to questions seeking confidential information regarding Defendant’s RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice and does not apply to inquiries regarding underlying facts and data compilations associated with adverse
6

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impact analyses (e.g., Master List and RIF List) or information regarding adverse impact analyses that was not generated at the direction of counsel for the purpose of seeking legal advice.20
Accordingly, Defendant’s Motion for Protective Order (doc. 3417) is granted to the extent that Plaintiffs shall refrain from asking deposition questions that would require Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 5th day of October, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

20See Upjohn Co., v. United States, 449 U.S. 383, 395 (1981) (holding that the attorney-client privilege only protects disclosure of communications for the particular purpose of providing or obtaining legal services; it does not protect disclosure of the underlying facts).
7

 
 Case 2:03-cv-02200-JWL-DJW Document 4392 Filed 11/06/2006 Page 1 of 9

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO.,

Defendant.

MEMORANDUM AND ORDER

Pending before the Court is Defendant’s Motion for Protective Order (doc. 3454). More

specifically, Defendant seeks return of an inadvertently disclosed document bearing bates stamp

54873 and entitled “Criteria for HR Review of Preliminary Performance Management Systems

Results” (the “Criteria Document”) on grounds that the document is protected from disclosure by

the attorney-client privilege.1 For the reasons below, Defendant’s Motion will be granted in part and

denied in part.

Background

Defendant claims the document at issue is part of a memorandum prepared by Jill Ferrel,

Sprint’s Vice President of Law for labor and employment. Defendant claims it originally asserted

privilege in its privilege log over this document because it contains legal advice from one of

Defendant’s senior in-house counsel to HR managers at Sprint. Defendant further contends the

inadvertent disclosure in this case occurred only after Plaintiff’s counsel questioned Defendant’s

claim of privilege on the document, and Defendant’s counsel re-reviewed the document to ensure

1Although Defendant originally sought return of various inadvertently disclosed e-mails in this Motion as well, Defendant has communicated to the Court that the issue has been resolved by the parties. Accordingly, the Court will deny that portion of the motion as it is now moot.

Case 2:03-cv-02200-JWL-DJW Document 4392 Filed 11/06/2006 Page 2 of 9
that it was indeed privileged. With that said, Defendant asserts that counsel re-reviewed the document without the accompanying cover memo from Jill Ferrel, which allegedly establishes the author of the document in question as Jill Ferrel in her capacity as legal counsel and allegedly confirms the privileged nature of the document. Defendant thus maintains its counsel erroneously concluded that the document was not privileged because he examined the document out of its proper context. Defendant has submitted the accompanying cover memo from Jill Ferrel for in camera review in connection with this Motion.2
The Legal Standard The purpose of the attorney-client privilege “is to encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice.”3 The privilege serves the client’s need for legal advice, but it also serves the attorney’s need to receive complete information in order to give the proper advice. The privilege protects communications with in-house, as well as outside, counsel.4 “Not every communication between an attorney and client is privileged, only confidential communications which involve the requesting or giving of legal advice.”5 “The focal point of the protection afforded by the attorney-client privilege lies with ‘communications’ between attorneys
2Exhibit B to Defendant’s Motion for Protective Order, submitted for in camera review on November 17, 2006 (see doc. 3457).
3Upjohn Co. v. United States, 449 U.S. 383, 389 (1981). 4Id. at 390. 5Burton v. R.J. Reynolds Tobacco Co.,, 175 F.R.D. 321, 327 (D. Kan. 1997) (citations omitted).
2

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and their clients” related to legal advice.6 Although the privilege protects disclosure of substantive communication between attorney and client, “it does not protect disclosure of the underlying facts by those who communicated with the attorney.”7
In Upjohn,8 the United States Supreme Court distinguished between disclosure of underlying facts and disclosure of privileged communications. The Court held that “[t]he protection of the privilege extends only to communications and not to facts. A fact is one thing and a communication concerning that fact is an entirely different thing.”9 The Court explained: “The client cannot be compelled to answer the question, ‘What did you say or write to the attorney?’ but may not refuse to disclose any relevant fact within his knowledge merely because he incorporated a statement of such fact into his communication with his attorney.”10
Because this action arises under a federal statutory scheme, federal law provides the rule of decision as to application of the attorney-client privilege.11 Under federal common law, the essential elements of the attorney-client privilege are: (1) Where legal advice is sought (2) from a professional legal advisor in his or her capacity as such, (3) the communications relating to that purpose, (4)
6IMC Chemicals, Inc. v. Niro, Inc., No. 98-2348, 2000 WL 1466495, at *8-9 (D. Kan. July 19, 2000) (quoting Upjohn Co., 449 U.S. at 395-96).
7Upjohn, 449 U.S. at 395-96. 8Id. 9Id. (emphasis in original) (quoting Philadelphia v. Westinghouse Elec. Corp., 205 F. Supp. 830, 831 (E.D. Pa. 1962). 10Id. at 396. 11See Sprague v. Thorn Americas, Inc., 129 F.3d 1355, 1368-69 (10th Cir. 1997) (federal privilege law applies to federal claim). No real conflict between federal and Kansas law regarding attorney-client privilege exists. See Hiskett v. Wal-Mart Stores, Inc., 180 F.R.D. 403, 405 (D. Kan. 1998).
3

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made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or by the legal advisor, (8) except the protection be waived.12 The party seeking to invoke the attorney-client privilege bears the burden of establishing its applicability.13 Based on these factors, the Court finds Defendant must establish that first, the Criteria Document is a communication made for the purpose of obtaining legal advice from the lawyer; second, the communication was made in confidence; and third, the privilege was not waived.
Applying these legal standards to the facts presented, the Court concludes that the Criteria Document inadvertently disclosed by Defendant and submitted for in camera review by the Court is protected from disclosure by the attorney-client privilege. In other words, the evidence presented by Defendant sufficiently demonstrates that the criteria document was generated by counsel as part of the Ferrel Memo at issue for the purpose of rendering legal advice.
Analysis The Criteria Document provides instruction for Sprint’s HR department on how to evaluate and respond to a preliminary conclusion that the Alpha system produced an adverse impact on some protected class. Plaintiffs argue this document cannot be protected from disclosure by privilege because this instruction document is not a “communication” but a “part of the policies and procedures of the company.” The Court disagrees. Although there is no indicia on the face of this document that is was prepared by legal counsel for the ultimate purpose of facilitating legal advice, Defendant has submitted metadata, affidavits and other evidence (which Plaintiffs have not disputed)
12Great Plains Mut. Ins. Co. v. Mutual Reinsurance Bureau, 150 F.R.D. 193, 196 (D. Kan. 1993).
13In re Foster, 188 F.3d 1259, 1264 (10th Cir. 1999). 4

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to establish that Jill Ferrel, a senior in-house counsel at Sprint, is the author of the criteria document and that the criteria document was transmitted to HR under a cover memo from Jill Ferrel reciting that the document is privileged.
As Defendants note in their briefing, this is not a situation in which HR used the underlying legal advice to create a formal policy and then claim the policy was privileged. In that scenario, while the policy would not be privileged, the legal advice that led to it would be privileged. Similarly, if HR followed a policy of reviewing Alpha rankings, the actions its personnel took would not be privileged. But the document that motivated those policies, sent in confidence from in-house counsel for the purpose of rendering legal advice, would be privileged.
Moreover, the Court finds that Defendant sufficiently kept the communication confidential and has not waived the privilege. In determining whether an inadvertent disclosure of documents constitutes a waiver of the attorney-client privilege, this Court employs a five-factor test.14 These factors are as follows: (1) the reasonableness of precautions taken to prevent inadvertent disclosure; (2) the time taken to rectify the error; (3) the scope of discovery; (4) the extent of disclosure; and (5) the overriding issue of fairness.15 In this case, all of the above factors favor return of the Criteria Document.
1. Sprint Employed Reasonable Precautions to Prevent Inadvertent Disclosure. The document productions in this case have involved tens of thousands of documents. In order to properly screen privileged documents, a partner-level attorney for Defendant reviewed all
14See Wallace v. Beech Aircraft Corp., 179 F.R.D. 313, 314 (D. Kan. 1998); Zapata v. IBP, Inc., 175 F.R.D. 574, 576-77 (D. Kan. 1998); Monarch Cement Co. v. Lone Star Indust., Inc., 132 F.R.D. 558, 560 (D. Kan. 1990).
15Id. 5

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of these documents for privilege issues. These documents where then collected, marked as privileged, and entered into a privilege log. Defendant’s counsel then had these documents double checked by legal assistants. Defendant maintained these privileged documents in its control.
This screening process favors a return of the inadvertently disclosed document in this case.16 The fact that Defendant’ counsel may not have properly screened the Criteria Document in this specific instance does not negate the measures Defendant employed to prevent disclosure throughout this litigation.17 Accordingly, the Court finds this factor favors return of the privileged document.
2. Sprint Took Prompt Measures to Rectify the Error. The relevant time period for rectifying any error begins when a party discovered or with reasonable diligence should have discovered the inadvertent disclosure.18 In this case, Defendant first became aware of the inadvertent disclosure of the Criteria Document on October 21, 2005, when Plaintiff’s counsel presented the document at the deposition of Gene Lampe. After the deposition, Defendant investigated the origin of the document and discovered that the document was authored by Ms. Ferrel and was a privileged communication. On October 27, 2005, Defendant sent a letter to Plaintiff’s counsel explaining the privileged nature of the document, the reason for the inadvertent disclosure, and requesting the immediate return of the document. Based on these facts, the Court finds Defendant took prompt steps to rectify its errors and thus this factor weighs in favor
16See Wallace 179 F.R.D. at 314 (holding that defendant took sufficient precautions where counsel and experienced legal assistant reviewed and marked documents and kept documents within defendant’s control); Zapata, 175 F.R.D. at 577 (same); Monarch Cement Co., 132 F.R.D. at 560 (same).
17See Wallace 179 F.R.D. at 314 (“While, apparently the initial review was not properly done by reviewing each document within this particular group of documents, the combined procedures employed to prevent disclosures appear adequate.”).
18See Zapata, 175 F.R.D. at 577. 6

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of return of the privileged document. 3. Discovery in This Case Has Been Vast. Where “document production is extensive . . . a finding that an inadvertent disclosure of
privileged documents waives the attorney-client privilege or work-product protection does not advance the aim of full and free discovery.”19 Parties “might tend to produce fewer documents or delay production for fear of losing protection for otherwise valid privilege claims.”20
The scope of discovery in this case has been expansive. To date, Defendant has produced tens of thousands of documents to Plaintiff. In the interest of advancing the aim of full and free discovery, the Court finds this factor favors a return of the privileged document.21
4. The Extent of the Disclosure in this Case is Minimal. The disclosure in this case involves one document. Defendant disclosed this document to Plaintiff’s counsel only. The only time the Criteria Document was discussed was during the deposition of Gene Lampe. The Court thus finds that the extent of disclosure in this case is minimal, and this factor weighs in favor of a return of the privileged document.
19Zapata, 175 F.R.D. at 577 (citing In re Wyoming Tight Sands Antitrust Cases, No. 85-2349-S, 1987 WL 93812, at *5 (D. Kan. 1987)).
20Id. 21See Zapata, 175 F.R.D. at 577 (ordering return of document where over forty thousand documents had been produced during a three and one-half year litigation, in which time only one inadvertent disclosure was made); Monarch Cement Co., 132 F.R.D. at 560 (ordering return of document where “[m]ore than 9,000 pages of documents were produced, and the documents in question were only eight pages contained in one of 118 personnel files.”).
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5. Overriding Issues of Fairness Favor Return of the Document. It appears that Defendant produced the privileged document in this case in an effort to cooperate with Plaintiff’s attorney; thus, the inadvertent disclosure was made by counsel during a good faith effort to comply with a discovery request. Moreover, because the document in this case involves the attorney-client privilege, fairness is best served by ordering a return of the document. This conclusion seems especially fitting when the Court considers that the attorney-client privilege is one which belongs to the client. “Fairness in this case constrains a holding that the client should not suffer because of the actions of counsel.”22 Accordingly, overriding issues of fairness favor a return of the privileged document. Based on the discussion above, the Court finds Defendant has adequately demonstrated that the Criteria Document is a communication that was made for the purpose of obtaining legal advice from a lawyer, that such communication was made in confidence and the privilege was not waived. Thus, the Court finds the Criteria Document inadvertently disclosed by Defendant is protected from disclosure by the attorney-client privilege and must be returned to Defendant. Accordingly, it is hereby ORDERED that Defendant’s Motion for Protective Order (doc. 3454) is granted in part and denied in part as follows: (1) That portion of the Motion requesting protection for the Criteria Document is granted
and Plaintiffs shall return the Criteria document, and all copies thereof, within five (5) days from the date of this Memorandum and Order. It is further ORDERED that Plaintiffs shall be prohibited from using this document in any manner.
22132 F.R.D. at 560. 8

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(2) That portion of the Motion requesting protection for five e-mails inadvertently produced is denied as moot.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 3rd day of November, 2006.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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 Case 2:03-cv-02200-JWL-DJW Document 4401 Filed 11/09/06 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant. ORDER
On November 8, 2006, the court held a telephone conference with the parties during which the court granted plaintiffs’ motion to review (doc. 4347) and sustained their objections to that portion of the magistrate judge’s September 25, 2006 order denying plaintiffs’ motion to compel defendant to produce documents responsive to Requests Nos. 27 through 36 of Plaintiffs’ Ninth Request for Production of Documents. As set forth in full on the record, the court concludes that the magistrate judge erred in concluding that the Requests are facially overly broad and, thus, erred in failing to require defendant to substantiate its objections. In the interest of judicial economy, the court declines to remand this matter to the magistrate judge and, instead, resolves defendant’s objections to plaintiffs’ Requests on its own in light of the complete record before it. As explained on the record, defendant’s objections to the Requests are overruled and defendant shall produce documents responsive to the Requests (with slight modifications to those Requests as described on the record) within 30 days of the date of this order.

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IT IS SO ORDERED.

Dated this 9th day of November, 2006, at Kansas City, Kansas.

s/ John W. Lungstrum John W. Lungstrum United States District Judge

____

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 Case 2:03-cv-02200-JWL-DJW Document 4404-1 Filed 11/09/06 Page 1 of 30

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant. MEMORANDUM & ORDER
Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b).
This matter is presently before the court on plaintiffs’ motion to review (doc. 4338) and objections to the magistrate judge’s February 1, 2006 and July 1, 2006 orders in which the magistrate judge concluded that documents relating to an adverse impact analysis conducted by defendant are protected from discovery by the attorney-client privilege. As will be explained, the motion is granted with respect to Exhibits A through E and Exhibit L and the court remands to the magistrate judge the issue of whether defendant waived the attorney-client privilege with respect to these Exhibits by not asserting that privilege in its privilege log and, if he concludes that defendant did waive the privilege, to consider the merits of defendant’s claim that the documents are protected from discovery by the work product doctrine. The motion is retained

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under advisement with respect to plaintiffs’ assertion that defendant waived the attorney-client privilege by asserting its “good faith” compliance with the ADEA and the court will conduct a telephone conference to address this issue on Thursday, November 16, 2006 at 2:00pm. The motion is otherwise denied.
I. Background In writing this memorandum and order, the court assumes familiarity with the factual
background of the case as well as the magistrate judge’s order underlying the motion to review. Nonetheless, for the reader’s convenience, the court briefly summarizes here the procedural history of plaintiffs’ motion to review.
In September 2005, plaintiffs submitted to the magistrate judge a document entitled “List of Documents Withheld by Defendant Despite No Involvement of Legal Department or Counsel.” In the document, plaintiffs asked the magistrate judge to compel defendant to produce certain documents identified in its privilege log. In support of their request, plaintiffs argued that defendant had failed to establish the elements required to invoke the attorney-client privilege or the work product doctrine with respect to those documents for which defendant failed to identify an attorney as the sender or recipient and which were described as “adverse impact,” “due diligence” or “impact ratio” documents.1 The magistrate judge construed the document as a
1These documents generally are spreadsheets reflecting various statistical analyses comparing the demographic data (gender, race and age) of employees targeted for layoff in the RIF at issue in this case to the demographic data of those employees defendant intended to retain in the RIF. Defendant maintains that these analyses were conducted at the specific
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motion to compel and the parties subsequently briefed the issue of whether the “adverse impact” or “due diligence” documents identified on defendant’s privilege log were immune from discovery by virtue of the attorney-client privilege or the work product doctrine. On February 1, 2006, the magistrate judge issued a written order denying plaintiffs’ motion to compel on this issue2 and concluding that defendant had met its burden of proof with regard to a claim of attorney-client privilege for the documents described in its privilege log as “adverse impact” and “due diligence.”
On February 20, 2006, plaintiffs filed a motion to review (doc. 3605) that portion of the magistrate judge’s February 1, 2006 order denying the motion to compel those documents identified by defendant on its privilege log as “adverse impact” documents or “due diligence” documents. In their motion to review, plaintiffs asked the court to defer ruling on the motion until after the magistrate judge resolved related issues that had emerged during the pendency of the motion to compel. Specifically, in January 2006, defendant inadvertently produced to plaintiffs during discovery sixty-five “adverse impact” or “due diligence” documents that
request of its counsel for the purpose of obtaining legal advice regarding the statistical impact on various classes of persons protected by the federal anti-discrimination laws. Plaintiffs insist that the adverse impact documents are merely compilations of underlying data independently generated and utilized by employees in defendant’s human resources department.
2Other issues not relevant to the adverse impact documents were raised by plaintiffs’ motion to compel and were addressed in the magistrate judge’s February 1, 2006 order. The magistrate judge granted certain aspects of plaintiffs’ motion and denied certain aspects of the motion. For purposes of plaintiffs’ motion to review, however, only that portion pertaining to the adverse impact documents is pertinent.
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defendant then sought to recall based on the attorney-client privilege. Plaintiffs, by letter, then asked the magistrate judge to conduct an in camera review of the sixty-five documents and to resolve defendant’s claim of privilege with respect to the sixty-five documents. The court construed plaintiffs’ letter as a motion for relief and the parties submitted briefs with respect to the motion. This court, then, retained plaintiffs’ February 2006 motion to review under advisement to permit the magistrate judge to determine whether the sixty-five documents inadvertently produced to plaintiffs (and, by agreement of the parties, all similar adverse impact or due diligence documents) were protected from disclosure by the attorney-client privilege.
After reviewing the parties’ briefs filed in connection with plaintiffs’ motion for relief as well as the sixty-five documents inadvertently produced, the magistrate judge was unable to determine whether the documents constituted mere compilations of underlying data generated and utilized by employees in defendant’s human resources department (as asserted by plaintiffs) or whether the documents constituted statistical analyses undertaken at the direction of defendant’s counsel (as asserted by defendant). The magistrate judge, then, conducted a closed evidentiary hearing over the course of two days in March 2006 regarding the use and creation of the adverse impact documents. At the hearing, defendant introduced into evidence each of the sixty-five documents inadvertently produced during discovery and the magistrate judge heard testimony from various witnesses concerning the use and creation of the adverse impact documents. In addition, defendant submitted for in camera review during the hearing various additional documents, including transmittal e-mails showing that certain adverse impact documents had been provided to defendant’s counsel as well as a copy of an October 5, 2001
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memorandum from Jill Ferrel (the “Ferrel Memorandum”),3 an attorney in defendant’s legal department, to other attorneys in the legal department and certain human resources employees.
On July 1, 2006, the magistrate judge issued a written order in which he concluded that the documents inadvertently produced to plaintiffs were protected from disclosure by the attorney-client privilege and directed plaintiffs to return the documents to defendant. The magistrate judge further denied plaintiffs’ request for production of all similar adverse impact documents. Specifically, the magistrate judge concluded that the adverse impact documents constituted communications made for the purpose of obtaining legal advice and at the direction of counsel (pursuant to the Ferrel Memorandum), that the documents were kept confidential and that defendant had not waived the privilege through its inadvertent production to plaintiffs, through the deposition testimony of one of defendant’s witnesses or through its assertion of a “good faith” affirmative defense. Plaintiffs filed a motion for reconsideration on several grounds and, on September 13, 2006, the magistrate judge denied that motion in its entirety.
Plaintiffs then filed their motion to review (doc. 4338) the magistrate judge’s February 1, 2006 and July 1, 2006 orders. In their motion, plaintiffs assert that the magistrate judge erred as follows: (1) in concluding that the adverse impact documents are protected from disclosure by the attorney-client privilege; (2) in rejecting plaintiffs’ argument that defendant had waived the attorney-client privilege (or could not establish the privilege in the first instance) because the adverse impact documents were disseminated beyond those persons who needed to know the
3In February 2004, this court held that the Ferrell Memorandum was protected from disclosure by the attorney-client privilege.
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documents’ contents; (3) in concluding that the adverse impact documents, in their entirety, are privileged and in impliedly rejecting plaintiffs’ argument that certain portions of the adverse impact documents are not privileged and are subject to discovery; (4) in concluding that defendant did not waive the attorney-client privilege with respect to those documents for which defendant, on its privilege log, claimed only work product protection; and (5) in rejecting plaintiffs’ argument that defendant’s assertion in its answer to plaintiffs’ second amended complaint that defendant had engaged in good faith efforts to comply with the ADEA was sufficient to require disclosure of otherwise privileged communications.
Plaintiffs’ motion to review has been fully briefed by the parties and, thus, this motion as well as plaintiffs’ previous motion to review (doc. 3605) which the court retained under advisement are now ripe for this court’s resolution. As set forth in detail below, both motions are granted in part, denied in part and retained under advisement in part.
II. Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district
courts review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a). The clearly erroneous standard applies to factual findings, see 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069, at 355 (2d ed. 1997) (and cases cited therein), and requires that the district court affirm unless
6

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it is left with the “definite and firm conviction that a mistake has been committed.” Ocelot Oil, 847 F.2d at 1464 (quoting United States v. United States Gypsum Co., 333 U.S. 364, 395 (1948)). By contrast, the “contrary to law” standard permits “plenary review as to matters of law.” See Wright, Miller & Marcus, supra, § 3069, at 355; Haines v. Liggett Group Inc., 975 F.2d 81, 91 (3rd Cir. 1992); Computer Economics, Inc. v. Gartner Group, Inc., 50 F. Supp .2d 980, 983 (S.D. Cal. 1999) (“contrary to law” standard permits independent review of purely legal determinations by a magistrate judge); Weekoty v. United States, 30 F. Supp. 2d 1343, 1344 (D.N.M. 1998) (when reviewing legal determinations made by magistrate judge, standard of review is de novo).
III. Documents Exchanged Exclusively Among HR Personnel In their motion to review, plaintiffs first contend that the magistrate judge erred in
concluding that the adverse impact documents were made at the direction of counsel for the purpose of obtaining legal advice. According to plaintiffs, the evidence submitted at the hearing simply does not support the magistrate judge’s conclusion. Specifically, plaintiffs contend that the evidence was either insufficient to establish that each of the adverse impact documents was sent to counsel or affirmatively established that certain adverse impact documents were never sent to counsel; rather, these adverse impact documents were exchanged exclusively among HR personnel, who manipulated the RIF decisional units in an effort to achieve “better” statistics (in terms of reflecting an adverse impact) before sending a final draft of the spreadsheets to counsel. As will be explained, even assuming that certain adverse impact documents were never sent to
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counsel and were exchanged exclusively among HR personnel for the purpose of manipulating the decisional units to achieve better statistics,4 the court finds no error in the magistrate judge’s
conclusion that such documents are nonetheless protected by the attorney-client privilege.
As an initial matter, plaintiffs presented this argument to the magistrate judge, who
expressly rejected it in his July 1, 2006 memorandum and order:
The Court is not persuaded by this argument. The essential elements of the privilege as defined above do not require an attorney to have either authored or received the document at issue in order to maintain the privilege. A party may successfully demonstrate applicability of the privilege to written communication between corporate management employees by establishing that the communication was made in confidence for the primary purpose of obtaining legal advice. Organizational clients and business entities often are personified by a number of employees. In preparation for, or in the midst of, consultations with an attorney, employees of the client will often consult one another to ensure that the attorney’s advice is based on full knowledge of all relevant facts.
See Memo. & Order at 14-15 (July 1, 2006). Much of the legal foundation for the magistrate
judge’s analysis was laid in the judge’s February 1, 2006 memorandum and order, in which he
cited more than ten cases recognizing that communications among non-attorneys in a corporation
may be privileged if made at the direction of counsel, to gather information to aid counsel in
providing legal services. See Memo. & Order at 5-7 & n. 21. While the list of cases cited by
the magistrate judge was certainly not meant to be exhaustive, the court’s own research has
uncovered numerous additional cases recognizing that the attorney-client privilege extends to
4While the court makes this assumption for purposes of resolving the motion to review, the court notes that the magistrate judge specifically found that the majority of the adverse impact documents were transmitted to defendant’s counsel via e-mail and that, on other occasions, adverse impact documents were hand-delivered to counsel during attorneyclient meetings.
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communications made within a corporation if those communications are made for the purpose of securing legal advice. See In re Rivastigmine Patent Lit., 237 F.R.D. 69, 80 (S.D.N.Y. 2006); SmithKline Beecham Corp. v. Apotex Corp., 232 F.R.D. 467, 477 (E.D. Pa. 2005) (citing Santrade, Ltd. v. Gen. Elec. Co., 150 F.R.D. 539, 545 (E.D.N.C. 1993)); Valve Corp. v. Sierra Entertainment Inc., 2004 WL 3780346, at *2 (W.D. Wash. Dec. 6, 2004); Adams v. Gateway, Inc., 2003 WL 23787856, at *11 (D. Utah Dec. 30, 2003); Kintera, Inc. v. Convio, Inc., 219 F.R.D. 503, 514 (S.D. Cal. 2003).
Significantly, plaintiffs do not direct the court to any cases suggesting that the rule should be otherwise and they challenge only two cases cited by the magistrate judge–Eutectic Corp. v. Metco, Inc., 61 F.R.D. 35 (E.D.N.Y. 1973), and United States v. Kovel, 296 F.2d 918 (2d Cir. 1961). According to plaintiffs, neither Eutectic nor Kovel “supports the magistrate’s conclusion that a lawyer does not have to be connected in some way to an intra-corporate communication for the privilege to apply.” Of course, the magistrate judge did not conclude that counsel did not have to be connected in any way to a communication for the privilege to apply. Rather, he concluded that communications between non-attorneys could nonetheless be privileged so long as the communications were made in confidence for the purpose of obtaining legal advice from counsel. Both Eutectic and Kovel fully support this conclusion. As the Second Circuit explained in Kovel:
[I]f the lawyer has directed the client, either in the specific case or generally, to tell his story in the first instance to an accountant engaged by the lawyer, who is then to interpret it so that the lawyer may better give legal advice, communications by the client reasonably related to that purpose ought fall within the privilege; there can be no more virtue in requiring the lawyer to sit by while the client
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pursues these possibly tedious preliminary conversations with the accountant than in insisting on the lawyer’s physical presence while the client dictates a statement to the lawyer’s secretary or in interviews by a clerk not yet admitted to practice. What is vital to the privilege is that the communication be made in confidence for the purpose of obtaining legal advice from the lawyer. Kovel, 296 F.2d at 922; accord Eutectic, 61 F.R.D. at 40 (privilege applied to documents communicated among non-attorneys where documents “contained information collected for the dominant purpose of facilitating the attorney’s efforts to provide services to the client, and the information in every instance was, in one form or another, communicated to the attorney”). Suffice it to say, the court is convinced that the mere fact that certain adverse impact documents were shared only among HR personnel is not necessarily fatal to defendant’s claim of privilege. The remaining question, then, is whether the magistrate judge correctly concluded that these documents, assuming they were shared only among HR personnel and further assuming that HR personnel manipulated the decisional units on various drafts to obtain better statistics before sending a final draft to counsel, were made for the purpose of obtaining legal advice. In support of his conclusion, the magistrate judge relied first on the October 5, 2001 Ferrel Memorandum. This memorandum, written by an attorney in defendant’s legal department and issued to other attorneys and HR personnel, is stamped “Privileged Attorney-Client Advice” and the subject line of the memorandum designates “Adverse Impact Analysis” as the subject. The Ferrel Memorandum explains the meaning of the phrase “adverse impact” and explains the process by which defendant’s legal department will perform an adverse impact analysis with respect to the RIF. Moreover, the Ferrel Memorandum specifically directs HR personnel to
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compile certain data on each employee in a given decisional unit so that the legal department can provide legal advice regarding the statistical impact of the RIF on various protected groups under the federal anti-discrimination laws. The Memorandum also directs HR personnel to utilize a specific methodology in gathering and presenting the data, including the use of spreadsheets and matrices reflecting specific calculations. Significantly, the adverse impact documents reviewed by the magistrate judge present the requested data in the specific formula and format prescribed by Ms. Ferrel in her October 5, 2001 memorandum.
In addition, several witnesses at the evidentiary hearing testified that the adverse impact documents were prepared pursuant to the methodology dictated by the legal department pursuant to the Ferrel Memorandum.5 These witnesses also testified that the adverse impact documents were prepared at the direction of counsel–again, pursuant to the Ferrel Memorandum–and that the documents were used to “initiate conversation” (see, e.g., March 10, 2006 Testimony of Jim Kissinger at 73) with the legal department so that the legal department could conduct an adverse impact analysis and provide advice to HR personnel in the RIF process. Defendant’s witnesses further testified that the adverse impact documents were not used for any purpose other than to
5Plaintiffs contend that the magistrate judge’s reliance on the Ferrel Memorandum is misplaced because the evidence demonstrated that some of the adverse impact documents were created before the Ferrel Memorandum was issued. This argument was presented to the magistrate judge, who rejected it in his September 13, 2006 order denying the motion for reconsideration. As explained by the magistrate judge, the adverse impact spreadsheets were simply one page of a larger electronic document and, thus, while the larger electronic document may reflect a pre-October 5, 2001 creation date, no evidence supports plaintiffs’ argument that the particular adverse impact document within the larger document was created prior to the Ferrel Memorandum.
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facilitate the provision of legal advice. The magistrate judge credited the testimony of these witnesses and this testimony, together with the content of the Ferrel Memorandum and the format of the documents themselves, caused the magistrate judge to conclude that each of the adverse impact documents were made for the purpose of obtaining legal advice.
Plaintiffs contend that the magistrate judge erred in “accepting” defendant’s witnesses’ “dutiful recitation” of the purpose and use of the adverse impact documents and that the witnesses’ “conclusory assertions” are insufficient to satisfy defendant’s burden to prove the applicability of the privilege. As an initial matter, the court has reviewed the transcripts from the evidentiary hearing; the testimony of defendant’s witnesses concerning the creation, use and purpose of the adverse impact documents cannot be described as “conclusory.” Indeed, the testimony of each witness on these subjects was the result of detailed questioning by both defense counsel and plaintiffs’ counsel. While plaintiffs suggest that defendant’s witnesses did not testify truthfully (or perhaps credibly), their argument would require the court to reweigh the evidence and substitute the court’s view for that of the magistrate judge, which the court is not permitted to do. See State Farm Mut. Auto. Ins. Co. v. Vicente, 1997 WL 82476, at *1 (10th Cir. Feb. 27, 1997).
In light of the foregoing, the court finds no error in the magistrate judge’s conclusion that the adverse impact documents–regardless of whether the documents themselves were ultimately transmitted to counsel–constituted communications made for the purpose of obtaining legal advice. The evidence fully supports the conclusion that HR personnel, in creating the adverse impact documents, were essentially acting under the authority and control of counsel. To the
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extent such documents (or drafts of documents) were exchanged among HR personnel exclusively, this does not change the conclusion that the documents were created and used to obtain legal advice, as the documents were exchanged among personnel for the purpose of channeling pertinent information to counsel for assessment or, as Mr. Kissinger testified, for the purpose of “initiating conversation” with counsel on the adverse impact issue. Moreover, to the extent HR personnel were manipulating decisional units on earlier drafts,6 the court is not persuaded that these actions are inconsistent with provision of legal advice. Indeed, the Ferrel Memorandum expressly contemplated an analysis of various decisional units depending on the existence of certain circumstances. Plaintiffs’ first objection, then, is overruled.
IV. Waiver by Defendant’s Failure to Keep the Documents Confidential Plaintiffs further assert that the magistrate judge erred in rejecting plaintiffs’ argument
that defendant had waived the attorney-client privilege (or could not establish the privilege in the first instance) because the adverse impact documents were disseminated beyond those persons who needed to know the documents’ contents. According to plaintiffs, the evidence at the hearing was insufficient to establish, with respect to each and every matrix, that the matrix was provided only to those individuals with a need to know the contents of the document. Plaintiffs further assert that the evidence actually established that certain matrices were
6To be clear, the “manipulation” (plaintiffs’ word choice) of decisional units to obtain better statistics does not suggest a change in any particular termination decision. Rather, it suggests only that HR personnel would expand, limit or otherwise modify the “unit” of employees in which an employee selected for termination was grouped.
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communicated to individuals who had no need to know the contents of the document. In his July 1, 2006 order, the magistrate judge acknowledged that “confidentiality is the
key” to the attorney-client privilege and that the privilege is lost if the client discloses the substance of an otherwise privileged communication to a third party. See In re Qwest Comms. Intern. Inc., 450 F.3d 1179, 1185 (10th Cir. 2006). The magistrate judge concluded that defendant had kept the adverse impact documents confidential, highlighting evidence that all such documents were protected by a password available only to HR and Legal Department personnel and that the vast majority (all but four) of the documents were marked “Sprint–Internal Use Only Confidential.” The magistrate judge also found, with specific reference to the testimony presented at the hearing, that recipients of the adverse impact documents were aware of the confidential nature of the information and that the purpose of the information was to obtain legal advice.
Plaintiffs do not challenge these findings, but challenge only the magistrate judge’s additional finding that the adverse impact documents were “disseminated only to those individuals who had some stated purpose in receiving them.” See Memo. & Order at 19 (July 1, 2006). According to plaintiffs, the magistrate judge’s “stated purpose” test is contrary to law and, in any event, the evidence at the hearing was insufficient to satisfy that test or the more stringent “need to know” test. As will be explained, the court assumes that plaintiffs’ articulation of the “need to know” test is the applicable standard in determining whether otherwise privileged documents have been kept confidential. Even still, the court concludes that the magistrate judge did not err in concluding that defendant had met its burden of establishing
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that it had kept the adverse impact documents confidential. In support of his conclusion that defendant had kept the adverse impact documents
confidential, the magistrate judge found that the documents were distributed only to those individuals who had “some stated purpose” in receiving the documents; the judge made no findings as to whether the recipients had a “need to know” the contents of the documents. According to plaintiffs, the appropriate standard in determining whether a particular document was kept confidential is not whether the recipients had a purpose in receiving the document but whether the recipients had a “need to know” the contents of the document. While the Tenth Circuit has not yet had the opportunity to determine whether the “need to know” standard is the appropriate standard in determining whether documents disseminated to other persons have nonetheless been kept confidential, there is ample support for plaintiffs’ argument that the “need to know” test is the appropriate test. See, e.g., FTC v. GlaxoSmithKline, 294 F.3d 141, 147 (D.C. Cir. 2002) (“The applicable standard is, as the district court recognized, whether the documents were distributed on a ‘need to know’ basis or to employees that were ‘authorized to speak or act’ for the company.”); Diversified Indus., Inc. v. Meredith, 572 F.2d 596, 609 (8th Cir. 1977) (key to analyzing whether document was kept confidential is whether the document was “disseminated beyond those persons who, because of the corporate structure, needed to know its contents.”).
Ultimately, the court need not decide which test is the appropriate test because the court concludes that the magistrate judge’s conclusion should be affirmed even under the more stringent “need to know” test. Significantly, plaintiffs’ complaint with respect to the magistrate
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judge’s decision is that defendant failed to establish that each and every recipient of each and every adverse impact document had a “need to know” the contents of that document. The D.C. Circuit addressed the same argument in FTC v. GlaxoSmithKline (GSK). In GSK, the Federal Trade Commission petitioned the district court to enforce a petition issued by the Commission directing GSK to produce various documents concerning Paxil, a drug manufactured by GSK. 294 F.3d at 143-44. The parties ultimately resolved through negotiation their differences over the disclosure of thousands of documents, leaving unresolved the status of only 91 documents that GSK declined to produce on the grounds that they were shielded by the attorney-client privilege. Id. at 144. Before the district court, the Commission argued that GSK’s assertions of privilege were invalid because GSK had forfeited its claim to confidentiality by disseminating all 91 documents widely both within GSK and to consultants and other third-parties. Id.
The district court ordered GSK to produce the 91 documents, concluding that GSK had not sustained its burden of demonstrating that the relevant documents were distributed on a “need to know” basis or to employees that were authorized to speak or act for GSK. Id. at 145. Specifically, the district court “faulted GSK for not having explained ‘why any, let alone all, of the employees received copies of certain documents.’” Id. at 147. Likewise, on appeal, the Commission argued that “GSK should have shown why each individual in possession of a confidential document ‘needed the information [therein] to carry out his/her work.’” Id. The D.C. Circuit reversed the district court, holding that the 91 documents were protected by the attorney-client privilege. Id. at 148. In so doing, the Circuit stated that the demands placed on GSK by the district court and urged by the Commission were “overreaching.” Id. at 147. As
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the Circuit explained: The Company’s burden is to show that it limited its dissemination of the documents in keeping with their asserted confidentiality, not to justify each determination that a particular employee should have access to the information therein. Not only would that task be Herculean–especially when the sender and recipient are no longer with the Company–but it is wholly unnecessary. After all, when a corporation provides a confidential document to certain specified employees or contractors with the admonition not to disseminate further its contents and the contents of the documents are related generally to the employees’ corporate duties, absent evidence to the contrary we may reasonably infer that the information was deemed necessary for the employees’ or contractors’ work.
Id. at 148. The court finds the D.C. Circuit’s opinion in GSK persuasive and, in the absence of any
Tenth Circuit authority suggesting that the rule should be otherwise, looks to GSK for guidance in resolving plaintiffs’ claim that defendant was required to prove that each recipient of each adverse impact document had a “need to know” the contents of the document. As noted above, the magistrate judge found that all adverse impact documents were protected by a password available only to HR and Legal Department personnel, that the vast majority of the documents were marked “Sprint–Internal Use Only Confidential,” and that the recipients of the adverse impact documents were aware of the confidential nature of the information and that the purpose of the information was to obtain legal advice. Plaintiffs do not challenge these findings in any respect. Moreover, the record reflects that the adverse impact documents are related generally to the corporate duties of the recipients. For example, Deb Sprayberry and Gina Eisler, two employees who received copies of the adverse impact documents and who plaintiffs contend had no “need” for at least some of these documents, were both managers in defendant’s HR
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department, were intimately involved in the RIF and were required to address issues that were
completely intertwined with defendant’s ongoing legal analysis of whether certain RIF decisions
had an adverse or disparate impact on a protected class of employees. Plaintiffs have offered no evidence to the contrary.7 In sum, then, the evidence at the hearing established that defendant
limited dissemination of the adverse impact documents to specific individuals whose corporate
duties related generally to the contents of the documents. The magistrate judge, then, was
correct in determining that defendant kept the documents confidential.
V. Discoverability of Data Summarized in the Adverse Impact Documents
Plaintiffs contend that the magistrate judge erred in concluding that the adverse impact
documents, in their entirety, are privileged. According to plaintiffs, the summary data extracted
from the Master Lists and RIF Lists and reproduced in the “top two boxes” of the adverse impact
documents is not privileged and is subject to discovery, regardless of whether the remaining
7Plaintiffs contend that defendants failed to prove that Ms. Sprayberry had a “need to know” the contents of the matrices reflected in Exhibits PP, QQ and RR because Ms. Sprayberry testified that she received these particular matrices after the legal department had completed its adverse impact analysis and review with respect to those matrices and that Ms. Sprayberry only received the documents for “final retention” purposes. Contrary to plaintiffs’ assertion, Ms. Sprayberry’s testimony does not unequivocally establish that she did not have a “need to know” the contents of Exhibits PP, QQ and RR. Ms. Sprayberry’s testimony, considered in full, establishes that her duties as the Manager of Regional HR Operations required her to guide her subordinate HR managers through the adverse impact process, including assisting her managers in creating the adverse impact matrices. With respect to Exhibits PP, QQ and RR, the evidence establishes that Ms. Sprayberry essentially managed the process through which those exhibits were ultimately created. See Testimony of Deborah Sprayberry, Sealed Transcript of Proceedings Held 3.10/2006 at pp. 142-44. Without question, then, Exhibits PP, QQ and RR related to Ms. Sprayberry’s duties.
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portions of the adverse impact documents are privileged. In his September 13, 2006 order denying plaintiffs’ motion for reconsideration, the magistrate judge held that plaintiffs had waived this argument by not asserting it until the filing of their motion for reconsideration. In the alternative, the magistrate judge concluded that the entirety of the documents at issue, including the information extracted from the Master and RIF Lists (lists which, in any event, had already been produced to plaintiffs)–constituted a communication made in confidence for the purpose of obtaining legal advice such that no portion of the documents were discoverable.
Plaintiffs contend that the magistrate judge’s conclusion that plaintiffs had waived the argument is incorrect. According to plaintiffs, they raised this argument in their January 3, 2006 surreply to defendant’s motion for a protective order precluding plaintiffs from questioning deponents regarding defendant’s adverse impact analyses (doc. 3525); in their January 31, 2006 reply to defendant’s response to plaintiffs’ motion for in camera review of the inadvertently disclosed documents (doc. 3553); and in their February 9, 2006 letter to the magistrate judge. Plaintiffs also assert that their post-hearing brief (doc. 3847) reiterated this argument. The court has carefully reviewed each of the documents referenced by plaintiff and, without exception, finds no such argument therein.
Plaintiffs’ January 3, 2006 surreply; January 31, 2006 reply; and post-hearing brief reflect only plaintiffs’ argument that the entirety of the adverse impact documents are discoverable because the documents consisted of “just numbers,” “mathematical calculations,” and “data compilations”; in other words, as argued by plaintiffs in these briefs, the documents as a whole
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contained only factual information and not legal advice.8 No argument is made that selected
portions of the documents are discoverable even if the documents are otherwise deemed
privileged. While plaintiffs’ February 9, 2006 letter to the magistrate judge addresses the issue
of whether certain portions of the adverse impact documents constitute data summaries as
opposed to legal advice, that issue is addressed in response to the magistrate judge’s specific
request that the parties advise him as to whether “the parties could reach some agreement” about
whether certain portions of each matrix were “data summaries as opposed to legal advice.” In
other words, the issue was actually raised by the magistrate judge in the context of inquiring
whether the parties could come to an agreement as to some portions of the documents and
plaintiffs, in asserting that certain portions were merely data compilations, were responding to
the judge’s request and not asserting an independent argument in connection with the subsequent
evidentiary hearing. Moreover, while it is not entirely clear from plaintiffs’ letter, the letter does
not seem to suggest, like plaintiffs do here, that the “top two boxes” of a given matrix constitute
8In their reply to defendant’s response to their motion to review, plaintiffs, by way of example, state that their January 3, 2006 surreply raised the very argument presented here as follows: “The only portion of the document is that is not a demographic fact or a mathematically-derived percentage based upon these demographic facts is the box which states: ‘Percentage is less than 80%, Possible Adverse Impact.’” A full reading of the passage from which this one sentence is excerpted, however, reveals that plaintiffs were not contending that selected portions of the matrices should be discoverable in the event the documents were otherwise deemed privileged. Rather, plaintiffs were arguing (as they have consistently argued) that the entire document was discoverable because it did not constitute legal advice, as evidenced by the sentence in plaintiffs’ January 3, 2006 surreply that follows the single sentence highlighted by plaintiffs: “This is a recitation of precisely that which Sprint earlier represented to the Court was not law applicable to this request for adverse impact data and therefore it cannot be legal advice as it is not the law.”
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data compilations; rather, the letter suggests only that the “summary numerical demographic information that is contained in the left column” of a given matrix constitutes data compilations that should be produced. In other words, plaintiffs’ letter and plaintiffs’ motion to review appear to challenge two entirely different portions of the matrices. The court, then, concludes that the February 9, 2006 letter is insufficient to preserve the specific issue now raised by plaintiffs.
Plaintiffs also suggest that this argument was made at the hearing itself by virtue of the fact that plaintiffs introduced the deposition testimony of Eric Rice, who testified that the information “in the top two boxes” of a given adverse impact matrix was manually drawn from Master and RIF Lists and the fact that plaintiffs “elicited ‘just numbers’ and ‘no legal advice’ testimony from the witnesses Sprint called at the hearing.” The testimony of Mr. Rice, however, simply establishes that certain information on the adverse impact documents was extracted from the Master and RIF Lists. In and of itself, the testimony does not suggest an argument that the “top two boxes” contains nonprivileged information that should be discoverable even if the document is otherwise deemed privileged. The testimony elicited by plaintiffs from defendant’s witnesses at the hearing simply lends support to the argument that is asserted by plaintiffs in their briefing–that the entirety of the adverse impact documents are discoverable because the information contained therein is factual information (“just numbers” or “mathematical calculations”) and not legal advice. This testimony does not speak to the issue of whether selected portions of the documents should be discoverable in the event the document is otherwise deemed privileged.
For the foregoing reasons, the court affirms the magistrate judge’s conclusion that 21

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plaintiffs waived any argument that selected portions of the adverse impact documents are discoverable. See Minshall v. McGraw Hill Broadcasting Co., 323 F.3d 1273, 1288 (10th Cir. 2003) (argument raised for the first time in reply brief is waived) (citing Coleman v. B-G Maintenance Management, 108 F.3d 1199, 1205 (10th Cir. 1997) (issues not raised in the opening brief are deemed abandoned or waived)). The court, then, declines to address the magistrate judge’s holding regarding the merits of plaintiffs’ argument.
VI. Waiver by Defendant’s Failure to Designate Protection Based on the AttorneyClient Privilege It is undisputed that defendant, in its privilege log, did not designate protection based on
the attorney-client privilege for certain adverse impact documents (Exhibits A through E and Exhibit L). With respect to these documents, defendant asserted protection based only on the work product doctrine. Before the magistrate judge, plaintiffs urged that defendant had waived any assertion of the attorney-client privilege with respect to these particular adverse impact documents by failing to assert the privilege on its privilege log. The magistrate judge did not expressly address this argument in his July 1, 2006 order, but impliedly rejected it by holding that all adverse impact documents were protected from disclosure by the attorney-client privilege.
In his September 13, 2006 order denying plaintiffs’ motion to reconsider, the magistrate judge expressly considered and rejected plaintiffs’ argument. In so doing, the magistrate judge
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first highlighted the language of Federal Rule of Civil Procedure 12(b)(5), which governs notification when a claim of privilege is asserted:
When a party withholds information that is otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner than, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. Fed. R. Civ. P. 26(b)(5). The magistrate judge then concluded that because Exhibits A through E and Exhibit L had been inadvertently disclosed to plaintiffs and then recalled on grounds of attorney-client privilege, the documents were not “withheld” for purposes of Rule 26(b)(5). Thus, the magistrate judge concluded that the notification requirements of Rule 26(b)(5) did not apply to these particular documents and that the disclosure requirements of Rule 26(b)(5) were otherwise satisfied in light of the fact that plaintiffs’ counsel had the opportunity to review the contents of the documents to assess the applicability of the privilege. In their motion to review, plaintiffs assert that the magistrate judge erred in concluding that defendant did not waive the attorney-client privilege with respect to those documents for which defendant, on its privilege log, claimed only work product protection. The magistrate judge’s distinction between those documents which have been withheld and those documents which have been inadvertently produced and then recalled is a reasonable one and is supported by the proposed amendment to Rule 26(b)(5) that will become effective December 1, 2006. Pursuant to that amendment, Rule 26(b)(5) will be amended to contain two subparts, Rule 26(b)(5)(A) and Rule 26(b)(5)(B). Rule 26(b)(5) as it currently reads in its
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entirety will become Rule 26(b)(5)(A) and will be subtitled “Information Withheld.” Rule
26(b)(5)(B), which encompasses the situation addressed by the magistrate judge in this case, will
read as follows:
(B) Information Produced. If information is produced in discovery that is subject to a claim of privilege or of protection as trial-preparation material, the party making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has and may not use or disclose the information until the claim is resolved. A receiving party may promptly present the information to the court under seal for a determination of the claim. If the receiving party disclosed the information before being notified, it must take reasonable steps to retrieve it. The producing party must preserve the information until the claim is resolved.
As noted in the advisory committee notes to the 2006 amendment to Rule 26(b)(5), the current
rule provides a procedure for claiming privilege with respect to information that has been
withheld (typically, by providing a “privilege log”) and the new subdivision provides a
procedure for a party to assert a claim of privilege after the information has been produced in
discovery.
According to the magistrate judge’s analysis, however, the fact that the documents were
inadvertently produced permits defendant to assert a claim of attorney-client privilege after
production even though defendant provided a privilege log identifying these documents as protected only by the work product doctrine.9 The court disagrees. The court understands the
rationale (reflected in the amendment to Rule 26(b)(5)) for drawing a distinction between the
9The issue of whether the privilege that defendant asserted after production was waived as a result of the production itself is not addressed by new Rule 26(b)(5)(B), see adv. comm. notes, and that issue is not raised by plaintiffs in their motion to review.
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treatment of documents which have been withheld and those that are inadvertently produced in those situations where the documents which have been inadvertently produced have not been previously withheld. Here, however, Exhibits A through E and Exhibit L were withheld subject to a privilege log and were later produced inadvertently. An argument can be made, then, that defendant waived the attorney-client privilege with respect to Exhibits A through E and Exhibit L at the time it provided a privilege log asserting only work product protection for these documents. In that case, defendant would have had no privilege to assert once the documents were inadvertently disclosed. The result of the magistrate judge’s order, then, arguably places defendant in a better position for having inadvertently produced documents for which it had already waived the attorney-client privilege.
The magistrate judge, however, is in the best position to evaluate in the context of this case whether defendant, by failing to assert the attorney-client privilege in its privilege log, waived the privilege. The court, then, remands this matter to the magistrate judge to consider whether defendant waived the attorney-client privilege by not asserting that privilege in its privilege log and, if he concludes that defendant did waive the privilege, to consider the merits of defendant’s claim that the documents are protected from discovery by the work product doctrine (an issue that the magistrate judge declined to address in his July 1, 2006 order in light of his conclusion that all the documents were protected by the attorney-client privilege).10
10It appears to the court that the record is complete with respect to the issue of whether defendant waived the privilege by not asserting it in its privilege log and the issue of whether the Exhibits are protected by the work product doctrine. Nonetheless, if the magistrate judge believes he needs additional input from the parties on one or both of these issues, the court
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VII. Waiver by Defendant’s Assertion of Good Faith Compliance with the ADEA
Finally, plaintiffs contend that the magistrate judge erred in rejecting their argument that
defendant’s assertion in its answer to plaintiffs’ second amended complaint that defendant had
engaged in good faith efforts to comply with the ADEA was sufficient to require disclosure of
otherwise privileged communications. In other words, plaintiffs contend that defendant waived
any privilege with respect to the adverse impact documents by affirmatively asserting in its
answer its good faith efforts to comply with the ADEA during the RIF process. In rejecting
plaintiffs’ argument, the magistrate judge concluded that the mere assertion of an affirmative
defense was not sufficient, in and of itself, to “place the advice of counsel at issue.” See Memo.
& Order at 24-25 (July 1, 2006) (citing SmithKline Beecham Corp. v. Apotex Corp., 2005 WL
2436662 (E.D. Pa. Sept. 28, 2005) (“Only if the defendant elects to offer evidence to disprove
the claim, and relies upon the attorney’s advice to do so, will the plaintiff be given access to protected communications.”)).11
suggests that the magistrate judge conduct a hearing, without the need for additional briefing, to expedite the resolution of this matter. In that regard, the court requests that the magistrate judge resolve this matter no later than December 8, 2006.
11It appears that the magistrate judge, by citing the Eastern District of Pennsylvania case and noting that defendant had not placed the “advice of counsel at issue,” impliedly held plaintiffs to the most restrictive approach to waiver adopted by the Third Circuit in RhonePoulenc Rorer Inc. v. Home Indem. Co., 32 F.3d 851, 863-64 (3d Cir. 1994). The court need not decide whether the Circuit would adopt this approach because, as explained in the text, the court concludes that the Circuit would reject the liberal approach to waiver urged by plaintiffs. See Frontier Refining Inc. v. Gorman-Rupp Co., 136 F.3d 695, 699-700 (10th Cir. 1998) (explaining three general approaches to waiver–the liberal “automatic waiver” rule; an intermediate test set forth by Hearn v. Rhay, 68 F.R.D. 574 (E.D. Wash. 1975), which provides that the privilege is waived only when the material to be discovered is both relevant
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Plaintiffs’ argument–that defendant in this case has waived the attorney-client privilege by merely asserting in its answer that it acted in “good faith”–necessarily requires an application of the “automatic waiver” rule. As explained by the Tenth Circuit, the automatic waiver rule “provides that a litigant automatically waives the privilege upon assertion of a claim, counterclaim, or affirmative defense that raises as an issue a matter to which otherwise privileged material is relevant.” Frontier Refining Inc. v. Gorman-Rupp Co., 136 F.3d 695, 699 (10th Cir. 1998). The “automatic waiver” rule, however, has been flatly rejected by the Tenth Circuit in Frontier. In concluding that Wyoming would not adopt the “automatic waiver” rule,12 the Circuit explained that the rule “has been roundly criticized in the circuits, does not adequately account for the importance of the attorney-client privilege to the adversary system, and is more applicable to constitutional, rather than attorney-client, privileges.” Id. at 700. Thus, plaintiffs’ argument that defendant waived the privilege simply by asserting “good faith” in its answer is foreclosed by Frontier and the magistrate judge correctly rejected the argument.
Plaintiffs, however, further contend that the magistrate judge’s ruling disregards and is contrary to Cox v. Administrator U.S. Steel & Carnegie, 17 F.3d 1386 (11th Cir. 1994), a
to the issues raised in the case and either vital or necessary to the opposing party’s defense of the case; and a restrictive test pursuant to which a litigant waives the privilege only if he directly puts the attorney’s advice at issue in the litigation).
12Although the Circuit in Frontier was predicting Wyoming law in a diversity case, the Circuit, concluding that the Wyoming Supreme Court had not directly announced a definitive test for waiver of attorney-client privilege, expressly looked to “other state-court decisions, well-reasoned decisions from other jurisdictions, and any other available authority to determine the applicable state law.” 136 F.3d at 700. Thus, there is no reason to believe that the Circuit would reach a contrary result under federal law.
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decision which, in turn, relies on United States v. Bilzerian, 926 F.2d 1285 (2d Cir. 1991). In Cox, the Eleventh Circuit concluded that one of the defendants in the RICO action had waived the attorney-client privilege by injecting into the case the issue of its knowledge of the law and its asserted belief that its actions were lawful. 17 F.3d at 1418-19. Significantly, that defendant had “consistently taken the position” that it believed its conduct to be lawful and, in support of its contention, intended to present evidence tending to show that it intended to comply with the law. See id. at 1418. Similarly, the criminal defendant in Bilzerian announced prior to trial his intention to testify that he believed in good faith that certain disclosures he made to the SEC were legal. See id. at 1419. The district court advised the defendant that his testimony in that regard would be sufficient to waive the attorney-client privilege and the Second Circuit affirmed that decision. Id. (citing Bilzerian, 926 F.2d at 1292).
The record before the court does not reflect whether the circumstances present in Cox and Bilzerian are present in this case. In other words, the court cannot discern on the record before it what defendant means by its use in its answer of the phrase “good faith” and, more specifically, the facts on which defendant bases its “good faith” assertion (e.g., defendant’s legal department advised defendant that its RIF decisions did not run afoul of the ADEA; it had general knowledge of the ADEA’s requirements and did not believe its RIF decisions violated the ADEA). In turn, the court does not know whether what defendant does mean by “good faith” and the facts upon which that assertion is based are sufficient to trigger a waiver of the privilege. For these reasons, this portion of plaintiffs’ motion is retained under advisement and the court will conduct a telephone conference on Thursday, November 16, 2006 at 2:00pm to permit
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defendant to explain (and plaintiffs to respond to that explanation) to the court the meaning of the phrase “good faith” as that phrase is used in defendant’s answer and to further explain to the court the factual basis for defendant’s “good faith” assertion.
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motions for review (docs. 3605 and 4338) are granted with respect to Exhibits A through E and Exhibit L and the court remands to the magistrate judge the issue of whether defendant waived the attorney-client privilege with respect to these Exhibits by not asserting that privilege in its privilege log and, if he concludes that defendant did waive the privilege, to consider the merits of defendant’s claim that the documents are protected from discovery by the work product doctrine. The motions are retained under advisement with respect to plaintiffs’ assertion that defendant waived the attorney-client privilege by asserting its “good faith” compliance with the ADEA. The motions are otherwise denied.
IT IS FURTHER ORDERED THAT the court will conduct a telephone conference on Thursday, November 16, 2006 at 2:00pm to hear additional argument concerning whether defendant has waived the attorney-client privilege by asserting its “good faith” compliance with the ADEA.
IT IS SO ORDERED.
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Case 2:03-cv-02200-JWL-DJW Document 4404-1 Filed 11/09/06 Page 30 of 30 Dated this 9th day of November, 2006, at Kansas City, Kansas. s/ John W. Lungtrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4423 Filed 11/16/2006 Page 1 of 9

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b). This matter is presently before the court on plaintiffs’ motion to review (doc. 4102) and objections to paragraph 8 of the magistrate judge’s April 25, 2006 order as well as plaintiffs’ motion to review (doc. 4334) and objections to paragraph 8 of the magistrate judge’s April 25, 2006 order; the magistrate judge’s July 10, 2006 order; and the magistrate judge’s September 13, 2006 order. As will be explained, the motions are granted and this matter is again remanded to the magistrate judge for factual findings concerning and an explanation of the reasons for the denial of plaintiffs’ motion for sanctions.

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Procedural History On February 15, 2006, plaintiffs filed an omnibus motion seeking to amend the
scheduling order, to compel defendant to produce various documents and to permit plaintiffs access to defendant’s computer system, and for sanctions against defendant for failing to produce “spreadsheet materials” in native format, for failing to timely produce other spreadsheet materials and for re-producing spreadsheet materials in non-native format that had already been produced in native format. The magistrate judge resolved plaintiffs’ motion in open court on April 20, 2006 and his ruling on the motion was memorialized in paragraph 8 of an order dated April 25, 2006. Pertinent to the motions to review pending before this court, the magistrate judge denied plaintiffs’ motion to the extent it sought sanctions against defendant.
On May 9, 2006, plaintiffs filed a motion to review (doc. 4102) and objections to paragraph 8 of the magistrate judge’s April 25, 2006 order in which the magistrate judge denied plaintiffs’ motion to compel discovery and to sanction defendant. On June 30, 2006, this court concluded that it was unable to review the order because the magistrate judge did not include in his order any factual findings pertinent to the resolution of the motion to compel and for sanctions. While the court recognized that the magistrate judge’s April 25, 2006 order was merely a summary of the judge’s prior oral rulings and, thus, the record certainly included the judge’s statements made at the April 20, 2006 hearing, neither the April 25, 2006 order nor the transcript of the April 20, 2006 hearing addressed the substance of the sanctions issue. The court, then, retained the motion to review under advisement and remanded the matter to the magistrate judge to render factual findings sufficient to permit the court to ascertain whether the
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magistrate judge properly exercised his discretion in resolving the underlying motion. On July 10, 2006, the magistrate judge issued an order in response to the court’s request
for additional factual findings. In that order, the magistrate judge simply set forth in writing the factual findings that he had made orally during the April 20, 2006 conference. With respect to plaintiffs’ motion for sanctions, the magistrate judge simply stated, “I think the best approach so far is to avoid those when we can.” On July 24, 2006, plaintiffs filed a motion asking the magistrate judge to reconsider or clarify his July 10, 2006 order by making specific factual findings regarding plaintiffs’ motion for sanctions. On September 13, 2006, the magistrate judge denied the motion to reconsider and, thereafter, plaintiffs filed a motion to review (doc. 4334) each of the orders relating to the magistrate judge’s denial of plaintiffs’ motion for sanctions–paragraph 8 of the April 25, 2006 order; the magistrate judge’s July 10, 2006 factual findings; and the magistrate judge’s September 13, 2006 order.
Discussion Plaintiffs seek review of the magistrate judge’s April 25, 2006; July 10, 2006; and
September 13, 2006 orders to the extent the magistrate judge denied plaintiffs’ motion for sanctions. Plaintiffs assert that those orders are clearly erroneous because they “contain little or no analysis of the underlying facts.” Plaintiffs further suggest that because of this deficiency, the magistrate judge’s orders are entitled to no deference from this court and this court should exercise a de novo review of plaintiffs’ motion for sanctions. Toward that end, plaintiffs simply reassert to this court, nearly verbatim, the argument it made to the magistrate judge–a lengthy,
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detailed account of defendant’s “assorted and continuing improper conduct” concerning the production of spreadsheet documents since April 2005. Defendant, in response, contends that the court should simply deny the motions to review because the magistrate judge’s conclusion is correct and is supported by previous “good faith” findings made by the magistrate judge.
Before examining the magistrate judge’s previous findings of defendant’s good faith, the court examines the findings made by the magistrate judge concerning plaintiffs’ motion for sanctions. In their February 15, 2006 motion, plaintiffs sought sanctions against defendant for three separate alleged abuses: failing to produce all “spreadsheet materials” in native format; failing to timely produce spreadsheet materials that were produced; and re-producing spreadsheet materials in non-native format that had already been produced in native format. The magistrate judge ruled on this motion in open court on April 20, 2006 and the court has reviewed the transcript of that proceeding in its entirety. In addressing plaintiffs’ motion to compel defendants to produce RIF spreadsheets in native format, the magistrate judge asked counsel for defendant whether all responsive spreadsheets had been produced. Counsel for defendant replied that defendant had produced all responsive spreadsheets. Based on this representation, coupled with plaintiffs’ inability to identify a specific spreadsheet that they believed had not been produced in native format, the magistrate judge concluded that defendant had met its obligation. Thus, the magistrate judge denied plaintiffs’ motion to compel on this issue, but permitted plaintiffs an opportunity to file a new motion to compel addressing with more specificity what documents they believed needed to be produced.
The court then denied plaintiffs’ request for access to defendant’s computer system and 4

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turned to the request for sanctions. With respect to plaintiffs’ request for sanctions, the magistrate judge simply stated,
And finally, there’s a request for sanctions. And at this point, that’s denied, also. I think the best approach so far is to avoid those when we can. The magistrate judge then proceeded to resolve other pending motions unrelated to plaintiffs’ omnibus motion. Thus, while the magistrate judge’s oral ruling arguably gives insight into why he denied plaintiffs’ request for sanctions to the extent that request was based on defendant’s failure to produce all spreadsheets in native format (i.e., he concluded in the context of the motion to compel that all documents had been produced and that defendant had met its production obligation), the judge’s oral ruling is devoid of any facts remotely suggesting why he denied plaintiffs’ request for sanctions to the extent that request was based on defendant’s failure to timely produce spreadsheet materials that were produced and defendant’s re-production of spreadsheet materials in non-native format that had already been produced in native format. Moreover, as previously explained in this court’s June 30, 2006 order, the magistrate judge’s April 25, 2006 written order memorializing his April 20, 2006 ruling offers no additional insight into why he denied the motion for sanctions. Rather, that written order simply stated that “for the general reasons stated on the record . . . the motion for sanctions is denied.” Unfortunately, the magistrate judge’s July 10, 2006 order is not responsive to this court’s request that the magistrate judge, based on his intimate knowledge of the course of discovery in this case, render factual findings concerning defendant’s conduct with respect to the discovery disputes at issue and make some explanation of the rationale for his decision. In his July 10
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order, the magistrate judge simply submitted “the following factual findings that were made at the April 20, 2006 discovery/status conference but were regrettably not included in the April 25, 2006 order.” He then summarized the transcript of the April 20, 2006 hearing and, with respect to the sanctions issue, stated: “The magistrate judge denied Plaintiffs’ request for sanctions, advising the parties that ‘I think the best approach so far is to avoid those when we can.’” It appears, then, that the magistrate judge mistakenly believed that, in supplementing the record, he was somehow limited to what he had said previously in open court and could not expand or further explain that reasoning in the July 10, 2006 order.
Ultimately, the magistrate judge has not fulfilled this court’s charge to provide factual findings and analysis sufficient to permit this court to perform a meaningful review of his decision denying plaintiffs’ motion for sanctions. Indeed, the only reason he has provided for denying the request for sanctions (his desire to “avoid” sanctions when possible) is legally insufficient. The court turns, then, to defendant’s argument that the magistrate judge has previously found that defendant has acted in good faith in connection with the production of spreadsheets in native format. According to defendant, the magistrate judge’s denial of plaintiffs’ motion for sanctions is supported by the magistrate judge’s February 8, 2006 order in which he held that defendant “provided an adequate explanation of why it has not completed production of all spreadsheets in their native, electronic format” that defendant had previously produced in non-native format. Contrary to defendant’s suggestion, this order simply does not provide the requisite factual basis for denying plaintiffs’ subsequent motion for sanctions. The order does not address two of the three issues raised by plaintiffs in their motion for sanctions
6

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(failing to timely produce spreadsheets all along and reproducing certain spreadsheets). Moreover, plaintiffs’ motion for sanctions had not yet been filed and, thus, the magistrate judge did not have the benefit of the arguments therein and, at the time of the February 8, 2006 order, was not examining defendant’s conduct in the face of a request for sanctions but only to determine whether defendant had shown cause, in response to the magistrate judge’s order to do so, why all responsive spreadsheets had not been produced by February 2, 2006, a deadline established by the magistrate judge for production.
Defendant also suggests that a February 2, 2006 order from the magistrate judge supports the judge’s decision to deny sanctions. Again, the court disagrees. The February 2, 2006 order addressed only whether defendant had waived the attorney-client privilege with respect to certain spreadsheets for failing to produce timely a privilege log asserting the privilege. In determining that defendant had not waived the privilege based on its untimely submission of a privilege log, the magistrate judge found no evidence that defendant had acted in bad faith and that defendant had made “good faith attempts” at compliance. While defendant would have this court interpret the February 2, 2006 order as a general finding of defendant’s good faith for all purposes in the discovery context, the court declines to do so as the magistrate judge’s findings in that order are clearly limited to the privilege log context.
The court, then, is left with no factual findings to review concerning the magistrate judge’s denial of plaintiffs’ motion for sanctions. Nonetheless, the court rejects plaintiffs’ suggestion that it resolve the issue de novo. That approach would be both inefficient and illogical. As the court highlighted in its June 30, 2006 order, plaintiffs’ motion is highly fact-
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specific and the magistrate judge is the person with first-hand knowledge of those facts and the parties’ conduct throughout the course of what has been a lengthy and vigorously contested discovery process involving large volumes of materials and greater than normal complexity. Because of his intimate knowledge with this case, he must tell this court and the parties what facts and what in his experience, based on his first-hand involvement with the discovery process over the past two years, led him to conclude that sanctions against defendant for the reasons requested by plaintiffs are not warranted. The court reiterates that these factual findings need not be lengthy; but they do need to be responsive to the issue. See Thompson v. Boggs, 33 F.3d 847, 858 n.9 (7th Cir. 1994) (although magistrate judge was not required to make detailed findings of fact, “a brief statement of the reasons for denying the motion would be beneficial to the litigants as well as facilitate meaningful appellate review”).
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion to review (doc. 4102) and objections to paragraph 8 of the magistrate judge’s April 25, 2006 order and plaintiffs’ motion to review (doc. 4334) and objections to paragraph 8 of the magistrate judge’s April 25, 2006 order; the magistrate judge’s July 10, 2006 order; and the magistrate judge’s September 13, 2006 order are both granted. This matter is remanded to the magistrate judge for factual findings concerning the denial of plaintiffs’ motion for sanctions. If plaintiffs remain aggrieved after the issuance of the magistrate judge’s factual findings, they may file a new motion to review.
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Case 2:03-cv-02200-JWL-DJW Document 4423 Filed 11/16/2006 Page 9 of 9 IT IS SO ORDERED. Dated this 16th day of November, 2006, at Kansas City, Kansas. s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4461 Filed 12/08/06 Page 1 of 29

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant. MEMORANDUM & ORDER
Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b).
This matter is presently before the court on that portion of plaintiffs’ motions to review (docs. 3605 and 4338) that the court retained under advisement in its November 9, 2006 memorandum and order; specifically, whether defendant waived the attorney-client privilege by asserting its “good faith” compliance with the ADEA. As will be explained, the court now denies that portion of plaintiffs’ motions and concludes that defendant has not waived the privilege by asserting its good faith compliance with the ADEA.

I. Background Plaintiffs’ motions to review challenged several orders issued by the magistrate judge in

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which he concluded that certain documents relating to adverse impact analyses conducted by defendant are protected from discovery by the attorney-client privilege.1 Specifically, the magistrate judge concluded that the adverse impact documents constituted communications made for the purpose of obtaining legal advice and at the direction of counsel, that the documents were kept confidential and that defendant had not waived the privilege in any respect. In their motions to review, plaintiffs asserted, among other things, that the magistrate judge erred in concluding that defendant had not waived the privilege by asserting its “good faith” compliance with the ADEA.
On November 9, 2006, this court issued its memorandum and order concerning plaintiffs’ motions to review. The court denied the motions to review in all but two respects–the court remanded to the magistrate judge the issue of whether defendant waived the attorney-client privilege with respect to certain documents for which defendant, on its privilege log, claimed only work product protection (that issue remains pending before the magistrate judge); and the court retained under advisement the issue of whether defendant’s assertion that it had engaged in “good faith” efforts during the RIF process to comply with the ADEA was sufficient to require disclosure of the adverse impact documents. With respect to that issue, the court explained that it could not discern on the record before it the facts on which defendant intended to base its assertion that it engaged in good faith efforts to comply with the ADEA and, thus, could not discern whether those facts would be sufficient to trigger a waiver of the privilege.
1For a more detailed explanation of the “adverse impact” issue in the context of this case, the reader is directed to this court’s November 9, 2006 memorandum and order.
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The court, then, held a telephone conference on November 16, 2006 to permit defendant
to explain (and plaintiffs to respond to that explanation) to the court the meaning of the phrase
“good faith” as that phrase is used in defendant’s answer and to further explain to the court the
factual basis for defendant’s “good faith” assertion. Thereafter, the court directed the parties to
file supplemental briefs on the waiver issue. That briefing is now complete and the issue is ripe
for the court’s resolution.2
II. Discussion
Plaintiffs urge that defendant’s assertion that it engaged in “good faith” efforts during the
2In their supplemental brief, defendant challenges certain statements that it believes the court made during the November 16, 2006 telephone conference with the parties. Specifically, defendant asserts that the court indicated that a party may assert the attorneyclient privilege for only two reasons–to simply vindicate the privilege for its own sake or to hide misdeeds–and that the court suggested that it believed that defendant was asserting the privilege to hide its misdeeds. Defendant insists that the court’s underlying premise is “foreign to American law” and that the privilege exists to encourage clients to approach lawyers for advice and thereby prevent problems and further objects to the court’s “acceptance” of plaintiffs’ argument that defendant has engaged in misdeeds.
The court has reviewed the transcript from the hearing and finds that defendant’s recollection of the court’s comments is inaccurate. In fact, the court stated that “there are a number of reasons for a party to vigorously assert the attorney-client privilege” and proceeded to identify only two of those reasons–vindicating the privilege itself and protecting from disclosure information that is harmful to the party asserting the privilege. In highlighting the “hiding misdeeds” rationale, the court did not mean to suggest that it believed that defendant was hiding misdeeds. Rather, the court expressly stated that it was drawing that inference only for purposes of the discussion–a discussion in which the court asked a series of pointed questions to defendant’s counsel concerning defendant’s “good faith” defense based on what the court perceived as plaintiffs’ arguments and evidence concerning the waiver issue.
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RIF process to comply with the ADEA is sufficient to require disclosure of documents reflecting adverse impact analyses conducted by defendant. As explained by defendant, it asserted its “good faith” in its answer to plaintiffs’ revised second amended complaint only to negate plaintiffs’ claims that defendant committed willful violations of the ADEA.3 Defendant asserts that it does not intend to rely on the adverse impact analyses or the advice of counsel in support of its “good faith” defense. Rather, defendant intends to rely on its anti-discrimination policies, the training that its employees received concerning those anti-discrimination policies and certain “due diligence” conducted by its Human Resources managers in reviewing RIF selection decisions to ensure that those decisions were justified by legitimate, nondiscriminatory reasons.4
Plaintiffs argue that defendant’s reliance on its anti-discrimination policies and the “due diligence” conducted by its Human Resources managers to prove defendant’s good faith compliance are both sufficient to trigger a waiver of the privilege with respect to the adverse impact documents. Plaintiffs further assert that the deposition testimony of defendant’s witnesses during discovery concerning reliance on the advice of counsel is sufficient to trigger a waiver of the privilege concerning the adverse impact documents.
3Although defendant asserted its “good faith” compliance as an affirmative defense in its answer to plaintiffs’ revised second amended complaint, the court has previously rejected plaintiffs’ argument that defendant had automatically waived the privilege merely by asserting “good faith” in its answer. See Frontier Refining Inc. v. Gorman-Rupp Co., 136 F.3d 695, 699-701 (10th Cir. 1998).
4In addition, defendant intends to rely on the candidate selection worksheets utilized during the RIF process, relevant information from its HRIS database and “reasonable factors other than age” that its management used making RIF selection decisions. Plaintiffs do not assert that defendant’s reliance on this evidence constitutes a waiver of the privilege.
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In resolving the waiver issue, the court first examines the pertinent case law and then
analyzes each of these specific categories of evidence with reference to that case law.5
A. Pertinent Legal Standards Concerning Waiver
As explained by the Tenth Circuit in Frontier Refining Inc. v. Gorman-Rupp Co., 136
F.3d 695, 699 (10th Cir. 1998), courts generally employ some version of one of three general
approaches to determine whether a litigant has waived the attorney-client privilege. The first
of these approaches is the “automatic waiver” rule whereby a litigant waives the privilege upon
the mere assertion of a claim, counterclaim, or affirmative defense that raises as an issue a matter
to which otherwise privileged material is relevant. This court, in its November 9, 2006
5In their most recent brief, plaintiffs contend that a ruling from the court that defendant has not waived the privilege (rendering “off limits” any reference at trial to the adverse impact analyses) could inhibit plaintiffs from introducing evidence of defendant’s awareness of the EEOC’s “eighty percent” or “four-fifths” rule, as that evidence loses context in the absence of evidence concerning adverse impact analyses. The court declines to address at this juncture plaintiffs’ intent to introduce evidence concerning defendant’s knowledge of the four-fifths rule, as plaintiffs’ argument does not bear on whether, in the first instance, defendant has waived the privilege due to its assertion of a good faith defense.
Similarly, plaintiffs raise two arguments concerning the use of expert testimony at trial. First, plaintiffs state that defendant should not be able to have an expert testify about the results of his or her adverse impact testing (presumably showing that the results of those tests indicate that no discrimination occurred) when defendant, during the RIF itself, performed its own adverse impact testing allegedly showing that discrimination had occurred. Second, plaintiffs contend that if plaintiffs’ experts, in performing an adverse impact analysis on behalf of plaintiffs, perform a statistical analysis at the Vice President level and defendant criticizes plaintiffs’ experts for that methodology, then plaintiffs should be able to show that defendant itself performed adverse impact analyses at the Vice President level during the RIF. Again, as these arguments do not bear on the issue before the court today, the court declines to address the merits of these arguments at this juncture.
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memorandum and order, concluded that the Circuit would reject this liberal approach to waiver. The “intermediate” approach to waiver provides that the privilege is waived “only when the material to be discovered is both relevant to the issues raised in the case and either vital or necessary to the opposing party’s defense of the case.” Id. (citing Hearn v. Rhay, 68 F.R.D. 574, 581 (E.D. Wash. 1975). The final, more restrictive approach provides that the privilege is waived only if the litigant directly puts the attorney’s advice at issue in the litigation. Id. at 699700 (citing Rhone-Poulenc Rorer Inc. v. Home Indem. Co., 32 F.3d 851 (3d Cir. 1994).
While the Tenth Circuit in Frontier did not need to choose between the intermediate and more restrictive approaches to waiver, this court has advised the parties (during the November 16, 2006 telephone conference) that it believes the Circuit would adopt the intermediate approach as applied by the court in Hearn v. Rhay in light of its tendency to eschew bright-line rules in favor of more flexible, balancing tests in the context of employment discrimination cases. Under the Hearn test, each of the following three conditions must exist to find waiver: (1) assertion of the privilege was the result of some affirmative act, such as filing suit, by the asserting party; (2) through this affirmative act, the asserting party put the protected information at issue by making it relevant to the case; and (3) application of the privilege would have denied the opposing party access to information vital to its defense. Id. at 701 (quoting Hearn, 68 F.R.D. at 581). A court, then, should find that the party asserting a privilege has impliedly waived that privilege through his own affirmative conduct when the party “places information protected by it in issue through some affirmative act for his own benefit, and to allow the privilege to protect against disclosure of such information would [be] manifestly unfair to the
6

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opposing party.” Hearn, 68 F.R.D. at 581.
B. Anti-Discrimination Policies During the November 16, 2006 telephone conference and in its supplemental briefing to
the court, defendant has asserted that it will demonstrate its “good faith” compliance with the ADEA by reliance on its anti-discrimination policies and the training that its employees received concerning those anti-discrimination policies. Plaintiffs contend that defendant’s reliance on those policies is sufficient to waive the privilege with respect to adverse impact analyses because those policies contain express provisions concerning “disparate impact analysis” and the legal department’s role in that analysis.6 According to plaintiffs, any contrary result would preclude plaintiffs from testing defendant’s adherence to its anti-discrimination policies and defendant’s asserted belief that its anti-discrimination policies were effective. Defendant, in turn, argues that an employer does not waive the attorney-client privilege by merely incorporating a written “legal review” requirement into its RIF guidelines. As explained below, the court concludes that
6Plaintiffs also state that the adverse impact analyses are inextricably merged with the “intent” element of plaintiffs’ claims because those analyses are the “only device by which Sprint’s knowledge of unlawful discrimination might be directly proved.” The court rejects plaintiffs’ suggestion that having an “intent” element as part of one’s burden of proof is sufficient to waive the privilege if protected documents would assist in proving that element. Otherwise, each and every discrimination claim “would pry open the privilege for [the plaintiff’s] indulgence.” See Ward v. Succession of Freeman, 854 F.2d 780, 786-87 (5th Cir. 1988) (rejecting plaintiffs’ argument that having scienter element as part of burden of proof in securities fraud case was sufficient for showing “good cause” for suspending the privilege under rule in litigation involving a corporation and its shareholders that shareholders may have access to otherwise privileged information upon a showing of good cause).
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defendant has not waived the privilege by referencing “disparate impact” review or “legal review” in its anti-discrimination policies.7
Before analyzing the parties’ argument, the court must ascertain the specific “anti-
discrimination policies” upon which defendant intends to rely in support of its good faith
defense. Defendant has not identified any particular policy and plaintiffs have submitted to the
court a “small sample” of what they contend amounts to “hundreds of pages of . . . written
policies and mandatory guidelines.” Defendant’s reference to “anti-discrimination policies” and
the training employees received concerning those policies clearly implies an intent to rely on
official statements of policy or procedure that have been adopted (formally or otherwise) by
defendant. While the record reflects that defendant maintains general nondiscrimination policies
and statements in the employment context, see Kissinger Depo. at 29 (Jan. 18, 2005) and 342-44 (Dec. 18, 2003),8 none of those policies are before the court and plaintiffs do not suggest that
7In its initial brief to the court, defendant contends that the court should not consider plaintiffs’ argument that defendant waived the privilege by expressly including in its policies a reference to “disparate impact” testing or “legal review.” According to defendant, plaintiffs’ argument was not presented in their initial motion to review and is thus inappropriately presented at this late stage. The court rejects this argument. While plaintiffs did not raise the specific issue of the contents of defendants’ policies before the magistrate judge or in their motion to review, plaintiffs obviously raised the “waiver by assertion of good faith defense” argument and only through prompting by the court and supplemental briefing did the specific components of that defense–including defendant’s reliance on its policies–become clear.
8All references to the “Kissinger” deposition refer to the 30(b)(6) deposition of James Kissinger, defendant’s Senior Vice President of Human Resources, whom defendant designated as its representative to testify about the policies and procedures of defendant’s human resources department.
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defendant’s reliance on those general policies would result in a waiver of the attorney-client privilege. With respect to the specific context of a reduction in force, the record reflects that a document entitled “Workforce Reduction Guidelines” (referred to by the parties as Exhibit 8 and bearing Bates-stamp numbers SPR-W010960 et seq.) is the only written company-wide policy, practice or procedure concerning the implementation of a reduction in force. See Kissinger Depo. at 345 (Dec. 18, 2003). Defendant’s Workforce Reduction Guidelines are distributed to defendant’s Human Resources department for use in working with line managers to facilitate a reduction in force. See Kissinger Depo. at 29 (Jan. 18, 2005). The Workforce Reduction Guidelines are mandatory and the managers utilizing the guidelines are expected to follow the steps outlined in the guidelines. See Kissinger Depo. at 35 (Dec. 17, 2003). The Workforce Reduction Guidelines, then, appear to be the type of official policy adopted by defendant upon which defendant intends to rely to prove its good faith defense.9
The court cannot conclude that any other documents before it constitute the type of “policy” on which defendant intends to rely to support its good faith defense. While plaintiffs have submitted numerous pages of documents that they summarily assert constitute “defendant’s policies and procedures,” the record does not support this conclusion. The vast majority of the documents submitted by plaintiffs appear to be stray e-mails referencing “adverse impact” or the
9The court need not resolve whether any portion of the Workforce Reduction Guidelines constitutes an “anti-discrimination policy” as defendant has not challenged plaintiffs’ assertion that it does constitute such a policy. Moreover, Mr. Kissinger testified that the Workforce Reduction Guidelines’ express reference to “discrimination” on the “Planning Checklist” incorporates defendant’s general policies prohibiting discrimination. See Kissinger Depo. at 29-30 (Jan. 18, 2005).
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need for “legal review” of selection decisions. In the context of the motion to review, however, the key is whether defendant has waived the privilege by its assertion of a “good faith” defense–a defense that it intends to prove by reliance on its anti-discrimination policies. There is no indication that defendant is intending to rely on these e-mails to prove its good faith defense. Rather, defendant is relying on its employees’ knowledge of defendant’s policies concerning nondiscrimination and the effectiveness of those policies. Even under the most liberal definition, the e-mails and other documents submitted by plaintiffs do not constitute “antidiscrimination policies.”
The court turns back, then, to the Workforce Reduction Guidelines. For purposes of the waiver issue, only two pages of that multi-page document are pertinent. The second page of the Guidelines is entitled “Planning Checklist” and it lists a “number of topics, issues, or actions that may be relevant in planning a workforce reduction depending on the circumstances.” The document then lists via bullet points fifteen (15) topics or issues, including topics such as “placement to avoid reduction,” “advance notice, timing and coordination of notification,” and “confidentiality.” The fourth topic on the list is “Discrimination or Disparate Impact,” and the ninth topic on the list is “Coordination with Law Department.” The third page of the Guidelines is entitled “Displacement Guidelines” and it sets forth “guidelines for selecting employees for reduction . . . in descending order of importance.” This page directs the recipient, when reviewing “same site multiple job incumbents” to “formally consider” the qualifications of each incumbent; recent performance ratings, attendance, total contribution, critical skill sets and knowledge of each incumbent; any corrective action notices or warnings; and length of service
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within the company and within the position. The recipient is then directed to “review planned displacement action with the Law Department and Corporate Employee Relations in advance for disparate impact analysis.”10
The court concludes that the mere fact that the Workforce Reduction Guidelines contain express provisions concerning “disparate impact” and coordination or counseling with defendant’s legal department is insufficient to trigger a waiver of the privilege with respect to the adverse impact analyses. The court does not dispute plaintiffs’ argument that defendant’s adverse impact analyses and its consultation with counsel are relevant to the overall effectiveness of the Workforce Reduction Guidelines; indeed, those concepts are expressly contained in the Guidelines themselves.11 As suggested by the Tenth Circuit in Frontier, however, the mere fact that privileged material is relevant to a matter that is raised as an issue in connection with the assertion of an affirmative defense is insufficient to trigger a waiver. See Frontier, 136 F.3d at 699 (“automatic waiver” rule provides that a litigant “automatically waives the privilege upon
10Although the phrases “disparate impact” and “disparate impact analysis” are utilized in the Workforce Reduction Guidelines, there is no dispute that the phrase “disparate impact” is interchangeable with “adverse impact.” To avoid confusion and to be consistent with prior orders focusing on “adverse impact analyses,” the court in this order uses only the phrase “adverse impact.”
11Even if those concepts were not expressly contained in the Guidelines, adverse impact analyses and consultation with counsel would nonetheless be pertinent to the issue of whether the Guidelines were effective if defendant otherwise required (though not in writing) its managers to consult with counsel about selection decisions. Certainly, the court would not find a waiver in those circumstances and the court does not believe that the waiver analysis is altered by the mere fact the defendant elected to express that requirement in the Guidelines themselves.
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assertion of . . . an affirmative defense that raises as an issue a matter to which otherwise privileged material is relevant”). In other words, the mere fact that the Guidelines expressly require consultation with counsel or adverse impact testing, standing alone, should not trigger a waiver of the privilege. Rather, as explained in Hearn, the key is whether defendant will “assert the privilege in aid of” or “invoke the privilege in furtherance of” its argument that it complied in good faith with the ADEA in part because of the effectiveness of and its adherence to its anti-discrimination policies, including the Workforce Reduction Guidelines. Hearn, 68 F.R.D. at 581.
Defendant urges that it will not assert the privilege in furtherance of its good faith defense in the sense that it will not rely on any evidence which would cause it to open the door to an inquiry from plaintiffs which would then, in turn, cause defendant to assert the privilege. According to defendant, it will tout its good faith compliance with the ADEA and the effectiveness of its policies without reference to the adverse impact analyses and without reference to consultation with counsel. Instead, it will focus solely on the remaining aspects of the Workforce Reduction Guidelines and other anti-discrimination policies, including requirements that managers consider factors such as performance ratings, attendance, knowledge and experience, length of service and corrective action notices. In other words, defendant will not attempt to prove its good faith, tout the effectiveness of its policies, or otherwise justify any selection decisions by relying on advice of counsel or the results or performance of any adverse impact analyses; it will defend its selection decisions based on grounds wholly separate from advice of counsel and adverse impact testing. In such circumstances, the court believes that
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defendant may rely on its adherence to and the effectiveness of its policies, including the Workforce Reduction Guidelines, without requiring an examination of the adverse impact analyses or otherwise protected communications. The privilege, then, has not been waived. See Motley v. Marathon Oil Co., 71 F.3d 1547, 1552 (10th Cir. 1995) (no waiver of privilege where defendant did not justify termination decision on the basis of advice of counsel and did not claim that termination was based on recommendation from counsel).
In keeping with its assertion that it does not intend to rely on any adverse impact analyses or consultation with counsel in discussing its anti-discrimination policies or the Workforce Reduction Guidelines, defendant suggests that the references to “disparate impact” and coordination or counseling with the legal department be redacted from the Workforce Reduction Guidelines and that plaintiffs be prohibited from inquiring about whether defendant’s managers consulted with counsel in implementing the reduction in force and whether those managers were advised about the results of any adverse impact analyses. The court is persuaded that this approach is an appropriate one. While plaintiffs contend that the documents should not be redacted and that, in the absence of a waiver finding, they should be permitted to introduce evidence that adverse impact analyses were required by the Workforce Reduction Guidelines but defendant should be prohibited from introducing evidence that those analyses were performed, leaving the jury with the inference that defendant did not adhere to its policy. This is not a reasonable solution to the issue. Because the court has concluded that defendant has not waived the privilege by including express provisions in its policy concerning adverse impact analyses and the need for legal review, it would be inappropriate to permit plaintiffs to inquire about such
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testing and then force defendant to either invoke the privilege in the jury’s presence (creating the negative inference desired by plaintiffs) or waive the privilege by responding to the question. See Nabisco, Inc. v. PF Brands, Inc., 191 F.3d 208, 225-56 (2d Cir. 1999) (“[W]e know of no precedent supporting [an adverse] inference based on the invocation of the attorney-client privilege.”), overruled on other grounds sub nom. Moseley v. Secret Catalogue, 537 U.S. 418 (2003).
Plaintiffs also contend that the redaction approach suggested by defendant creates additional problems because then the Workforce Reduction Guidelines are left devoid of any reference for the need to avoid discrimination in selection decisions, prompting plaintiffs to highlight for the jury that defendant’s Workforce Reduction Guidelines do not even address the topic of discrimination. The court rejects this argument as well. Redaction of the phrase “disparate impact” still leaves a reference to “discrimination” on the Planning Checklist page of the Guidelines and it is this reference to “discrimination” that Mr. Kissinger testified was intended to incorporate into the Guidelines defendant’s general nondiscrimination policies. Plaintiffs, then, would not be able to suggest that the Guidelines did not address the topic of discrimination. In any event, the court would not permit plaintiffs to leave the inference with the jury that provisions of the Workforce Reduction Guidelines that had been redacted on the basis of privilege did not exist in the first instance.
For the foregoing reasons, the court concludes that defendant has not waived the privilege with respect to adverse impact analyses by referencing “disparate impact” review or “legal review” in its Workforce Reduction Guidelines.
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C. Due Diligence Conducted by Human Resources In its supplemental briefing, defendant also asserts that it will support its “good faith”
defense with evidence concerning “the assistance of the Human Resources Department and its due diligence in reviewing [selection] decisions prior to obtaining any legal advice.” In response, plaintiffs urge that any due diligence conducted by Human Resources is inseparable from the due diligence conducted by or on behalf of defendant’s legal department such that defendant’s intent to rely on “due diligence” in any respect clearly waives the privilege with respect to the adverse impact documents. Defendant, on the other hand, contends that the due diligence review conducted by Human Resources is distinct from the review conducted by defendant’s legal department such that its reliance on the due diligence conducted by Human Resources leaves intact the privilege concerning adverse impact documents. As explained below, the court concludes that defendant’s intention to introduce evidence of human resources’ due diligence review of selection decisions does not implicate the adverse impact analyses or any other privileged communication and that defendant has not waived the privilege by its reliance on the due diligence review conducted by human resources.
To begin, the record reflects a great deal of confusion on the part of both plaintiffs and defendant concerning the extent to which due diligence performed by Human Resources is separate from the review conducted by the legal department. While each party vigorously blames the other for this confusion, it appears to the court that both parties have contributed to it. Defendant, in much of its briefing throughout this case and through the testimony at the March 2006 evidentiary hearing before Magistrate Judge Waxse, maintained that the due
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diligence conducted by Human Resources, at least through the time when the adverse impact documents were created by Human Resources, was a separate process from that conducted by the legal department. Plaintiffs, too, have evidenced a belief that these processes were separate and distinct. However, as reflected in much of the deposition testimony presented to the court by plaintiffs in connection with this motion and their motion to review the magistrate judge’s order of October 5, 2006 granting defendant’s motion for protective order prohibiting discovery relating to adverse impact analyses, defendant has objected on the basis of attorney-client privilege to questions posed by plaintiffs’ counsel that appear designed to solicit information concerning this separate due diligence conducted by Human Resources. In large part, then, the issue has been confounded through the course of depositions in this case.12
In an effort to ascertain for itself whether the due diligence conducted by Human Resources is separate from any review conducted by or on behalf of the legal department, the court examines the evidence in the record before it. In that regard, the record reveals that the vast majority of defendant’s witnesses have testified (that is, when they have been permitted by defendant’s counsel to testify on the subject) that human resources conducted an initial “due
12Defendant contends that to the extent defendant’s counsel improperly shielded deposition questions with a privilege objection, the fault lies with the “poor questioning” advanced by plaintiffs’ counsel. While some of the questions asked by plaintiffs’ counsel may have merged the concepts of “adverse impact” and “due diligence,” certainly both parties (and witnesses) have used those phrases interchangeably at times. Moreover, defendant’s counsel did not assist the deposition process by asserting a blanket privilege objection rather than clarifying for plaintiffs’ counsel the distinction defendant was drawing between “adverse impact” and “due diligence” or attempting to sort out with plaintiffs’ counsel the specific information sought from the deponent.
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diligence” review (also referred to as a “sore thumb” review by certain witnesses) of selection decisions prior to obtaining legal advice. Similarly, virtually all of defendant’s witnesses testified that the adverse impact documents were not utilized by human resources in any fashion and that those documents were generated by Human Resources for the sole purpose of transmitting the documents to the legal department.
The most thorough explanation of the due diligence conducted by Human Resources is found in the testimony given by Deb Sprayberry at the March 2006 evidentiary hearing before Magistrate Judge Waxse. During the time period relevant to this lawsuit, Ms. Sprayberry was employed as defendant’s Manager of Regional HR Operations responsible for supporting HR managers in the field (managers who, in turn, supported the sales organization and retail stores). As part of her job, Ms. Sprayberry was responsible for guiding field HR managers though the reduction in force process. As explained by Ms. Sprayberry, human resources would conduct a “preliminary HR review” prior to any contact with the legal department and prior to the generation of any adverse impact documents. This review constituted a “quick” review of the selection decisions by reviewing the candidate selection worksheets (also referred to as “realignment selection worksheets”)–worksheets containing the names of the individuals selected for termination and reflecting how those individuals were evaluated against specific selection criteria. These worksheets were not part of the adverse impact documents and, in fact, the initial HR review, as explained by Ms. Sprayberry, occurred before the adverse impact documents were created. According to Ms. Sprayberry, human resources, in conducting their initial review, did not review any summary data and only examined the “raw data” to see if
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“there was something that was very obvious that we needed to address.” Ms. Sprayberry testified that each HR manager would have received candidate selection worksheets from the field and that any initial HR review would have been based on these worksheets. In summary, Ms. Sprayberry testified that the initial HR review was completely separate from the adverse impact process involving the legal department.
Ms. Sprayberry’s testimony is consistent with the testimony of other Human Resources employees. For example, Michael Brill, a manager in defendant’s human resources department, testified that the organizations that he supported would provide to him candidate selection worksheets and he would use those worksheets to “perform initial due diligence before we would partner with legal on final adverse impact.” According to Mr. Brill, human resources would review the candidate selection worksheets to “determine were there any decisions that look like they were inappropriate decisions.” James Kissinger, previously a Vice President for Human Resources, testified that Human Resources frequently conducted a “sore thumb” review of selection decisions prior to obtaining legal advice. According to Mr. Kissinger, this review “stopped short of the official adverse impact analysis that’s required and required and directed by the law department” and typically consisted of an “overall observation of the number of minority employees subject to reduction.” Mr. Kissinger testified that this review simply looked for “obvious issues” and that it did not involve statistical adverse impact analysis in the sense that was required by the legal department.
In addition, the testimony of numerous witnesses confirms that Human Resources did not utilize the adverse impact analyses in conducting their own due diligence review (or in any
18

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respect, for that matter). At the March 2006 evidentiary hearing before Magistrate Judge Waxse, each witness who testified on behalf of defendant (i.e., Scott Winkler; James Kissinger; Deb Sprayberry; Gina Eisler; and Eric Rice) testified that Human Resources’ only involvement with the adverse impact analyses was to input the pertinent data in the computer (the computer then generated the adverse impact calculations and the matrix) and then forward the resulting document to the legal department. Without exception, these witnesses testified that Human Resources did not utilize the adverse impact documents for any reason independent of the legal review conducted by the legal department.
While plaintiffs acknowledge the testimony of these witnesses, they assert that two other Human Resources employees–Marvin Motley and John Shannon–have testified that the due diligence conducted by Human Resources involved reviewing the same adverse impact documents that were ultimately sent to legal, thus rendering the two processes inextricably intertwined. While Mr. Motley’s deposition testimony is not a model of clarity (due in part to plaintiffs’ counsel’s use interchangeably of the phrases “adverse impact review” and “due diligence review”), the court does not view that testimony as inconsistent with the testimony of other human resources employees. Mr. Motley testified that in terms of any “adverse impact analysis,” the role of human resources was simply to collect the pertinent data and pass that information on to the legal department for a determination of whether any adverse impact existed. Mr. Motley further testified that human resources, prior to any involvement with the legal department, would have conducted a “front end” or “sore thumb” analysis. According to Mr. Motley, this review consisted of looking “at the information about what the total population
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looked like and who was being separated to try to at least get a feel for whether we thought there
was a problem or not.” Consistent with Ms. Sprayberry’s testimony, then, this testimony
indicates that human resources did not review any summary information or percentages and only
looked at the raw data for obvious problems or glaring inconsistencies. After plaintiffs’ counsel
inquires about the specifics of “how” human resources would perform its “front end” analysis,
the following exchange takes place:
Mr. Motley: I think that they would have looked to see what the relative age of the people that are being separated compared to the population that they came from. And the example that I would give you is if we saw a situation where the population was generally fairly–the majority of the population was over 40, you would expect the majority of the separated employees to be over 40.
Counsel: So did you gather statistics to try to determine whether or not the majority of [the] population was over 40?
Mr. Motley: I think they would have done basically, as I said before, sort of sore thumb and they would have passed off their data to do the specific analysis to the law department.
Counsel: Sure. Were there any documents generated with regard for the front end analysis by the HR?
Mr. Motley: Maybe not.
Counsel: Maybe so?
Mr. Motley: More likely not. I mean, they would have used, we would have used the same forms that we passed on to the legal folks. But I mean, we collect the data, we’re going to look at it.
It is apparently Mr. Motley’s testimony concerning human resources’ use of the “same forms”
that were sent to legal from which plaintiffs infer that human resources employees used the
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adverse impact analyses in conducting their own due diligence or sore thumb review. The court, however, declines to draw such a sweeping inference from this isolated portion
of Mr. Motley’s testimony, particularly as Mr. Motley does not ever state that human resources used the adverse impact documents in connection with its own due diligence. Indeed, it is more probable that this portion of Mr. Motley’s deposition references either the Master and RIF lists (spreadsheets generated by human resources indicating respectively the universe of employees in a particular pool and the individuals selected for termination from that particular pool) or the candidate selection worksheets about which other human resources employees testified. This reading of this portion of Mr. Motley’s testimony is more consistent with the entirety of Mr. Motley’s testimony concerning the due diligence review. In that regard, Mr. Motley consistently testified that, in his recollection, the human resources review consisted of looking “at the age of the people who were being separated” and “the pool of the people that they came from” to determine whether “an anomaly” existed. The Master and RIF lists–documents that were ultimately sent to legal but are not protected by the privilege–contain the very data that human resources collected and from which human resources could have performed its “front end” analysis as described by Mr. Motley. Similarly, to the extent that candidate selection worksheets were transmitted to the legal department, those documents would have been collected by human resources and examined by human resources in its initial due diligence review. For the foregoing reasons, then, the court cannot conclude that Mr. Motley’s deposition testimony supports plaintiffs’ assertion that human resources utilized the adverse impact documents in performing its own due diligence of selection decisions.
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With respect to Human Resources employee John Shannon, plaintiffs are correct that Mr. Shannon testified that he utilized the adverse impact analyses in performing his own due diligence review of selection decisions. Mr. Shannon concedes, however, that he was “running [his] own adverse impacts outside of the policy” and that his conduct in utilizing adverse impact analyses in performing due diligence was “outside the sanction of our legal department.”13 Thus, while the record reflects that Mr. Shannon was utilizing adverse impact analyses, the record also reflects that Mr. Shannon knew he was not authorized to do so and that his conduct was contrary to corporate policy. In fact, Mr. Shannon’s testimony otherwise supports the conclusion that HR due diligence consisted primarily of reviewing the candidate selection worksheets for obvious issues. In that regard, Mr. Shannon testified that human resources would receive candidate selection worksheets from managers in the field and the human resources employees would “dig into” the worksheets to ascertain whether the selection decisions appeared to be supported by reason and logic and to seek clarification or additional information concerning selections decisions in advance of any input from the legal department. Mr. Shannon’s testimony, then, does not persuade the court that the “HR due diligence review” on which defendant intends to rely at trial involved a review of adverse impact documents that were sent to legal.
13The record reflects that defendant has produced documents relevant to Mr. Shannon’s “own” adverse impact analyses and that defendant has permitted Mr. Shannon to testify on the subject. In other words, defendant is not asserting the attorney-client privilege with respect to adverse impact analyses conducted by Mr. Shannon that were not done at the direction of the legal department.
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Finally, plaintiffs contend that defendant’s refusal to permit their witnesses to answer deposition questions (through the assertion of a privilege objection) concerning HR’s due diligence review demonstrates that the HR due diligence review is inextricably intertwined with the review conducted by the legal department. The court, however, is unwilling to draw this conclusion based solely on the deposition excerpts provided by plaintiff. In many of the exchanges highlighted by plaintiffs’ counsel in which privilege objections were lodged, plaintiffs’ counsel had asked compound questions concerning both “adverse impact” and “due diligence” or had otherwise intermingled the two concepts. In other words, there are very few pointed questions aimed solely at the separate due diligence conducted by human resources. To make matters worse, defendant’s counsel, on several occasions, was perhaps overreaching in its assertion of the privilege objection and failed to clarify that it did not object to questions aimed at the separate due diligence conducted by human resources. Both parties, then, have contributed to a muddled deposition record on this issue and the court cannot conclude from those excerpts before it that defendant intended to use the privilege to shield questions seeking only information concerning the due diligence conducted by human resources. To be clear, however, the court’s ruling that defendant’s reliance on the “separate” due diligence conducted by human resources has not waived the privilege is premised on defendant’s representation that it will not lodge privilege objections to questions concerning that due diligence. If Magistrate Judge Waxse, in resolving plaintiffs’ motion to compel responses to deposition questions, determines that any depositions need to be reopened to explore further the issue of HR’s due diligence and defendant does not abandon its objections to questions concerning human resources’ due diligence, then
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the court will need to revisit the waiver issue entirely, as defendant’s good faith defense is admittedly based in large part on the due diligence conducted by human resources.14
The court concludes, then, that defendant’s intention to introduce evidence of human resources’ due diligence review of selection decisions does not implicate the adverse impact analyses or any other privileged communication as the facts in the record concerning the due diligence review conducted by human resources demonstrate that the review did not utilize adverse impact analyses. In other words, the adverse impact analyses are not germane to the due diligence review conducted by human resources upon which defendant intends to rely. As such, defendant, through its reliance on human resources’ due diligence review, has not put the adverse impact analyses or any other privileged communication at issue. Moreover, there is no manifest unfairness to plaintiffs in protecting the adverse impact analyses against disclosure as the adverse impact analyses were not part of human resources’ due diligence review. In other words, plaintiffs are able to address fully defendant’s evidence concerning human resources’ due diligence review–a review that did not include utilization of the adverse impact analyses–without access to the adverse impact analyses.
For the foregoing reasons, the attorney-client privilege has not been waived by
14The court’s ruling today is also premised on the fact that, as the record demonstrates today, John Shannon is the lone exception to the rule that human resources employees did not utilize adverse impact analyses in performing their own due diligence. If Magistrate Judge Waxse determines that depositions need to be reopened to explore the due diligence process further and plaintiffs discover that numerous other human resources employees were utilizing adverse impact analyses outside the sanction of the legal department, plaintiffs are not precluded from seeking appropriate relief from the court.
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defendant’s reliance on the due diligence review conducted by human resources. See Frontier Refining Inc. v. Gorman-Rupp Co., 136 F.3d 695 (10th Cir. 1998) (under middle-of-the-road approach to waiver, privilege is waived only when the material to be discovered is both relevant to the issues raised in the case and either vital or necessary to the opposing party’s defense of the case); Hearn v. Rhay, 68 F.R.D. 574, 581 (E.D. Wash. 1975) (privilege is waived when “the party asserting the privilege place[s] information protected by it in issue through some affirmative act for his own benefit, and to allow the privilege to protect against disclosure of such information would [be] manifestly unfair to the opposing party”).
D. Deposition Testimony of Defendant’s Witnesses Plaintiffs also contend that defendant’s witnesses, contrary to defendant’s counsel’s
insistence that defendant will not rely on an “advice of counsel” defense, have repeatedly testified that they relied upon defendant’s legal department to advise them if any particular RIF selection decisions violated or appeared to violate anti-discrimination laws. According to plaintiffs, an inference of nondiscrimination in favor of defendant then arises from the absence of testimony (due to defendant’s invocation of the privilege) that the legal department ever indicated that any selection decisions raised red flags in terms of the pertinent discrimination laws. Plaintiffs contend that this result is clearly impermissible under Hearn and its progeny, including In re Broadcom Corp. Securities Litigation, 2005 WL 1403516 (C.D. Cal. Feb. 10, 2005) and Cox v. Administrator U.S. Steel & Carnegie, 17 F.3d 1386 (11th Cir. 1994).
Both In re Broadcom Corp. and Cox are distinguishable from the facts presented by 25

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plaintiffs here. In the first case, the individual defendants represented that they would affirmatively testify that each SEC filing and disclosure document was reviewed by counsel and that they expected counsel to advise them “if anything illegal was happening.” In re Broadcom Corp., 2005 WL 1403516, at *2. Similarly, in Cox, the defendant desired to affirmatively present evidence that it believed its conduct was legal. 17 F.3d at 1419. By contrast, the deposition testimony relied upon by plaintiffs in this case shows, without exception, that the testimony concerning reliance on counsel was elicited by plaintiffs’ counsel in response to pointed questions from plaintiffs’ counsel concerning adverse impact analyses–a subject that defendant has consistently urged is “off limits.” For example, one of defendant’s executives, Michael Fuller, was asked by plaintiffs’ counsel whether “any adverse impact analysis” was conducted with respect to a particular RIF and, in response, Mr. Fuller stated that he did not know, but that he “would expect the organization to inform [him] if any issues or problems were detected.” Another executive, Robert Dellinger, was asked by plaintiffs’ counsel whether he was made aware of the results of adverse impact analyses; Mr. Dellinger replied that he believed he would be made aware if there was a specific issue in his organization.15
15Plaintiffs further contend that the testimony of defendant’s witnesses reveals that the only information upon which those witnesses could have based their good faith belief that defendant was not violating the ADEA was the absence of any indication from defendant’s legal department that problems existed with any selection decisions. The court cannot accept this argument in light of the fact that the only testimony before the court stems from direct questions relating solely to adverse impact analyses or direct questions concerning whether the witness expected someone to advise him or her if problems existed with selection decisions. The excerpts before the court do not reflect any questions concerning the factual basis for a witness’ good faith belief that defendant’s selection decisions complied with the ADEA.
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The court finds no waiver in such circumstances.16 In so concluding, the court is guided in large part by the Fifth Circuit’s decision in Ward v. Succession of Freeman, 854 F.2d 788 (5th Cir. 1988). While the procedural posture of Ward is somewhat unique, the court nonetheless finds the opinion persuasive in the factual context presented here. In Ward, a case brought by shareholders against a corporation alleging violations of securities laws, the district court had compelled defendants to disclose certain documents containing attorney-client communications based on a previous decision from the Fifth Circuit holding that shareholders, in litigation involving a corporation and its shareholders, may have access to otherwise privileged information after a showing of good cause. Ward, 854 F.2d at 784. The plaintiffs then used those documents in an attempt to establish the scienter element of their securities claims. See id. at 786. In an attempt to rebut these allegations, the defendants then sought to demonstrate their good faith reliance on the advice of counsel. See id. at 788. At that point, the district court, which had previously indicated that defendants had preserved their right to appeal the court’s initial decision requiring disclosure of privileged communications, held that defendants had waived the privilege entirely by voluntarily injecting the advice-of-counsel issue into the case. See id. at 787.
On appeal, the Fifth Circuit reversed the district court’s initial decision to compel disclosure of the attorney-client communications and also reversed the district court’s decision
16Certainly, if defendant affirmatively and voluntarily injects the reliance on counsel issue at trial or in subsequent briefing to the court, the court will revisit the issue of whether defendant has waived the privilege.
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that defendants thereafter waived the privilege by raising the advice-of-counsel issue. According to the Fifth Circuit, the district court’s finding of waiver did “not square with traditional notions of when a party acts voluntarily in introducing privileged matter so as to waive the privilege.” Id. Specifically, the Fifth Circuit emphasized that the defendants “never mentioned” the adviceof-counsel defense until after the district court compelled disclosure of privileged communications and only raised it at trial after the plaintiffs in the first instance introduced privileged communications concerning the advice of counsel. Id. at 788. In such circumstances, the Circuit held that the defendants did not “voluntarily” inject the advice-of-counsel issue into the case but were merely rebutting an issue injected into the trial by plaintiffs:
[Defendants were] not the first party to inject reliance on advice of counsel into the trial. The plaintiffs first argued that the advice given by [defendants’] attorneys to the defendants regarding disclosure decisions went straight to the crucial issue of whether the allegedly fraudulent decisions were made with scienter. [Defendants] had no choice but to negate the proof by showing it acted in good faith and without any knowledge of an evil plot to defraud shareholders. . . . [W]e do not see how [defendants] can be said to have waived its privilege when it was plaintiffs who exploited the attorney-client communications in order to attempt to prove their claims. Id. at 789. Similarly, the record before the court indicates that defendant’s witnesses did not “voluntarily” raise the advice-of-counsel issue; they raised it only in response to direct questions from plaintiffs’ counsel concerning privileged communications, including the adverse impact analyses and whether anyone had advised the witness about the results of such analyses. Unlike In re Broadcom Corp. and Cox, then, the testimony of these witnesses does not indicate that defendant intends to use advice of counsel to justify any conduct on its part. See Motley v.
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Marathon Oil Co., 71 F.3d 1547, 1552 (10th Cir. 1995) (no waiver of privilege where employer did not attempt to justify its decisions based on advice of counsel). In other words, there is nothing in the record suggesting to the court that these witnesses (or any other witnesses on behalf of defendant) intend to, at their own initiative, testify at trial that they relied on counsel to advise them of any potential problems concerning RIF selection decisions. Rather, the record reflects that, like the factual scenario in Ward, defendant’s witnesses would feel compelled to testify about their reliance on counsel’s advice only if plaintiffs, on cross-examination, were permitted to ask those witnesses about their knowledge of adverse impact analyses–a subject that has otherwise been deemed privileged. As the court will not permit plaintiffs to inquire about privileged communications, defendant’s witnesses will not testify about their reliance on counsel.
For the foregoing reasons, the court concludes that defendant has not waived the privilege by virtue of the deposition testimony of its witnesses.
IT IS THEREFORE ORDERED BY THE COURT THAT that portion of plaintiffs’ motions for review (docs. 3605 and 4338) that the court previously retained under advisement are now denied.
IT IS SO ORDERED. Dated this __8th____ day of December, 2006, at Kansas City, Kansas.
__s/ John W. Lungstrum_______ John W. Lungstrum United States District Judge 29

 
 Case 2:03-cv-02200-JWL-DJW Document 4467 Filed 12/13/2006 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO.,

Defendant.

MEMORANDUM AND ORDER

This matter is before the Court on Defendant’s Motion to Reconsider its February 1, 2006

Order, in the Alternative to Clarify, and Motion to Stay February 1, 2006 Order requiring production

of documents (doc. 3591). For the reasons stated below, Defendant’s Motion to Reconsider will be

denied, Defendant’s Motion to Clarify will be granted in part and denied in part, and Defendant’s

Motion to Stay will be granted.

Relevant Factual Background

At the September 1, 2005 status conference, Plaintiffs submitted for the Court’s review a

document entitled “List of Documents Withheld by Defendant Despite No Involvement of Legal

Department or Counsel” (the “List”)1. The List identifies 426 documents “listed on Defendant’s

privilege log as having been withheld from production despite the fact that the log itself shows there

to have been no involvement of Sprint legal department or counsel so as to support any claim of

privilege or work product.”2 In conjunction with this List, Plaintiffs “request that Defendant’s

assertion of any privilege be overruled with regard to these documents.”3

1The List is attached as Exhibit 1 to the September 6, 2005 Court Order (doc. 3203). 2Id. 3Id.

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During the September 1, 2005 conference, the Court ultimately construed the “List” as a

Motion to Compel (doc. 3203) and ordered Defendant to submit a pleading by September 15, 2005

explaining “the basis upon which it is claiming attorney-client privilege for those documents

identified in any privilege log where no attorney is listed.” In a subsequent request for more time

to submit this pleading, Defendant stated that “[u]pon further review of the 426 documents identified

by Plaintiff[s], Sprint believes additional time is necessary to further research issues, both factual

and legal, before filing a formal response.”4

Approximately one month after having been ordered to submit this pleading, Defendant

ultimately filed a twenty-two page brief5 and twenty-one exhibits in support of its contention that

the privilege log documents identified by Plaintiff were subject to the attorney-client privilege

and/or the attorney work-product doctrine. Plaintiffs filed a responsive brief.6 Defendant then

sought leave of Court to file a Surreply, which the Court granted. After requesting and receiving

a subsequent extension of time, Defendant filed its Surreply on December 22, 2005.

On February 1, 2006, the Court issued a Memorandum and Order (doc. 3549) finding that

C

Defendant successfully met its burden to establish attorney-client privilege

protection for a portion of the 426 documents included on the List; but

C

Defendant failed to establish the elements required to invoke the attorney-

client privilege for the balance of the 426 documents included on the List.

Given these findings, the Court ordered Defendant to produce those documents for which

Defendant failed to establish privilege.

4Doc. 3263 at p.1, ¶¶1-2. 5Doc. 3335. 6Doc. 3453.
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In the motion currently pending, Defendant requests the Court reconsider its order to produce those particular documents for which Defendant failed to establish privilege. Defendant argues it misunderstood the issue to be briefed and thus did not have an opportunity to be heard on the issue actually decided by the Court. More specifically, Defendant states it understood the only issue to be briefed was the generic issue of whether the attorney-client privilege can apply to documents that do not, on their face, appear to involve counsel. Defendant states it did not understand that it was required to provide, in its briefs and privilege log, sufficient information to enable the Court to determine whether all the required elements of the privilege had been met regarding those documents. To that end, Defendant requests the Court reconsider whether the elements of the attorney-client have been met in light of a subsequently revised privilege log that it contends more accurately describes the documents at issue.
Should the Court decide not to reconsider its order of production, Defendant alternatively requests the Court clarify its order with regard to various documents and impose a stay of the February 1, 2006 Memorandum and Order with regard to production of documents in order to permit Defendant to file a motion for review with the district court judge.
Discussion A. Motion to Reconsider based on Defendant’s Misunderstanding
Pursuant to D. Kan. Rule 7.3, motions seeking reconsideration of non-dispositive orders must be based on “(1) an intervening change in controlling law, (2) the availability of new evidence, or (3) the need to correct clear error or prevent manifest injustice.”7 Reconsideration may be appropriate “where the court has misapprehended the facts, a party’s position, or the controlling
7The Tenth Circuit has adopted the same standard. See, e.g., Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000).
3

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law.”8 With that said, a motion to reconsider is not a second chance for the losing party to ask the Court to revisit issues already addressed or to consider new arguments and facts that could have been presented originally.9 Nor is a motion to reconsider to be used as “a second chance when a party has failed to present it strongest case in the first instance.”10 Whether to grant or deny a motion for reconsideration is soundly committed to the court’s discretion.11
Here, Defendant argues it misunderstood the issue to be briefed and thus reconsideration is necessary to correct clear error or prevent manifest injustice. Simply put, the Court is not persuaded by Defendant’s argument.
The Court held, in its February 1, 2006 Memorandum and Order, that Defendant failed to carry its burden of persuasion establishing that certain documents it claimed were protected by attorney-client privilege were actually protected by the privilege. Notably, this is not an issue of waiver. Waiver involves an intentional relinquishment of a right. Waiver was not an issue in the February 1, 2006 Memorandum and Order. The Court granted the motion to compel for the documents at issue because Defendant failed to carry its burden of proof on the objections raised by Plaintiffs to the documents described in Defendant’s privilege log. In other words, Defendant failed – when it initially provided the privilege log, when it provided supplemental privilege logs and when it submitted its 22-page brief and subsequent Surreply – to provide adequate facts to establish
8Sonnino v. Univ. of Kan. Hosp. Auth., 221 F.R.D. 661, 664 (D. Kan. 2004); Servants, 204 F.3d at 1012.
9Servants, 204 F.3d at 1012 10Van Skiver v. United States, 952 F.2d 1241, 1243 (10th Cir.), cert. denied, 113 S.Ct. 89 (1992). Sonnino, 221 F.R.D. 661, 664 (D. Kan. 2004). 11Hancock v. City of Oklahoma City, 857 F.2d 1394, 1395 (10th Cir. 1988).
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that the documents at issue were protected from disclosure by the attorney-client privilege. The Court has great difficulty in accepting Defendant’s argument of “misunderstanding”
with regard to the issue that was to be briefed. Defendant filed its Response brief on October 3, 2005, including within its title that the document was its “Memorandum in Opposition to Plaintiffs’ Motion To Compel Documents.”12 Defendant’s brief states that “Plaintiff further requested ‘that Defendant’s assertion of any privilege be overruled with regard to these documents.’”13 Defendant’s brief categorizes the documents and otherwise appears to show Defendant fully understood that the issue was whether the privilege assertion was valid as opposed to the supposed narrow reading Defendant now asserts in its Motion to Reconsider.14 Indeed, Defendant’s Response brief notes in footnote 9 that it was “willing to provide information . . . beyond that provided in the Log, regarding the senders and recipients of the subject communications” but that “[f]or the sake of brevity, however, Sprint asserts that the senders and recipients are members of Sprint’s management who used the underlying advice in discharging their duties as managers at Sprint.”15 Thus, it appears that Defendant fully understood the issue at hand was Plaintiffs’ motion to compel documents but chose not to provide any evidence in support of its claims of privilege.
Defendant’s Surreply brief was then filed on December 22,, 2005. Defendant’s Surreply acknowledged the overarching nature of the issues briefed when it claimed “Sprint has met its
12Doc. 3335. 13Id. at p.2. 14Id. at pp. 7-9 (setting forth and attempting to address all elements of the attorney-client privilege and work product doctrine). 15Id. at p. 9.
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burden of establishing that the challenged documents are privileged.”16 Defendant also admitted in its Surreply that “After Plaintiff challenged the 426 documents on the Log in September, Sprint conducted a good faith re-evaluation of its claim of privilege on each of the 426 documents. As a result of that process, and as noted by Plaintiff in her Reply, Sprint has now produced several of the 426 challenged documents.”17
Thus, in its extensive Response brief and subsequent Surreply brief, Defendant was repeatedly given the opportunity to meet its burden and support its assertions of privilege with regard to these documents. Defendant failed in this endeavor. Notwithstanding this fact, Defendant now argues in its request for reconsideration that if the Court will only consider Defendant’s supplemental privilege log, the information contained therein will sufficiently establish the privilege. The Court, however, finds production of the supplemental privilege log is too late with regard to the documents at issue. The Court has already ordered production of the documents. It was Defendant’s burden to prove its privileges prior to the time that the Court was asked to determine them.
Production of a “new and improved” privilege log is untimely if done after the Court was requested to determine the issue and after entry of the Court’s order directing production of the documents. A party seeking to assert the privilege must make a clear showing that it applies.18 Failure to do so is not excused because the document is later shown to be one which would have been privileged if a timely showing had been made.19 Even though the privilege may have attached
16Doc. 3522 at p. 2. 17Doc. 3522 at p. 4. 18Peat, Marwick, Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984).
19Id. 6

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if sufficient information had been timely and adequately asserted, that such a showing had not been

made when the trial court was called upon to make its ruling defeats the privilege.20 “[A]pplicability

of the privilege turns on the adequacy and timeliness of the showing as well as on the nature of the

document.”21

Having considered all of Defendant’s arguments, the Court is compelled to overrule the

Motion for Reconsideration. Thus, Defendant will be required to produce the requested documents.

B. Defendant’s Request for Clarification

In the alternative to reconsideration, Defendant requests clarification of the February 1, 2006

Memorandum and Order.

C

Documents 54630, 54874, 57215, 57429-57471, 57330

In its February 1, 2006 Order, the Court concluded that “Category Four” (adverse impact)

documents containing one of several specified descriptive “adverse impact analyses” phrases were

protected from disclosure by Judge Lungstrum’s previous ruling regarding the privileged nature of

such analyses.22 While “EEO analysis,” “EEO alpha analysis,” and “AI” were not specific

descriptive phrases listed in the February 1, 2006 Order, Defendant contends documents 54630,

54874, 57215, 57429-57471, 57330 and 163528 also contain adverse impact analyses as indicated

by their descriptions in the privilege log. To that end, Defendant argues the phrases “EEO

analysis,” “EEO alpha analysis,” and “AI” are substantively equivalent to the identified phrases:

“impact ratio analysis”; “adverse impact analysis”; “adverse impact”; “impact ratio analysis”; “due

20Id. 21Id. 22February 1, 2006 Memorandum and Order (doc. 3549) at p. 16.
7

Case 2:03-cv-02200-JWL-DJW Document 4467 Filed 12/13/2006 Page 8 of 12

diligence matrix”; “adverse impact information”; and “legal advice re IT directors.”

Based on the undersigned Magistrate Judge’s extensive exposure to the numerous adverse

impact issues presented by the parties during the course of this litigation, the Court is persuaded by

Defendant’s argument here and thus clarifies its February 1, 2006 Memorandum and Order to find

that documents 54630, 54874, 57215, 57429-57471, 57330 and 163528 are protected from

disclosure by Judge Lungstrum’s previous ruling regarding the privileged nature of such analyses

and thus need not be produced.

C

Document 54922

The log entry regarding this Category 2 document states: “E-Mail re LINK rating adverse

impact analysis.” The Court finds that, although set forth in Category 2 as opposed to Category 4,

document 54922 is adequately described as legal advice communicated between non-lawyer

members of Defendant’s management team. This description is consistent with a finding that the

documents were confidential and communicated to non-lawyers to further the rendition of legal

services to the client, which the Court found in its February 1, 2006 Memorandum and Order to be

a communication protected by the attorney-client privilege. Thus, the Court clarifies its February

1, 2006 Order to find that document 54922 need not be produced.

C

Documents 179512 and 46294-46298

With regard to documents bearing bates stamps 179512 and 46294-46298, the Court finds

the thorough discussion and subsequent holding in its February 1, 2006 Memorandum and Order

needs no clarification. Thus, the handwritten portion of the documents bearing bates stamps

46294-46298 are protected from disclosure by the attorney-client privilege and need not be produced

but the underlying documents 46294-46298, as redacted, and document 179512 must be produced.

8

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C

Documents For Which Defendant May Have Provided Adequate Information

Prior to the Court’s Order

In conjunction with this Court’s September 1, 2005 Order construing Plaintiffs’ challenge

to documents described in Defendant’s privilege log as a Motion to Compel, Defendant submitted

the August 12, 2005 privilege log upon which Plaintiffs based their challenge. The 133-page

privilege log was submitted in paper format. During the briefing of the Motion to Compel, both

parties exclusively relied on the descriptions and information within the August 12, 2005 log.

After the Motion was fully briefed, the Court requested Defendant submit the August 12,

2005 privilege log to the Court in electronic format.23 On January 25, 2006, Defendant complied

with the Court’s request by sending an email directly to chambers that attached the August 12, 2005

privilege log in .pdf format. In addition to the August 12, 2005 electronic version of the paper

privilege log, however, Defendant also submitted an electronic version of a second privilege log,

this one entitled “KC Privilege Log.”

In its request for clarification, Defendant seeks to have the Court reconsider its February 1,

2006 decision with regard to nine documents for which Defendant submitted revised descriptions

and information in the “KC Privilege Log.” In support of this request, Defendant states that the

revised log was submitted on January 25, 2006, which was prior to entry of the February 1, 2006

Memorandum and Order. Thus, Defendant argues, the revised descriptions and information should

have been taken into consideration by the Court in its February 1, 2006 ruling.

23See Transcript from January 19, 2006 Discovery/Status Conference at p. 86 (doc. 3546). 9

Case 2:03-cv-02200-JWL-DJW Document 4467 Filed 12/13/2006 Page 10 of 12

The Court disagrees. From the very outset, Plaintiffs’ Motion to Compel was based on the

information and descriptions set forth in the August 12, 2005 Privilege Log. During the briefing of

the Motion to Compel, both parties exclusively relied on the descriptions and information within the

August 12, 2005 log. Moreover, Defendant provided no explanation in the January 25, 2006 email

and did not submit any supplemental pleading incorporating descriptions or information from the

“KC Privilege Log” with regard to the pending Motion to Compel. If Defendant had wanted the

Court to take the revised information into consideration in ruling on the Motion to Compel,

Defendant had the burden of notifying the Court of this desire. Accordingly, the Court finds no

clarification to its February 1, 2006 Order is necessary for documents 154188-197, 154259-268,

154084-095, 153995-154001, 154084-95, 130597-130600, 130624-130626, 57214 and 153918.

C

Documents That Appeared Multiple Times on the List and were Found

Elsewhere to be Protected from Production

Defendant also requests clarification regarding three (3) documents that, due to multiple

listings with different descriptions, have been found both protected by the privilege and unprotected

by the privilege at the same time. Defendant contends that the reason for the multiple listings stems

from the vast number of documents collected by Sprint, which resulted in the same document being

collected multiple times, which in turn, meant that the same document was occasionally included

on the log more than once.

Based on the unique circumstances presented, the Court hereby clarifies its Order regarding

these three documents such that Defendant need not produce them. The Court makes this decision

on grounds that the referenced three documents, in a different listing on the log, were found by the

Court to be otherwise protected by the attorney-client privilege.

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C. Defendant’s Request for Stay Pending Motion for Review Upon consideration of the circumstances presented, the Court hereby grants Defendant’s
request that the February 1, 2006 Memorandum and Order be stayed to the extent that Defendant need not produce any documents pending review of objections to be filed with the District Judge.
Conclusion For the reasons stated above, Defendant’s Motion is granted in part and denied in part: (1) Defendant’s Motion for Reconsideration based on an updated privilege log is denied;

(2) Defendant’s Motion to Clarify the February 1, 2006 Memorandum and Order

(a) is granted to the extent that

C

Defendant shall not be required to produce documents 54630, 54874,

54922, 57215, 57429-57471, 57330 and 163528; and

C

Defendant shall not be required to produce the three documents

referenced by Defendant that were listed multiple times in the

privilege log and found by the Court in at least one instance to be

protected by the attorney-client privilege.

(b) is denied to the extent that no clarification is necessary with regard to documents 46294-46298, 179512, 154188-197, 154259-268, 154084-095, 153995-154001, 154084-95, 130597-130600, 130624-130626, 57214 and 153918.

(3) Defendant’s Motion to Stay the February 1, 2006 Memorandum and Order is granted to the extent that Defendant need not produce any documents pending review of objections to be filed with the District Judge.

IT IS SO ORDERED.

Dated in Kansas City, Kansas on this 13th day of December, 2006.

s/ David J. Waxse David J. Waxse United States Magistrate Judge
11

Case 2:03-cv-02200-JWL-DJW Document 4467 Filed 12/13/2006 Page 12 of 12 cc: All counsel and pro se parties
12

 
 Case 2:03-cv-02200-JWL-DJW Document 4521 Filed 01/05/2007 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant. MEMORANDUM & ORDER
Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated asserting that her age was a determining factor in defendant’s decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b).
This matter is presently before the court on plaintiffs’ motion to review (doc. 4427) and objections to the magistrate judge’s November 6, 2006 order in which the magistrate judge granted defendant’s motion for protective order requesting the return of one document on the grounds that the document is a privileged attorney-client communication and that defendant has not waived the privilege in any respect. In their motion, plaintiffs contend that both conclusions are erroneous and urge that the document is not a privileged attorney-client communication and that defendant waived what claim to privilege it had with respect to the document. As will be explained, the motion is granted in part and denied in part. The motion is denied with respect to the magistrate judge’s conclusion that the document is a privileged attorney-client

Case 2:03-cv-02200-JWL-DJW Document 4521 Filed 01/05/2007 Page 2 of 12
communication and is granted with respect to the magistrate judge’s conclusion that defendant has not waived the privilege. In other words, the court concludes that the document is privileged but that defendant waived the privilege with respect to the document. As will also be explained, the court remands to the magistrate judge the limited issue of whether plaintiffs are entitled to an unredacted copy of the document.
I. Background The following facts are undisputed by the parties. In May 2005, defendant produced
documents to plaintiffs and, in the course of that production, decided to withhold a document bearing Bates-stamp number 54873 and entitled “Criteria for HR Review of Preliminary Performance Management Systems Results” (hereinafter the “Criteria Document”). The Criteria Document is a one-page document providing step-by-step instructions to defendant’s Human Resources personnel concerning the review of certain preliminary results indicating that defendant’s “Alpha” performance review rating system had an adverse impact on one or more protected classes. On July 28, 2005, defendant provided a privilege log (the first log to identify the Criteria Document) identifying the Criteria Document as protected from disclosure by virtue of the work product doctrine; defendant did not assert in this log protection based on the attorney-client privilege. Subsequent logs similarly asserted that the Criteria Document was subject to protection based solely on the work product doctrine. On each log, the date and author of the Criteria Document was listed as “unknown.”
During a discovery/status conference held before the magistrate judge on September 1, 2

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2005, plaintiffs presented defendant and the magistrate judge with a list of the Bates numbers of 426 documents identified on defendant’s most recent privilege log for which plaintiffs believed that defendant had no legitimate claim of protection. The magistrate judge construed the list as a motion to compel and ordered defendant, by September 15, 2005, to explain to plaintiffs the basis upon which defendant was claiming protection for each of the 426 documents. Thereafter, defendant requested and received an extension of time up to and including October 3, 2005 to respond to plaintiffs’ motion to compel.
In preparing defendant’s response, one of defendant’s lawyers, Patrick Hulla, reviewed a hard copy of each of the 426 documents, one of which was the Criteria Document. Mr. Hulla is an experienced lawyer who, at that time, had been intimately involved with this litigation from its inception. According to Mr. Hulla, he could not ascertain from the face of the Criteria Document or the privilege log entry for the document whether the document in its entirety was protected from disclosure by the attorney-client privilege or the work product doctrine, based in large part on the fact that he did not know who authored the document (which, in turn, was due in part to the fact that defendant, up until this point, apparently did not realize that the Criteria Document was initially distributed to Human Resources’ employees with an attached cover memorandum from Jill Ferrel, one of defendant’s in-house counsel, indicating that she had authored the document and that the attached Criteria Document was an attorney-client privileged document). Thus, Mr. Hulla determined that only paragraphs 9 and 10 of the Criteria Document were protected from disclosure based on the work product doctrine. Accordingly, Mr. Hulla, in responding to plaintiffs’ motion to compel, stated that defendant would produce a redacted
3

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version of the Criteria Document. During the parties’ October 6, 2005 discovery/status conference with the magistrate
judge, defendant produced to plaintiffs the Criteria Document, with paragraphs 9 and 10 redacted, along with 25 other documents included in plaintiffs’ list of 426 documents that defendant had concluded were not protected from disclosure. The following day, plaintiffs sent via fax to defendant a detailed list of the documents defendant had produced at the October 6, 2005 status conference and specifically requested that defendant tender to the court an unredacted copy of the Criteria Document. Defendant declined to provide the document for in camera review and did not contend at that time that the Criteria Document had been inadvertently produced.
On October 21, 2005, during the deposition of Gene Lampe, one of defendant’s Human Resources employees, plaintiffs’ counsel inquired about the contents of the Criteria Document. At that point, another lawyer for defendant, Philip Dupont, contended that the document had been inadvertently produced. Thereafter, Mr. Dupont investigated the origin of the document, including analyzing the document’s metadata, and determined that it had been authored by Ms. Ferrel. Although the record is not entirely clear, it appears that defendant, at this time, connected the Criteria Document to Ms. Ferrel’s cover memorandum.1 On October 27, 2005, defendant’s
1In fact, Ms. Ferrel’s cover memorandum and the Criteria Document appear in sequential order on defendant’s privilege logs. That is, Ms. Ferrel’s cover memorandum bears Bates-stamp number 54872 and is identified immediately prior to the Criteria Document, which bears Bates-stamp number 54873. This indicates that the documents had been maintained together but, for whatever reason, defendant did not understand the link between the documents.
4

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counsel sent a letter to plaintiffs requesting the immediate return of the Criteria Document. Plaintiffs’ counsel refused to return the document, contending that the disclosure was not inadvertent. In November 2005, defendant filed a motion for protective order seeking the return of the document.
In his November 6, 2006 memorandum and order, the magistrate judge granted defendant’s motion for protective order, directed plaintiffs to return the Criteria Document and prohibited plaintiffs from using the document in any manner. Specifically, the magistrate judge concluded that the Criteria Document constitutes a privileged attorney-client communication and that defendant’s “inadvertent disclosure” of the Criteria Document was insufficient to constitute a waiver of the privilege.
II. Applicable Standard Magistrate judges may issue orders as to non-dispositive pretrial matters and district
courts review such orders under a “clearly erroneous or contrary to law” standard of review. First Union Mortgage Corp. v. Smith, 229 F.3d 992, 995 (10th Cir. 2000) (quoting Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1461-62 (10th Cir. 1988)); 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a). The clearly erroneous standard applies to factual findings, see 12 Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 3069, at 355 (2d ed. 1997) (and cases cited therein), and requires that the district court affirm unless it is left with the “definite and firm conviction that a mistake has been committed.” Ocelot Oil, 847 F.2d at 1464 (quoting United States v. United States Gypsum Co., 333 U.S. 364, 395
5

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(1948)). By contrast, the “contrary to law” standard permits “plenary review as to matters of law.” See Wright, Miller & Marcus, supra, § 3069, at 355; Haines v. Liggett Group Inc., 975 F.2d 81, 91 (3rd Cir. 1992); Computer Economics, Inc. v. Gartner Group, Inc., 50 F. Supp .2d 980, 983 (S.D. Cal. 1999) (“contrary to law” standard permits independent review of purely legal determinations by a magistrate judge); Weekoty v. United States, 30 F. Supp. 2d 1343, 1344 (D.N.M. 1998) (when reviewing legal determinations made by magistrate judge, standard of review is de novo).
III. Whether the Document Constitutes a Privileged Attorney-Client Communication In their motion to review, plaintiffs first contend that the magistrate judge erred in
concluding that the Criteria Document is a privileged attorney-client communication. According to plaintiffs, the Criteria Document is simply a “policy or procedure” of defendant that human resources follows in the ordinary course of its human resources’ functions. As plaintiffs candidly concede, however, their argument concerning whether the Criteria Document is privileged is made without the benefit of having seen Ms. Ferrel’s cover memorandum to which the Criteria Document was initially attached. The cover memorandum has never been produced by defendant and has been submitted to the court (as it was to the magistrate judge) for in camera review. As the magistrate judge correctly concluded, that cover memorandum, as well as other evidence such as metadata, establishes that the Criteria Document was authored by Ms. Ferrel, defendant’s in-house counsel. In addition, the cover memorandum advises that the Criteria Document is a privileged attorney-client communication. The contents of the cover
6

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memorandum reflect that the Criteria Document is not intended to be an official “policy or procedure” of defendant (as suggested by plaintiffs) but is intended to offer legal advice concerning the review process described in the Criteria Document. Without hesitation, the court concludes that the magistrate judge did not err when he held that the Criteria Document constitutes a privileged attorney-client communication. United States v. Johnston, 146 F.3d 785, 794 (10th Cir. 1998) (confidential communications between lawyer and client are privileged when those communications relate to legal advice or strategy); accord Motley v. Marathon Oil Co., 71 F.3d 1547, 1550-51 (10th Cir. 1995) (memorandum drafted by in-house counsel concerning proposed guidelines for implementation of RIF was privileged communication where memorandum was treated as confidential and contained legal advice for corporate restructuring).
IV. Whether Defendant Waived the Privilege Plaintiffs assert that the magistrate judge erred in concluding that defendant
“inadvertently” produced the document and that its inadvertent disclosure did not constitute a waiver of the privilege. Plaintiffs urge that the undisputed facts demonstrate that no “inadvertent” production occurred with respect to the Criteria Document; rather, defendant deliberately produced the document after redacting paragraphs 9 and 10 and concluding that the remainder of the document was not privileged or otherwise protected. According to plaintiffs, defendant’s deliberate production of the Criteria Document is sufficient to constitute a waiver of the privilege. In response, defendant argues that its disclosure of the document was inadvertent and that the magistrate judge correctly applied the appropriate test in determining
7

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that defendant’s inadvertent production did not constitute a waiver of the privilege. As an initial matter, the magistrate judge’s November 6, 2006 memorandum and order
appears to assume that defendant’s production of the document was inadvertent and proceeds to apply the five-factor test generally used to determine whether an inadvertent disclosure constitutes a waiver of the privilege. In other words, the magistrate judge did not address the extent, if any, to which defendant’s purposeful production of the Criteria Document might render the five-factor “inadvertent disclosure” test inapplicable. Significantly, each of the cases relied upon by the magistrate judge in support of his application of the five-factor test involved truly accidental and unknowing production of privileged materials, usually in the context of voluminous discovery responses. See Wallace v. Beech Aircraft Corp., 179 F.R.D. 313, 314 (D. Kan. 1998) (applying five-factor test for inadvertent disclosure where defendant produced a “substantial quantity” of documents to plaintiff for review, including two privileged documents that defendant had overlooked due to their inclusion within what appeared to be routine funding request forms); Zapata v. IBP, Inc., 175 F.R.D. 574, 576-77 (D. Kan. 1998) (applying five-factor test for inadvertent disclosure where defendant’s expert produced over one thousand documents during his deposition, including a copy of the opposing party’s expert report containing handwritten notes of defendant’s counsel, unbeknownst to defendant’s counsel); Monarch Cement Co. v. Lone Star Indus., Inc., 132 F.R.D. 558, 560 (D. Kan. 1990) (applying five-factor test for inadvertent disclosure where plaintiff produced 118 personnel files, one of which included 8 pages of privileged material buried at the back of the file and overlooked by counsel).
In contrast, the facts here demonstrate that defendant’s counsel specifically reviewed the 8

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Criteria Document and knowingly and intentionally produced that document after determining that paragraphs 9 and 10 should be redacted and that the remainder of the document should be produced to plaintiffs. According to defendant, its disclosure is nonetheless “inadvertent” because the disclosure was based on a mistake of counsel, who reviewed the document outside the context of Ms. Ferrel’s cover memorandum and, without the benefit of that memorandum, did not realize that the document was authored by defendant’s in-house counsel and could not otherwise ascertain from the face of the document that it was entitled to protection from disclosure.2 There is a distinction, however, between an “inadvertent” disclosure and a disclosure that is “advertent and intended where the person making discovery was merely unaware of the legal consequences or nature of the document produced.” Lifewise Master Funding v. Telebank, 206 F.R.D. 298, 303 (D. Utah 2002).
For example, in Transonic Systems, Inc. v. Non-Invasive Medical Technologies Corp., 192 F.R.D. 710 (D. Utah 2000), the plaintiff, in connection with a particular document production that included 450 pages of documents, produced a document prepared by and
2Although defendant suggests that its disclosure was “inadvertent” because it was based on the one-time mistake and uninformed belief of the lawyer who ultimately decided to produce the document in October 2005, other circumstances reflect that defendant, for months prior to the October 2005 production, did not believe that the Criteria Document was protected by the attorney-client privilege. Beginning in July 2005, defendant consistently identified the Criteria Document in its privilege logs as being protected from disclosure based only on the work product doctrine; defendant never asserted in its logs that the Criteria Document was protected from disclosure by the attorney-client privilege. This, in turn, suggests that when defendant initially reviewed and withheld the document from production in May 2005 that it did so based solely on the work product doctrine.
9

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containing comments from plaintiff’s in-house counsel. Id. at 711-12. The document was clearly labeled “Highly Confidential Attorneys’ Eyes Only.” Id. at 712. Rejecting the plaintiff’s argument that the disclosure was inadvertent, and concluding that the privilege had been waived, the court explained:
The facts of this case require a conclusion that when the subject document was produced, its content was known and it was produced with [plaintiff’s] counsel being aware of what it was and to what it related. . . . [W]hat was not appreciated at the time of production was the legal significance or the document. This was not a document inadvertently included in vast materials. The document was Bates stamped and voluntarily produced. The production was not an unintentional act. Poorly judged disclosure is not inadvertent. Therefore, this court concludes that disclosure of the document in question was not inadvertent, but mistaken, if at all, only as to whether it was privileged, and that therefore [plaintiff] is not entitled to return of the document. Id. at 715-16 (internal citation omitted). Similarly, in Koch Materials Co. v. Shore Slurry Seal, Inc., 208 F.R.D. 109, 112 (D.N.J. 2002), the plaintiff, in the course of producing more than six thousand documents, knowingly produced several handwritten unsigned documents without realizing that the documents were authored by in-house counsel and without attempting to determine the author of the documents. The court concluded that the circumstances justified a finding of waiver. See id. at 119. Here, it is undisputed that defendant’s counsel intended to provide a redacted version of the Criteria Document to plaintiffs’ counsel, albeit based on counsel’s admittedly uninformed belief that the document was not privileged. In light of these circumstances, the magistrate judge’s conclusion that disclosure of the Criteria Document was “inadvertent” is erroneous. Without question, defendant’s disclosure was intentional and voluntary and constitutes a waiver
10

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of the privilege. See Wunderlich-Malec Systems, Inc. v. Eisenmann Corp., 2006 WL 3370700, at *4-5 (N.D. Ill. Nov. 17, 2006) (disclosure was not inadvertent but voluntary–and thus privilege was waived–where defendant never actually intended prior to production to keep documents out of plaintiff’s hands but only intended to do so as an “afterthought”); see also Zapata, 175 F.R.D. at 576 (an “inadvertent” disclosure is one that “was not intended by [the party’s] attorneys”).
Having concluded that defendant’s voluntary disclosure of the Criteria Document is sufficient to waive the attorney-client privilege with respect to that document, the court necessarily concludes that defendant has also waived its claim that the work product doctrine protects the Criteria Document from disclosure. See In re Quest Comm. Intern. Inc., 450 F.3d 1179, 1185-86 (10th Cir. 2006) (voluntary production of work-product and/or privileged material during discovery waives both attorney-client privilege and work-product protection). One issue, however, remains for resolution and the court will remand it to the magistrate judge–whether plaintiff is entitled to an unredacted version of the Criteria Document. Clearly, paragraphs 9 and 10 constitute privileged attorney-client communications (because the entirety of the document is privileged) and the privilege was not waived by defendant’s disclosure because it redacted those paragraphs prior to disclosure. However, plaintiffs contend that defendant otherwise waived the privilege by failing to designate protection based on the attorney-client privilege in its privilege logs and, instead, asserting only work product protection. The magistrate judge did not address this argument in his order and, thus, the court leaves it for the magistrate judge to decide whether defendant waived the privilege with respect to paragraphs 9 and 10 by failing
11

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to assert that privilege in its logs. If the magistrate judge determines that defendant waived the privilege with respect to paragraphs 9 and 10, he must then decide the merits of defendant’s asserted work-product protection claim.
IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion for review (doc. 4427) is granted in part and denied in part. If plaintiffs have already returned the redacted Criteria Document to defendant, defendant shall provide another copy of the redacted Criteria Document to plaintiffs within 5 days of the date of this order. Otherwise, plaintiffs are entitled to retain the redacted Criteria Document. The court remands to the magistrate judge the limited issue of whether plaintiffs are entitled to an unredacted copy of the Criteria Document.
IT IS SO ORDERED.
Dated this 5th day of January, 2007, at Kansas City, Kansas.
s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4541 Filed 01/23/2007 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,

CIVIL ACTION No. 03-2200-JWL-DJW

Defendant.

MEMORANDUM AND ORDER

On November 16, 2006, Chief District Judge John W. Lungstrum remanded this matter

for factual findings concerning and an explanation of the reasons for the denial of Plaintiffs’

motion for sanctions (doc. 4423). The Court held a telephone status conference on November

20, 2006, and ordered the parties to submit further briefing on the issue. Defendant accordingly

filed its Proposed Findings of Fact in Support of April 25, 2006 Order Denying Plaintiffs’

Motion for Sanctions (doc. 4436). Plaintiffs thereafter filed their Response to Defendant’s

Proposed Facts and Motion for Findings of Fact Related to Denial of Plaintiffs’ Motion for

Sanctions (doc. 4459). As explained in greater detail below, the Magistrate Judge provides the

following explanation why he denied Plaintiffs’ motion to the extent it sought to impose

sanctions upon Defendant for its alleged failure to produce all spreadsheet materials in native

format, its failure to timely produce the spreadsheet materials that were produced, and its

conduct in re-producing spreadsheet materials in non-native format that had already been

produced in native format.

I. Procedural History

Case 2:03-cv-02200-JWL-DJW Document 4541 Filed 01/23/2007 Page 2 of 13
On February 15, 2006, Plaintiffs filed an omnibus motion seeking to amend the scheduling order, to compel Defendant to produce RIF spreadsheets and e-mails in native format, to permit Plaintiffs access to Defendant’s computer system, and for sanctions against Defendant. Plaintiffs requested that sanctions be imposed on Defendant for its alleged failure to produce “spreadsheet materials” in native format, its failure to timely produce other spreadsheet materials, and its production of duplicate spreadsheet materials in non-native format that had already been produced in native format. Plaintiffs’ sanction request sought “whatever sanction the Court deems appropriate against Defendant Sprint for its conduct in response to Judge Lungstrum’s August 12, 2005 Order -- primarily the failure to produce spreadsheet materials in native format and the re-production of more than 200,000 pages of spreadsheet materials (in non-native format) that had already been produced in native format,” along with “whatever sanction the Court deems appropriate against Defendant Sprint for failing to timely produce spreadsheet materials as required by Judge Waxse’s May 5, 2005 Show Cause Order and other Show Cause Orders.”
Plaintiffs’ motion, along with twelve other pending discovery motions, was resolved in open court at the April 20, 2006 discovery conference and the ruling on the motion was memorialized in paragraph 8 of an Order dated April 25, 2006 (doc. 3896). The Magistrate Judge denied without prejudice Plaintiffs’ motion to compel for lack of specificity as to the documents sought. He also found sanctions were not appropriate and denied the motion to the extent it sought sanctions, advising the parties that “I think the best approach so far is to avoid those when we can.”
2

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On May 9, 2006, Plaintiffs filed a Motion for Review and Objections to Portions of Paragraph 8 of Magistrate’s Order of April 25, 2006 (doc. 4102). On June 30, 2006, Judge Lungstrum issued a Memorandum and Order (doc. 4212) retaining Plaintiffs’ motion for review under advisement and remanding the underlying motion to compel discovery to the Magistrate Judge based on the lack of a sufficient record. The Memorandum and Order directed the Magistrate Judge to render factual findings sufficient to enable the District Judge to perform a meaningful review of the decision on the motion to compel and for sanctions.
On July 10, 2006, an order was issued in response to the remand. That Order memorialized the substance of the April 20, 2005 hearing where the Magistrate Judge ruled on the omnibus motion to compel and for sanctions. In particular, the order set forth the nature of the verbal exchange that lead to the denial of sanctions. That exchange involved the Magistrate Judge specifically inquiring whether Defendant had produced the RIF spreadsheets and e-mails in native format, which he understood to be the primary basis of Plaintiffs’ motion to compel and request for sanctions. Based on Defendant’s representation in open court that it had produced, at the time of the pleading, all decision-making type RIF spreadsheets in native format of which it was aware, the Magistrate Judge found that Defendant had met its obligation to produce RIF spreadsheets in native format, unless Plaintiffs had a specific issue with a specific spreadsheet or email that they believed Defendant had not produced in native format. As the Magistrate Judge found that Defendant had met its obligation to produce RIF spreadsheets in native format, the Magistrate Judge denied Plaintiffs’ related request for sanctions.
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On July 24, 2006, Plaintiffs filed a motion to reconsider or clarify the July 10, 2006 order by making specific factual findings regarding Plaintiffs’ motion for sanctions. After the motion to reconsider was denied on September 13, 2006, Plaintiffs filed a motion for review (doc. 4334) with the District Judge appealing the Magistrate Judge’s denial of Plaintiffs’ motion for sanctions. In their motion, Plaintiffs specifically requested that Judge Lungstrum sanction Defendant based on its “highly prejudicial sluggish conduct, non-native format production, and duplication in response to this Court’s August 12, 2005 Order,” and “inordinate and prejudicial delay in failing to timely produce spreadsheets as required by Judge Waxse’s May 5, 2005 Show Cause Order and other Show Cause Orders.”
On November 16, 2006, District Judge Lungstrum again remanded the matter to the Magistrate Judge for factual findings concerning and an explanation of the reasons for the denial of Plaintiffs’ motion for sanctions (doc. 4423). In accordance with this directive, the Magistrate Judge provides the following more detailed explanation of the denial of Plaintiffs’ motion to the extent it requested the imposition of sanctions against Defendant. II. Legal Standards Under Which a Court May Impose Discovery Sanctions
A court has both express power, under the Federal Rules of Civil Procedure, and inherent power to impose sanctions for bad faith conduct during discovery.1 Rule 37 provides two frameworks for the imposition of sanctions. First, under Rule 37(a) and (b), a party may move for an order to compel discovery. If that motion is granted and a party refuses or fails to comply with the court’s order, the court may issue a wide range of sanctions under Rule
1See Fed. R. Civ. P. 37; Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991); Roadway Express, Inc. v. Piper, 447 U.S. 752, 765 (1980).
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37(b). Second, subsection (d) provides for a less common scenario when sanctions may be imposed even though no prior court order has been issued. The court may enter an order for sanctions under Rule 37(d), for example, if a party fails to attend a deposition or respond to discovery requests. Rule 37(d) also allows the court to award attorney’s fees and expenses.
The court may also impose sanctions based on its inherent authority. Federal courts possess inherent powers necessary “to manage their own affairs so as to achieve the orderly and expeditious disposition of cases.”2 A court’s inherent power “is governed not by rule or statute but by the control necessarily vested in courts to manage their own affairs so as to achieve the orderly and expeditious disposition of cases.”3
The imposition of sanctions for a party who violates discovery orders, as well as the choice of an appropriate sanction, is a matter committed to the sound discretion of the court.4 District of Kansas Rule 11.1(c) provides that “[i]n considering the imposition of sanctions, the court may consider whether a party’s failure was substantially justified or whether other circumstances make the imposition of sanctions inappropriate.”5 Fed. R. Civ. P. 37(b)(2) also requires that any sanction be just and that the sanction be specifically related to the particular claim which was at issue in the order to provide discovery. In selecting a proper sanction for delayed production of requested materials, the district court should consider the reasons the
2Chambers, 501 U.S. at 43 (citing Link v. Wabash R. Co., 370 U.S. 626, 630-631 (1962)).
3Link, 370 U.S. at 630-31; see also Roadway Express, 447 U.S. at 765. 4Myers v. Colgate-Palmolive Co., 102 F. Supp. 2d 1208, 1222 (D. Kan. 2000); see also D. Kan. Rule 11.1(c). 5D. Kan. Rule 11.1(c).
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party delayed producing requested materials, including whether the party acted in bad faith, the extent of prejudice to the defendant as a result of the delay, and the feasibility of curing any prejudice.6 III. Reasons for Denial of Plaintiffs’ Motion for Sanctions
Judge Lungstrum’s remand indicates the need for factual findings regarding three separate discovery abuses alleged by Plaintiffs: (1) Defendant’s failure to produce all “spreadsheet materials” in native format, (2) Defendant’s failure to timely produce spreadsheet materials that were produced, and (3) Defendant’s re-production of spreadsheet materials in non-native format that had already been produced in native format. The Magistrate Judge will address each alleged discovery abuse separately.
A. Failure to Produce Spreadsheet Materials in Native Format Plaintiffs’ motion for sanctions states that it is primarily based on Defendant’s failure to produce “spreadsheet materials” responsive to Judge Lungstrum’s August 12, 2005 Memorandum and Order in native format. Plaintiffs argue that Defendant should be sanctioned for its decision to produce the RIF selection spreadsheets, ordered to be produced by Judge Lungstrum’s August 12th Memorandum and Order, as .tif images rather than in their native format. They contend that although Judge Lungstrum’s August 12th Memorandum and Order did not specify that Defendant produce the spreadsheet materials in native format, the Magistrate Judge’s discovery conference rulings required Defendant to produce these materials in native format.
6Goeken v. Wal-Mart Stores, Inc., No. 99-4191-SAC, 2002 WL 1334863, at *1 (D. Kan. May 23, 2002) (citing United States v. Russell, 109 F.3d 1503, 1511 (10th Cir.1997)).
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According to Defendant’s proposed findings of fact, at the beginning of this case, the parties voluntarily reached an agreement that Defendant would produce responsive documents, including spreadsheet materials, in .tif format only. Pursuant to that agreement, Defendant states that its counsel established its own internal database and production protocol designed for the production of documents in .tif format and produced a significant amount of data in .tif format for a year and a half. More than a year after the provisional certification of the case, Plaintiffs changed their minds and requested that the RIF selection spreadsheets be produced in native format. According to Defendant, the original agreement that documents would be produced in .tif format was thus amended on May 19, 2005, such that RIF selection spreadsheets would be produced in native format. In June 2005, Defendant began tendering RIF spreadsheets as previously ordered by the Magistrate Judge in native format. On August 12, 2005, Judge Lungstrum issued his Memorandum and Order in which he ordered Defendant to produce all RIF-related spreadsheets (not just the RIF selection spreadsheets) and other materials. In response to that order, Defendant produced responsive documents in .tif format. Defendant asserts that it reasonably believed in good faith that the August 12th Memorandum and Order did not modify the parties’ original agreement that Defendant produce documents as .tif images. When it was later ordered to produce the spreadsheets in native format, Defendant states that it complied with that order within six weeks.
As indicated in response to the Magistrate Judge’s inquiry at the April 20, 2006 discovery conference, Defendant represented that it had, at the time of the motion for sanctions, produced all decision-making type RIF spreadsheets in native format of which it was aware. Upon hearing that Defendant had produced all available spreadsheets in native format, the
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Magistrate Judge found that Defendant met its obligation to produce the RIF spreadsheets in native format.
To the extent Plaintiffs seek sanctions based on Defendant’s decision to initially produce the spreadsheet materials responsive to Judge Lungstrum’s August 12, 2005 Memorandum and Order as non-native .tif images rather than in their native format, the Magistrate Judge finds that Defendant’s production as .tif images does not constitute sanctionable conduct. Several circumstances lead the Magistrate Judge to this finding. First, none of Plaintiffs’ original discovery requests for the RIF spreadsheets specified that the spreadsheets should be produced in their native format rather than as .tif images, which was the parties’ original agreement. It was only after Defendant began producing the RIF selection spreadsheets as .tif images in response to the Magistrate Judge’s May 5, 2005 Show Cause Order that Plaintiffs requested that Defendant re-produce the previously-produced spreadsheets in their native Excel format. Second, the August 12th Memorandum and Order did not specify that Defendant produce the documents in native format. Third, Plaintiffs were aware of the logistical problems Defendant was experiencing attempting to simultaneously produce documents responsive to Judge Lungstrum’s August 12th Memorandum and Order and the Magistrate Judge’s orders. Fourth, Defendant advised Plaintiffs that it did not have all of the spreadsheets in their native format, but some spreadsheets were only maintained in hard copy or .tif format. Fifth, the timing of the Magistrate Judge’s prior and subsequent discovery conference rulings created ambiguity whether the Magistrate Judge’s order that the RIF selection spreadsheets be produced in their native format applied to Judge Lungstrum’s August 12th Memorandum and Order to produce all RIF-related spreadsheets. Finally, Defendant
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subsequently produced all the spreadsheets it had in native format. Given these circumstances, the Magistrate Judge found that Defendant should not be sanctioned for initially producing the spreadsheets in .tif format rather than native format.
B. Failure to timely produce spreadsheet materials 1. Production in response to the Magistrate Judge’s Orders
Plaintiffs also request that the Magistrate Judge impose sanctions on Defendant for their failure to timely produce spreadsheet materials as required by Judge Waxse’s May 5, 2005 Show Cause Order and other Show Cause Orders. Defendant argues that Plaintiffs have not provided any evidence that it intentionally or negligently delayed production of any documents or otherwise acted in bad faith, nor that they have suffered prejudice from any delay. Defendant further argues that Plaintiffs bear a portion of the responsibility for the discovery delays in this case, by changing their minds about whether they wanted materials in .tif or native format and by failing to provide the bates numbers of particular .tif spreadsheets they desired in native format in response to Defendant’s offer to produce such documents.
At almost every discovery conference, the Magistrate Judge heard from Plaintiffs that it was taking Defendant too long to produce the spreadsheets and inquired of Defendant why it was taking so long. The Magistrate Judge agrees with Plaintiffs that it did take Defendant a long time to produce the spreadsheets at issue. However, as Plaintiffs neglect to mention, Defendant provided at almost every discovery conference some explanation why the spreadsheets could not be produced as previously anticipated. At the February 2, 2006 discovery conference, the Magistrate Judge expressly held that Defendant had provided an
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adequate explanation of why it had not completed production of all spreadsheets in their native electronic format previously produced to Plaintiffs in non-native format.
Having conducted numerous discovery conferences where the parties provided detailed explanations of their problems, the Magistrate Judge finds that Defendant’s delays were neither willful nor motivated by a desire to obtain a tactical advantage, but instead were caused by the unique circumstances of the case. Those circumstances include Plaintiffs’ lack of specificity in its initial discovery requests, Plaintiffs’ subsequent alterations to those discovery requests, the manner in which Defendant collected and maintained documents, as well as the way it structured and coordinated its production efforts responsive to multiple discovery requests and court orders. Based on these circumstances, the Magistrate Judge declined to impose sanctions on Defendant.
2. Production in response to Judge Lungstrum’s August 12, 2005 Memorandum and Order
Plaintiffs also seek sanctions based on Defendant’s failure to timely produce the spreadsheets in response to Judge Lungstrum’s August 12, 2005 Memorandum and Order. The docket, however, reflects that Defendant timely requested and was granted extensions of time to provide its final certification that all responsive documents had been produced and that it had fully and completely complied with its obligations under the Order. The last two extensions were unopposed by Plaintiffs. For Plaintiffs to now argue that Defendant’s production was untimely is not well taken in light of these facts.
Plaintiffs make much of the fact that Defendant produced over two-thirds of the documents during the last week of the four-month period it took to respond to the August 12, 2005 Memorandum and Order. While the Magistrate Judge understands Plaintiffs’ frustration
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with Defendant producing a large number of documents in the last week it had to complete the production of documents responsive to Judge Lungstrum’s August 12, 2005 Memorandum and Order, the Magistrate Judge does not find Defendant’s disproportionately large production of documents in the last week constitutes sanctionable conduct.
C. Re-producing spreadsheet materials in non-native format that had already been produced in native format
Plaintiffs also seek sanctions based on Defendant’s re-producing more than 200,000 pages of spreadsheet materials (in non-native format) that had already been produced in native format. They claim that of the 381,706 pages Defendant produced, more than 200,000 were duplicates. Defendant argues that there is no evidence that it intentionally or negligently re-produced documents in bad faith or otherwise acted in any manner inconsistent with a good faith effort to produce documents in response to discovery requests and court orders. It further argues that duplication is inevitable in a document-intensive case such as this, and there is no evidence that duplication here is outside what would be expected under the circumstances of this case. Finally, Defendant explains that production of some of the same documents in non-native format after they had already been produced in native format may have been the result of the fact that it was engaged in a good faith attempt to complete two document productions during the same time period. The completion of its production of the RIF selection spreadsheets in native format overlapped in time and scope with its non-native response to the Judge Lungstrum’s broader August 12, 2005 Memorandum and Order. In order to eliminate re-production of some spreadsheets, Defendant argues that it would have had to remove the already-produced RIF selection spreadsheets from the August 12, 2005 production, which would have only resulted in further delays.
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With regard to the reproduction of spreadsheet materials in non-native format that had already been produced in native format, the Magistrate Judge finds there is no evidence that Defendant intentionally or negligently re-produced duplicate documents in bad faith or otherwise acted in any manner inconsistent with a good faith effort to produce documents in response to all the discovery orders and Plaintiffs’ discovery requests. As pointed out by Defendant, a certain amount of duplication is inevitable in a large document-intensive case such as this one. Moreover, Plaintiffs’ motion for sanctions was not the first time the Magistrate Judge heard Plaintiffs’ complaints regarding Defendant’s production of documents that were duplicates. When Plaintiffs raised the duplicate production issue at the December 15, 2005 discovery conference, Defendant’s counsel stated that he “would not be surprised if there was duplication on some of these spreadsheets.”7 Defendant explained then that its goal was to respond completely to Judge Lungstrum’s August 12, 2005 Order where it was to certify that it had produced all spreadsheets, not just human resources, and not just restricted the way it earlier indicated it would produce them. Because of its production of everything, Defendant warned Plaintiffs that it was “very likely that there are duplicates of some of the other spreadsheets that have been produced earlier in this case.”8
Plaintiffs have provided no precedent for imposing sanctions based upon a party’s production of duplicate documents. The Magistrate Judge finds that mere production of duplicate documents, without any evidence of bad faith or improper motive, does not constitute sanctionable conduct. Plaintiffs were aware that Defendant was producing documents in
7See Dec. 15, 2005 Tr. p. 54. 8See Dec. 15, 2005 Tr. p. 55.
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response to multiple requests and court orders. They should have therefore expected a certain amount of duplication. Furthermore, the Magistrate Judge finds that Plaintiffs’ own actions in making repeated requests that documents be reproduced in different formats also contributed to the duplicate production. For these reasons, the Magistrate Judge finds that sanctions against Defendant were not appropriate.
RESPECTFULLY SUBMITTED, Dated in Kansas City, Kansas on this 23rd day of January, 2007.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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 Case 2:03-cv-02200-JWL-DJW Document 4551 Filed 01/31/2007 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.
MEMORANDUM & ORDER
Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated
asserting that her age was a determining factor in defendant’s decision to terminate her
employment during a reduction-in-force. This case has been provisionally certified as a
collective action pursuant to 29 U.S.C. § 216(b). This matter is presently before the court on
plaintiff’s motion to reconsider and/or clarify (doc. 4495) the court’s December 8, 2006
memorandum and order denying that portion of plaintiffs’ motions to review challenging
whether defendant had waived the attorney-client privilege by asserting its “good faith” compliance with the ADEA. For the reasons set forth below, the motion is denied.1
In its December 8, 2006 memorandum and order, the court concluded that defendant has
not waived the attorney-client privilege by asserting its good faith compliance with the ADEA.
1Plaintiffs also move the court to reconsider a second order issued by the court on December 8, 2006 (an order denying plaintiffs’ motion to review the magistrate judge’s order granting defendant’s motion for protective order prohibiting discovery relating to adverse impact analyses) to the extent that order is based on conclusions reached in the court’s first order issued on December 8, 2006. For the reasons stated herein, then, plaintiffs’ motion to reconsider the court’s second order of December 8, 2006 is also denied.

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Specifically, the court concluded that defendant has not waived the privilege by referencing “disparate impact” review or “legal review” in its anti-discrimination policies (policies upon which defendant intends to rely to demonstrate its good faith compliance); that defendant has not waived the privilege by its reliance on the due diligence review conducted by human resources (a review that the court found to be distinct from the review process conducted by defendant’s legal department); and that defendant has not waived the privilege by its witnesses’ testimony concerning reliance on counsel’s advice as to whether any RIF selection decisions violated or appeared to violate anti-discrimination laws. Plaintiffs now move the court to reconsider its memorandum and order, contending that the court “did not address certain facts and arguments” presented by plaintiffs and that the order contains “other errors which must be corrected to prevent manifest injustice.”
As will be explained, the motion to reconsider is denied and the record is closed with respect to the underlying motions to review and, more specifically, the waiver issue. The court, in rendering its December 8, 2006 memorandum and order, thoroughly examined all the evidence and arguments submitted by the parties and carefully reviewed the transcript of the full evidentiary hearing conducted before the magistrate judge. At no time during the pendency of the motions to review did plaintiffs suggest that they desired to submit evidence beyond what was before the court or that the record before the court was somehow insufficient to permit the court to resolve the waiver issue. The court takes this opportunity, however, to clarify that the scope of the court’s December 8, 2006 memorandum and order is fairly limited, contrary to what plaintiffs apparently perceive as the scope of the court’s order. In that regard, the limited issue
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before the court (and the only issue resolved by the court in its December 8, 2006 memorandum and order) was whether defendant had waived the attorney-client privilege with respect to “adverse impact” documents by asserting its good faith compliance with the ADEA–in other words, the court resolved only whether the adverse impact documents remained privileged despite defendant’s assertion that it complied in good faith with the ADEA. While that ruling certainly has implications in the discovery context, the court did not resolve issues concerning the parties’ discovery obligations with respect to non-privileged documents and inquiries (those issues were expressly left to the magistrate judge for resolution in the first instance upon motion by one of the parties) and did not resolve broad issues concerning the admissibility of evidence at trial. Thus, to the extent plaintiffs express concern in their motion about these subjects, those concerns are premature and not pertinent to the court’s December 8, 2006 order.
The Court’s Failure to Address All Deposition Excerpts and Written Discovery Responses In its December 8, 2006 memorandum and order, the court concluded that defendant’s
intention to introduce evidence of human resources’ due diligence review of selection decisions does not implicate the adverse impact analyses or any other privileged communication and that defendant has not waived the privilege by its reliance on the separate, initial due diligence review conducted by human resources. In so concluding, the court rejected plaintiffs’ argument that defendant’s objections, on the basis of attorney-client privilege, to matters concerning the due diligence review demonstrates that the HR due diligence review is inextricably intertwined with the review conducted by the legal department. Plaintiffs now move for reconsideration of
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this portion of the court’s order on the grounds that the court did not discuss (and, therefore,
according to plaintiffs, presumably did not consider) all of the deposition excerpts and written
discovery responses provided by plaintiffs purportedly demonstrating, by virtue of defendant’s
privilege objections, that the two review processes are inextricably intertwined.
The court assures plaintiffs that it, in fact, carefully considered all of the deposition
excerpts and written discovery responses submitted by plaintiffs concerning the issue of whether
defendant’s objections demonstrated that the two review processes are intertwined. With respect
to the deposition excerpts, the court did not specifically address in its order each example
provided by plaintiffs; rather, the court, after reviewing each example, selected various
highlights to address in explaining the court’s conclusions, much like plaintiffs highlighted the
deposition excerpts of Marvin Motley and John Shannon (excerpts that the court did specifically
address).2 In any event, none of the examples provided by plaintiffs changes the court’s position
2As the court noted in its December 8, 2006 memorandum and order, John Shannon testified that he utilized the adverse impact analyses in performing his own due diligence review of selection decisions, that he was not authorized to do so, and that his conduct was contrary to corporate policy. In explaining that defendant was not asserting the attorneyclient privilege with respect to adverse impact analyses conducted by Mr. Shannon, then, the court noted that “defendant has produced documents relevant to Mr. Shannon’s ‘own’ adverse impact analyses.” In their motion to reconsider, plaintiffs assert that, in fact, none of the materials with regard to Mr. Shannon’s own review have been produced by defendant. The court’s December 8, 2006 order, however, did not purport to resolve whether nonprivileged documents had been produced or whether defendant had met its discovery obligations in that regard; the sole issue before the court was whether defendant had waived the privilege by asserting its good faith compliance with the ADEA. Any issues concerning document production, then, should be advanced before the magistrate judge (appropriately, plaintiffs indicate that they have filed with the magistrate judge a motion to compel these documents).
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that the deponents–because of either the nature of plaintiffs’ questions or defendant’s practice of shielding questions with privilege objections–were not sufficiently focused on the separate, initial due diligence review performed by human resources to permit this court to conclude, as urged by plaintiffs, that defendant’s refusal to permit these witnesses to answer deposition questions concerning any “due diligence” review demonstrates that the HR due diligence review is inextricably intertwined with the review conducted by the legal department.
Similarly, while the court did not discuss the one written discovery response submitted by plaintiffs in support of their argument that defendant’s privilege objection to “due diligence” inquiries necessarily demonstrates that the HR due diligence review is inextricably intertwined with the review conducted by the legal department, the court examined that response and readily concluded, consistent with its review of the deposition excerpts, that defendant’s response did not mandate a finding that the two review processes are intertwined. In Request No. 45 of plaintiffs’ Ninth Request for Production of Documents, plaintiffs sought “all documents that refer to, reflect, describe or contain the results of any due diligence review conducted by HR personnel of the demographic data to ensure that the decisions avoid the appearance of impropriety regarding employees’ races, genders, and/or ages, as described by Sprint on p.5, ¶ 1, third sentence of Doc. 2787” (emphasis added). Sprint asserted a host of objections in response to the request, including an objection that the request “seeks documents subject to the attorney-client privilege and the attorney work-product doctrine.” The court cannot ascertain, based solely on the written request and response, whether Sprint is suggesting that no separate and non-privileged review occurred or whether some portion of what human resources’
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employees would call “any due diligence review” included work done at the direction of counsel. While this may be an example of Sprint improperly lodging a privilege objection, the court specifically left the door open to revisiting the waiver issue if Sprint presses its objections to discovery concerning the separate due diligence conducted by HR. Because the court has left the door open depending on the course that defendant elects to take, reconsideration of the court’s order is not warranted at this juncture.3
Defendant’s Continued Objections to Matters Concerning Due Diligence The court’s December 8, 2006 ruling that defendant’s reliance on the “separate” due
diligence conducted by human resources has not waived the privilege (or, stated another way, that human resources’ due diligence was not inextricably intertwined with the adverse impact review conducted by the legal department) was expressly premised on defendant’s representation that it would not lodge privilege objections to questions concerning that due diligence. Plaintiffs now move the court to reconsider its order in part because, according to plaintiffs, defendant,
3Plaintiffs also highlight in their motion to reconsider defendant’s privilege logs which allegedly show that defendant has withheld hundreds of “due diligence” documents based on the attorney-client privilege. These logs were not presented to the court prior to the submission of the motion to reconsider and, thus, the court need not consider those logs at this time. Similarly, plaintiffs criticize the court for failing to specifically address the deposition testimony of Deb Sprayberry and, instead, focusing solely on Ms. Sprayberry’s testimony at the evidentiary hearing before Judge Waxse. Ms. Sprayberry’s deposition testimony, however, was not submitted to the court in connection with the waiver issue and the court is hard-pressed to find error in failing to discuss that testimony under the circumstances. In any event, because the testimony was submitted in connection with a separate motion to review that the court had before it during the same time frame, the court did, in fact, review that testimony to the extent it provided insight into the waiver issue.
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since the court’s order, has continued to object to matters that concern purely “due diligence” reviews as privileged material. However, a motion to reconsider is clearly not the appropriate procedural vehicle to raise this argument. While the court’s order left open the possibility that it might need to revisit the waiver issue if defendant continued to press its privilege objections with respect to matters concerning human resources’ due diligence review, the court’s order made clear that it would revisit the issue only after defendant’s objections were presented to the magistrate judge for resolution. Simply put, plaintiffs’ complaints to this court concerning defendant’s continued objections are premature.
HR Personnel Utilizing Adverse Impact Analyses in their Own Due Diligence Reviews In its December 8, 2006 memorandum and order, the court concluded that defendant’s
intention to introduce evidence of human resources’ due diligence review of selection decisions does not implicate the adverse impact analyses because the record, as presented to the court, demonstrated that human resources conducted a separate, initial due diligence review of selection decisions (consisting primarily of reviewing candidate selection worksheets) that did not utilize the adverse impact analyses in any fashion. Plaintiffs move the court to reconsider this portion of its order, urging that certain witnesses testified that the due diligence conducted by Human Resources did involve reviewing the adverse impact analyses such that the two review processes are inextricably intertwined. While plaintiffs previously presented (and the court rejected) this argument, plaintiffs contend that the court did not consider all of the evidence they presented to support their argument.
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Contrary to plaintiffs’ argument, the court considered all the evidence presented by plaintiffs on this issue. The court, for example, quite thoroughly examined and discussed Marvin Motley’s testimony and, although plaintiffs disagree with the court’s interpretation of that testimony, plaintiffs cannot seriously dispute that the court considered Mr. Motley’s testimony in its entirety. While plaintiffs highlight that another employee, Jon Binder, testified that HR “looked” at the adverse impact spreadsheet before sending it on to the legal department, this testimony is not inconsistent with the court’s conclusion that the adverse impact analyses were not utilized by HR in connection with the separate due diligence review performed by HR. Plaintiffs also make much of the “best stats” e-mail exchange involving HR employee Gene Lampe and the deposition testimony of Sharon Louk, contending that this evidence clearly indicates that HR was utilizing the adverse impact analyses. But plaintiffs are conflating two separate issues–the issue of HR personnel exchanging adverse impact analyses exclusively among other HR personnel for the purpose of achieving “better stats” and the issue of whether, apart from this activity, HR otherwise performed a separate due diligence review (upon which defendant intends to rely to demonstrate its good faith compliance with the ADEA) that did not involve the adverse impact analyses.
As the court held in its November 9, 2006 order in large part denying plaintiffs’ motion to review, the fact that certain adverse impact documents were never sent to counsel and were exchanged exclusively among HR personnel for the purpose of manipulating the decisional units to achieve better statistics is not fatal to defendant’s claim of privilege and the court affirmed the magistrate judge’s decision that such documents are nonetheless protected by the attorney-client
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privilege because the documents were made for the purpose of obtaining legal advice. This issue is entirely distinct from the issue of whether HR conducted a separate non-privileged due diligence review that did not involve use of the adverse impact analyses. In other words, while the evidence highlighted by plaintiffs in their motion to reconsider indicates that HR on occasion used the adverse impact analyses, the evidence does not indicate that HR did so in connection with its own initial “sore thumb” due diligence review.
Redaction In its December 8, 2006 memorandum and order, the court concluded that, for purposes
of trial, all references to “disparate impact” and coordination or counseling with the legal department will be redacted from the Workforce Reduction Guidelines. In their motion to reconsider, plaintiffs essentially assert that this portion of the court’s order is unfair and that they are “uncomfortable” with the court’s approach. Significantly, nearly every argument made by plaintiffs in their motion to reconsider concerning the redaction of the Workforce Reduction Guidelines was either made by plaintiffs in their December 5, 2006 submission to the court (and addressed by the court in its order) or could have been made by plaintiffs in their December 5, 2006 submission to the court. These arguments, then, are not proper on a motion to reconsider. See Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000) (a motion for reconsideration is not appropriate vehicle to revisit issues already addressed or advance arguments that could have been raised previously). While plaintiffs express concern over whether defendant will be permitted to redact numerous other documents (and appear to fault
9

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the court for failing to address these other documents in its order), plaintiffs overlook the limited holding of the court’s December 8, 2006 order–that redaction of the Workforce Reduction Guidelines will be permitted.
Moreover, contrary to plaintiffs’ suggestion, the court expressly addressed the other documents submitted by plaintiffs that plaintiffs contended amounted to “written policies and mandatory guidelines.” After reviewing those documents, the court stated that it could not “conclude that any other documents before it constitute the type of ‘policy’ on which defendant intends to rely to support its good faith defense.” For purposes of plaintiffs’ motion to review, then, the court disregarded these other documents, most of which appeared to be stray e-mails referencing “adverse impact” or the need for “legal review” of selection decisions, as the focus of the issue before the court was defendant’s reliance on its anti-discrimination policies. The court, then, had no need to resolve whether any of these documents should be redacted and that issue can be resolved at a later date, assuming the documents are otherwise admissible at trial.
Pattern and Practice Issues Next, plaintiffs contend that the court’s memorandum and order is erroneous because it
precludes plaintiffs from using evidence (namely, evidence concerning defendant’s review of selection decisions for adverse impact) that would assist plaintiffs in proving a pattern and practice of discrimination. According to plaintiffs, the adverse impact evidence is itself “strong evidence” of a pattern and practice of age discrimination. This argument is rejected as it is made for the first time on plaintiffs’ motion to reconsider. See Servants of Paraclete v. Does, 204 F.3d
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1005, 1012 (10th Cir. 2000). In any event, even assuming that evidence of defendant’s adverse impact review would be helpful to plaintiffs’ case, plaintiffs have not articulated why that, in and of itself, would justify breaching the attorney-client privilege or triggering a waiver of the privilege.
Crime/Fraud Exception Plaintiffs also criticize the court for failing to address in its order the crime/fraud
exception to defendant’s assertion of the attorney-client privilege. Curiously, the crime/fraud issue is one that has never been raised by plaintiffs; the court, sua sponte, raised the issue of the applicability of the crime/fraud exception during the November 16, 2006 telephone conference with the parties. The court was satisfied with defense counsel’s responses during that discussion and plaintiffs never raised the issue at any point after the November 16, 2006 conference. In such circumstances, no issue existed with respect to the crime/fraud exception for the court to address in its December 8, 2006 order.
Request for In-Person Hearing Finally, plaintiffs request an in-person hearing “where these issues can be discussed and
where the evidence can be viewed,” including video tapes of certain depositions. Plaintiffs have not previously requested an in-person hearing or oral argument generally concerning their motions to review or specifically concerning the waiver issue and it is inappropriate to make such a request only after the court has denied plaintiffs’ motions to review. Moreover, nothing
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Case 2:03-cv-02200-JWL-DJW Document 4551 Filed 01/31/2007 Page 12 of 12 presented in their motion to reconsider warrants an in-person hearing or oral argument. Both parties have taken advantage of every opportunity provided to them (and there were many) to submit exhaustive briefing and a full evidentiary record, all of which the court has considered. In such circumstances, the court is confident that oral argument would not assist the court in resolving the issues before it and would not alter the court’s conclusions in any manner. IT IS THEREFORE ORDERED BY THE COURT THAT plaintiffs’ motion to reconsider and/or clarify (doc. 4495) is denied. IT IS SO ORDERED. Dated this 31st day of January, 2007, at Kansas City, Kansas. s/ John W. Lungstrum John W. Lungstrum United States District Judge
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 Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 1 of 22

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO.,

Defendant.

MEMORANDUM AND ORDER

Pending before the Court is Plaintiffs’ Motion to Compel Defendant’s Witnesses to Respond

to Deposition Questions (doc. 4362). More specifically, Plaintiffs seek an Order requiring eleven

of Defendants’ witnesses to reappear for deposition and

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respond to specific questions to which Defendant’s counsel previously

directed such witnesses not to answer on grounds of privilege; and

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respond to all other questions inquiring into Defendant’s RIF-related adverse

impact analyses (other than privileged legal advice the witness received).

Procedural Background

This is not the first time the parties have sought Court intervention in order to resolve a

discovery dispute regarding the privileged nature of deposition questions inquiring into the issue of

adverse impact analyses. On November 4, 2005, Defendant filed a Motion for Protective Order1

requesting the Court issue an order precluding Plaintiffs from continued questioning of deponents

regarding Defendant’s RIF-related adverse impact analyses, which Defendant claims is protected

from disclosure by privilege. Given the adverse impact issue in Defendant’s Motion for Protective

Order was identical to the adverse impact issue presented in various other motions that had been

1Doc. 3417.

Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 2 of 22
previously filed, the Court deferred ruling on the Motion for Protective Order until the Court had
ruled on whether the adverse impact documents were protected from disclosure by privilege.
This Court ultimately resolved this issue in favor of protection by the attorney-client privilege for the adverse impact documents at issue.2 In light of these rulings, this Court granted
Defendant’s Motion for Protective Order regarding deposition questions “to the extent any of
plaintiffs’ deposition questions require defendant or its agents to reveal confidential RIF-related
adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice.”3 Plaintiffs filed a motion for review this decision with Judge Lungstrum and, on the same
day, also filed the instant Motion to Compel Defendant’s witnesses to respond to adverse impact
deposition questions.
On December 8, 2006, Judge Lungstrum denied Plaintiffs’ Motion for Review. In so doing,
he specifically stated as follows:
The magistrate judge expressly held that plaintiffs could not pose questions that would “require Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice” but that plaintiffs could pose questions “regarding underlying facts and data compilations associated with adverse impact analyses (e.g., Master List and RIF List) or information regarding adverse impact analyses that was not generated at the direction of counsel for the purpose of seeking legal advice.”
Significantly, the magistrate judge did not have presented to him by either party any specific examples of potential deposition questions or any specific examples of defendant’s objections to specific questions propounded in a deposition. Not surprisingly, then, the magistrate judge did not attempt to speculate as to what questions might be appropriate in the context of a deposition. Again, the appropriate vehicle for plaintiffs to obtain specific guidance is one which they have already utilized through the filing of their motion to compel responses to deposition
2Docs. 4213 (original) and 4315 (on reconsideration) 3Doc. 4343.
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questions.4 Discussion
Based on this Court’s previous ruling regarding adverse impact analyses deposition questions in general, as well as the directive in Judge Lungstrum’s December 8, 2006 Memorandum and Order, the Court finds , as a preliminary matter, that the portion of the pending Motion that seeks to compel Defendant to respond to any prospective question “inquiring into Defendant’s RIF-related adverse impact analyses (other than privileged legal advice the witness received)” must be denied . This is because, as Judge Lungstrum states, such a request requires this Court to “attempt to speculate as to what questions might be appropriate in the context of a deposition.”
With regard to that portion of the pending Motion that seeks to compel Defendant to respond to specific questions, the Court will utilize the following legal standard for the deposition questions posed and the privilege objections lodged:
Privilege objections to deposition questions will be sustained to the extent a deposition question requires Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. Privileged objections to deposition questions will be overruled to the extent a deposition question inquire into only underlying facts and data compilations associated with adverse impact analyses (e.g., Master List and RIF List) or information – not confidential – regarding adverse impact analyses that was not generated at the direction of counsel for the purpose of seeking legal advice.
4Doc. 4462 at p.7. 3

Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 4 of 22
1. BURDEN OF PROOF The Federal Rules of Civil Procedure specifically limit the scope of discovery to matters that
are “not privileged.”5 As in this case, a claim of privilege may be made by objection to a question asked at a deposition.6 When a party objects and thereafter withholds information otherwise discoverable by claiming privilege, “the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.”7 It is the party objecting to discovery on grounds of privilege that has the burden to establish the privilege.8
Thus, for each of the attorney-client privilege objections lodged by Defendant during the depositions at issue here, Defendant must provide the necessary information to enable Plaintiffs – and the Court – to assess the applicability of the privilege. In other words, Defendant bears the burden of providing sufficient facts to demonstrate that the referenced deposition questions require Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice.
5Fed. R. Civ. P. 26(b)(1) (“Parties may obtain discovery regarding any matter, not privileged, that is relevant to the claim or defense of any party”) (emphasis added).
6McHan v. Grandbouche, 99 F.R.D. 260, 268 (D. Kan. 1983). 7Fed. R. Civ. P. 26(b)(5). 8In re Universal Serv. Fund Tel. Billing Practices Lit., 232 F.R.D. 669, 671 (D. Kan. 2005) (citing Berroth v. Kansas Farm Bureau Mut. Ins. Co., 205 F.R.D. 586, 589 (D. Kan. 2002) (citing Motley v. Marathon Oil Co., 71 F.3d 1547, 1550 (10th Cir. 1995))).
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2. SPECIFIC DEPOSITION QUESTIONS AND OBJECTIONS

a. Deposition of David Bottoms

Q: Do you know what adverse impact is?

Defendant’s counsel objects and instructs the witness that “[i]f you can answer that question without revealing that legal advice, that is to say if you have an understanding of what adverse impact is that came to you without HR or legal, then you can answer the question.”

Q: I'm not asking you, Mr. Bottoms, so that we're clear, for anything that a lawyer said to you. I'm just asking whether or not you understand what adverse impact is.

Defendant’s counsel objects and instructs the witness that “if that information came to you through any other source other than Sprint legal or HR, because that's the only way it would come through HR is because it came from legal in the first place, then you can answer the question.”

A: I would not have any basis of understanding what adverse impact is unless it came through my legal or HR organization.

Q: Did you get an understanding of what adverse impact was through the HR organization?

Defendant’s counsel lodges the “same objection” and instructs the witness not to answer

Defendant argues the questions at issue here seek privileged information and that its counsel

justifiably instructed the witness not to answer the questions posed based on the privileged nature

of the responsive information. In support of this argument, Defendant contends that

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communications originating from the Legal Department regarding confidential

RIF-related adverse impact analyses generated for the purpose of rendering legal

advice are privileged; and

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the witness testified that he “would not have any basis of understanding what adverse

impact is unless it came through my legal or HR organization.”

The Court is not persuaded by Defendant’s argument. Even if it is true that communications

originating from the Legal Department are privileged if they consist of confidential, adverse impact

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Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 6 of 22
analyses generated for the purpose of rendering legal advice, this fact does nothing to establish that the actual adverse impact information communicated from Legal (and possibly through Human Resources) to Mr. Bottoms was (1) confidential in nature; and (2) generated for the purpose of rendering legal advice. In other words, Defendant fails to establish that the entire range of the witness’ adverse impact analyses knowledge (1) originated from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice. Information regarding adverse impact analyses gleaned by the witness that originated from the Legal Department that was not kept confidential and was not generated for the purpose of rendering legal advice does not satisfy the requirements necessary to invoke the attorney-client privilege. For example, this witness may have learned about concepts related to “adverse impact” analysis through the Human Resources organization in a general training session, through a Human Resources handbook, or a myriad of other channels that do not relate to legal advice. Defendant bears the burden to establish that all responsive information from the witness is protected from disclosure by the attorney-client privilege. It is not, as Defendant argues, the duty of Plaintiffs’ counsel to rephrase the question at issue to exclude those circumstances where the answers are privileged.
To that end, Defendant’s counsel could very well have carried its burden by conducting a comprehensive voir dire examination of the deponent with regard to the entire range of his or her knowledge with respect to adverse impact analyses. Although, with regard to the deposition questions before the Court, Defendant’s counsel appears to have conducted some form of voir dire examination of the witness, counsel failed to inquire into the privileged nature of the entire range of responsive information from the witness. In order to successfully conduct a voir dire examination of the witness on this issue, counsel should have taken the voir dire examination one step further by
6

Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 7 of 22
asking whether all information known by the witness and responsive to the deposition questions (1) originated from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice. Without this information, it is impossible to know whether or not counsel justifiably instructed the witness not to answer any portion of the questions posed based on the privileged nature of responsive information.
Based on this discussion, the Court finds that Defendant has failed to establish that the deposition questions posed to witness David Bottoms require Defendant to reveal confidential adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. Accordingly, the privilege objections lodged by Defendant are overruled to the extent that the witness must answer the questions posed if he has an understanding of the term “adverse impact” outside of any communication that (1) originated from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice. Again, Defendant, as the party lodging the objection, bears the burden to establish that the privilege exists.
b. Deposition of Deb Sprayberry Q: Did you ever share the results of any adverse impact analysis on age done in connection with
a RIF event with line management? Defendant’s counsel: “This question is impinging on the attorney/client privilege, and I'm going to instruct the witness not to answer these questions to the extent in any way, directly or indirectly, divulges any communication either to lawyers or from lawyers, including any legal advice on what to do. I think the Court's rulings have support for that; so I'm going to instruct you not to answer any questions with respect to adverse impact.”
* * * * * * * *
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Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 8 of 22
“I have talked to the witness and any information with respect to adverse impact would be information obtained from discussions with attorneys at Sprint and, therefore, it is our position that that is attorney/client privilege, and so I am instructing this witness not to answer any questions with respect to adverse impact. To the extent any impact ratio analysis questions are directed at trying to back door the adverse impact, I will be compelled to instruct the witness not to answer. So at this point, I am instructing this witness to not answer the pending question that you had with respect to adverse impact, and I will be instructing her not to answer any questions based upon the statement I just made.”
* * * * * * * Q: But you did receive data about the demographics of the work force?
Defendant’s counsel: “ I'm going to object to the form of the question. It's impinging on the attorney/client privilege, and I'm going to instruct the witness not to answer.” Defendant argues the two questions at issue here seek privileged information and that, again, its counsel justifiably instructed the witness not to answer the questions posed based on the privileged nature of the responsive information. In support of this argument, Defendant states (1) Ms. Sprayberry previously testified that she was aware of two different review processes – one that was conducted prior to legal review [which would not be privileged] and one that was conducted by the legal department [which would be privileged]; and (2) Plaintiffs’ counsel failed to phrase his question about “the results of any adverse impact analysis” so as to exclude analyses conducted at the direction of the legal department or so as to exclude directions issued by the legal department. For example, counsel could have asked if Ms. Sprayberry had received demographic information for reasons other than the preparation of adverse impact analyses at the direction of counsel. Based on the discussion set forth in the previous section, the Court finds Defendant has failed to establish that the range of all information responsive to the two deposition questions posed and known by Ms. Sprayberry (1) originated from the Legal Department; (2) was kept in confidence;
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Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 9 of 22
and (3) was generated for the purpose of rendering legal advice. In fact, the argument presented by Defendant in its brief and set forth above strongly suggests that there may be responsive information known by Ms. Sprayberry as a result of the Human Resources independent demographic review, as opposed to the review directed by the Legal Department.
In objecting to the entire question as posed, Defendant bears the burden to establish that all responsive information from the witness is protected from disclosure by the attorney-client privilege. Again, it is not, as Defendant argues, the duty of Plaintiffs’ counsel to rephrase the question at issue to exclude those circumstances where the answers are privileged. Defendant’s counsel should have conducted a voir dire examination of the deponent asking whether information known by the witness and responsive to the two deposition questions (1) originated from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice. Without this information, it is impossible to know whether or not counsel justifiably instructed the witness not to answer any portion of the questions posed based on the privileged nature of responsive information. Accordingly, the privilege objections lodged by Defendant here are overruled to the extent that Ms. Sprayberry must provide any and all responsive information to these questions that do not specifically reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice.
c. Deposition of Gene Betts Q: Did anyone ever explain to you what adverse impact was, not legal, anyone?
Defendant’s Counsel: “I can just tell you that's the only way he would know, and that clearly seeks legal advice, legal information.” Q: Listen to my question carefully. Did anyone other than someone in the legal department ever explain to you adverse impact and what it was?
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Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 10 of 22
“That still reflects legal advice, because the only way that person would know to pass that information off is through legal advice. And Judge Waxse has said the fact that there is no lawyer present, which is now the context of your hypothetical question, is not an issue.” To the extent counsel for Defendant’s responses to these deposition questions can be construed as objections, both are overruled. Defendant bears the burden of establishing that the attorney-client privilege exists. Here, that means Defendant must establish that these two deposition questions require Defendant or its agents to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. Defendant has failed, in both the deposition proceedings as well as the briefing submitted in conjunction with this motion, to voir dire Mr. Betts or provide any facts to support its conclusory assertion by counsel that these two deposition questions require Mr. Betts to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. d. Deposition of John Shannon During his deposition, Defendant’s witness John Shannon was instructed not to answer questions about (1) the data information process and whether someone would be included in the termination analysis if that person had found another position at Sprint; (2) whether or not adverse impact analysis was required under the RIF guidelines; (3) whether or not an adverse impact analysis was done for particular pools; (4) whether or not Mr. Shannon was familiar with Sprint’s policies and procedures for doing disparate impact analysis on RIFs since 1991 – even if the knowledge was independent of Sprint’s Legal Department; (5) the date that the statistics and calculations were put together for a specific adverse impact analysis; (6) the document or computer program Mr. Shannon used to run adverse impact, as well as what year Mr. Shannon first used the document or program; (7) what Mr. Shannon meant in a document he authored which referenced “if the ratio exceeds 80
10

Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 11 of 22

percent”; and (8) what tool Mr. Shannon used when he was doing an adverse impact analysis that

was admittedly on his own and did not have any involvement or direction from Sprint’s Legal

Department.

Prior to instructing Mr. Shannon not to answer these questions, counsel for Defendant lodged

various objections based on the attorney-client privilege on grounds that the questions called for

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analysis done at the direction of counsel;

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advice of counsel;

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communications from counsel;

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legal advice; and

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direction from legal counsel.

On several occasions, counsel for Defendant provided limiting instructions to Mr. Shannon,

including that Mr. Shannon should answer if the response did not include information reflecting

communications from counsel; or should not answer to the extent the response calls for legal advice

or direction from legal counsel. Defendant argues that the questions at issue here seek privileged

information and counsel justifiably instructed the witness not to answer the questions posed based

on the privileged nature of the responsive information. In support of this argument, Defendant

asserts that because communications from the Legal Department regarding confidential RIF-related

adverse impact analyses generated for the purpose of rendering legal advice are privileged and

because Mr. Shannon’s knowledge with respect to the questions asked all were learned either

directly or indirectly from the Legal Department, then Mr. Shannon’s knowledge with respect to the

questions asked are all protected from disclosure by the attorney-client privilege.

The Court finds Defendant’s reasoning is flawed. As a preliminary matter, counsel for

Defendant failed to develop any facts during the deposition (or in the pleadings) to establish that Mr.

Shannon’s knowledge with respect to the questions asked all were learned either directly or

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indirectly from the Legal Department. Moreover, even if Mr. Shannon had learned all of the responsive information he possessed from the Legal Department, this fact is not determinative of whether such knowledge is protected from disclosure by the attorney-client privilege. In order to establish privilege, Defendant must prove that responsive information possessed by Mr. Shannon (1) was kept in confidence; and (2) was generated for the purpose of rendering legal advice. Responsive information gleaned by Mr. Shannon from the Legal Department that was not kept confidential and was not generated for the purpose of rendering legal advice does not satisfy the requirements necessary to invoke the attorney-client privilege. In objecting to the entire question as posed, Defendant bears the burden to establish that all responsive information from the witness is protected from disclosure by the attorney-client privilege. Again, it is not the duty of Plaintiffs’ counsel to rephrase the question at issue to exclude those circumstances where the answers are privileged.
As discussed above, Defendant’s counsel could have carried its burden by conducting a voir dire examination of Mr. Shannon with regard to the entire range of his knowledge with respect to the questions posed. Although counsel for Defendant on several occasions provided limiting instructions directing the witness not to answer to the extent the responsive information was learned from legal counsel, the Court finds this instruction is insufficient to satisfy the requirements of Fed. R. Civ. P. 26(b)(5), which requires that
[w]hen a party withholds information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. Based on this discussion, the Court finds that Defendant has failed to establish that the
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deposition questions posed to witness John Shannon require Defendant, without exception, to reveal confidential adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. Accordingly, the privilege objections lodged by Defendant are overruled to the extent that Mr. Shannon must answer the questions posed unless Defendant can establish through voir dire examination of the witness or otherwise that responsive information possessed by Mr. Shannon (1) came from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice.
To that end, and taking into account the frequency of privilege objections lodged and subsequent disputes arising between counsel during Mr. Shannon’s deposition regarding the propriety of the privilege objections, as well as Mr. Shannon’s concessions regarding the “frolic” adverse impact review, the Court will direct the Special Master to preside over the continuation of Mr. Shannon’s deposition for the purpose of ruling on any and all adverse impact analysis privilege objections lodged. The Special Master shall rule on all such privilege objections in accordance with the legal standards set forth in this Memorandum and Order.
e. Deposition Excerpts of Fred Harris and Deb Sprayberry At the deposition of Defendant’s witness Fred Harris, Defendant’s counsel asserted the privilege on a document presented to the witness and instructed the witness not to speak to it. At the deposition of Defendant’s witness Deb Sprayberry, Defendant’s counsel instructed Ms. Sprayberry not to answer questions about handwritten notations made on documents on grounds that the notations were privileged. Although it appears from the dialogue between counsel at these depositions that there is a dispute regarding whether or not the underlying documents – or handwritten notations on the documents – may or may not be protected from disclosure by privilege,
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the parties did not present this dispute to the Court for resolution. Because the parties fail to present any discovery dispute regarding questions posed or objections lodged outside the context of the referenced documents, and because the privileged nature of the documents is not an issue currently before the Court, the Court will make no ruling with regard to questions posed or objections lodged during the depositions of Fred Harris and Deb Sprayberry.
f. Depositions of Richard Blanc, Katherine Downey, Jon Binder, Linda Gamso, Vicki Kolb, and Leon Lang
The deposition questions at issue with regard to Richard Blanc, Katherine Downey, Jon Binder, Linda Gamso, Vicki Kolb, and Leon Lang are set forth in Appendix 1 at the end of this opinion. Based on the discussion set forth in Section 2(a) regarding deposition questions posed to David Bottoms, the Court finds that Defendant has failed to establish that the deposition questions posed to witnesses Blanc, Downey, Binder, Gamso, Kolb and Lang require Defendant to reveal confidential adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. As noted above, Fed. R. Civ. P. 26(b)(5) provides that when a party objects and thereafter withholds information otherwise discoverable by claiming privilege, “the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.”9
Here, Defendant has failed to provide the necessary information to enable Plaintiffs – and the Court – to assess applicability of the privilege. In other words, Defendant has failed to provide sufficient facts to demonstrate that the referenced deposition questions require witnesses Blanc,
9Fed. R. Civ. P. 26(b)(5). 14

Case 2:03-cv-02200-JWL-DJW Document 4559 Filed 02/07/2007 Page 15 of 22
Downey, Binder, Gamso, Kolb or Lang to reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. Accordingly, the privilege objections lodged by Defendant to the Blanc, Downey, Binder, Gamso, Kolb and Lang deposition questions presented are overruled to the extent that these witnesses must answer the questions posed unless Defendant can demonstrate – through voir dire examination of the witness or otherwise – that the responsive information (1) originated from the Legal Department; (2) was kept in confidence; and (3) was generated for the purpose of rendering legal advice. 3. EXISTING AND FUTURE DISCOVERY DISPUTES REGARDING THE
PRIVILEGED NATURE OF ADVERSE IMPACT ANALYSES DEPOSITION QUESTIONS In addition to requesting that the eleven witnesses reappear for deposition and respond to specific questions to which Defendant’s counsel previously objected, Plaintiffs advise they may seek Court intervention to resolve additional disputes regarding the privileged nature of adverse impact analyses deposition questions. Given the precise legal standard necessary to resolve these deposition disputes has been set forth by the Court in this Memorandum and Order, the Court finds it appropriate to refer all existing and future discovery disputes on this issue to the Special Master for resolution. Thus, Plaintiff’s Sealed Motion for Relief (doc. 4535) and any other motion filed after October 13, 2006 seeking relief related to deposition questions and/or privilege objections dealing with the topic of adverse impact analyses shall be referred to the Special Master for decision. 4. SUMMARY OF RULING Based on the discussion above, Plaintiffs’ Motion to Compel is granted in part and denied in part as follows: (1) That portion of the Motion that seeks to compel Defendant to respond to any
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prospective question “inquiring into Defendant’s RIF-related adverse impact analyses (other than privileged legal advice the witness received)” is denied on grounds that it requires this Court to speculate as to what questions might be appropriate in the context of a deposition; (2) That portion of the Motion that seeks to compel eleven of Defendants’ witnesses to reappear for deposition and respond to specific questions to which Defendant’s counsel previously directed such witnesses not to answer on grounds of privilege is granted and (a) the privilege objections previously lodged by Defendant in these eleven
depositions are overruled to the extent that the witnesses must provide any and all responsive information that does not reveal confidential RIF-related adverse impact analyses generated at the direction of counsel for the purpose of rendering legal advice. (b) Defendant, as the objecting party, shall bear the burden to establish – through voir dire examination of the witness or otherwise – that responsive information possessed by the witnesses (i) originated from the Legal Department; (ii) was kept in confidence; and (iii) was generated for the purpose of rendering legal advice; It is further ordered that the Special Master shall preside over the continuation of Mr. Shannon’s deposition for the purpose of ruling on objections lodged that deal with the privileged nature of testimony regarding adverse impact analyses. The Special Master shall rule on all such privilege objections in accordance with the legal standards set forth in this Memorandum and Order. It is further ordered that the August 30, 2006 Amended Order Appointing Special Master (doc. 4298) shall be further amended to authorize referral to the Special Master all existing and potential discovery disputes that have arisen or may arise during depositions regarding applicability of privilege to testimony regarding adverse impact analyses. Thus, Plaintiff’s Sealed Motion for Relief (doc. 4535) and any other motion filed after October 13, 2007 seeking relief related to
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deposition questions and/or privilege objections dealing with whether adverse impact analyses testimony is protected from disclosure by privilege shall be referred to the Special Master for decision. The Special Master shall rule on all such privilege objections in accordance with the legal standards set forth in this Memorandum and Order.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 7th day of February, 2007.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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APPENDIX 1 Deposition Excerpts of Richard Blanc Q: Do you remember the term adverse impact being used in the context of RIF selection
guidelines? A: I have heard the term. Q: What is your understanding of what the term means, if you have one? Defendant’s counsel: “His only understanding would come through advice of counsel which could come through HR, and so I object and instruct the witness not to answer on the basis of privilege.” Q: Absent anything you have heard from attorneys, do you know what adverse impact means? Defendant’s counsel: “Can you [Mr. Blanc] answer whether or not you have an understanding of what adverse impact is without basing that answer on discussions with either HR or legal?” A: No, I can't.
* * * * * * * * Q: Did you know in the fall of 2001 that the selections of employees to be reduced had an
adverse impact on people over 40 in your department? Defendant’s counsel: “That question, because – the only way he would have that information, once again, would call for the communication of legal advice, and so I object on the basis of privilege and instruct the witness not to answer.” Deposition Excerpts of Katherine Downey Q: When did you learn the 80 percent rule? Was that at Xerox? A: Yes, it would have been at Xerox. Q: And is Exhibit 1892, is that the 80 percent rule being applied that you learned at Xerox? Defendant’s counsel: “I’m going to object to the form of the question, again, and I instruct not to answer.”
* * * * * * * * *
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Q: All right, so does the 80 percent rule as it’s allowed out in Exhibit 1892 differ any way from that in terms of the math and the way it’s calculated from the way you learned it at Xerox prior to ever coming to work for Sprint?
Defendant’s counsel: “Object to the question. Instruct not to answer; grounds, attorney-client privilege.”
Q: And was what you were doing at Xerox, simply applying the published EEOC guideline?
Defendant’s counsel: “Object to the form of the question. It again puts her in the position of very possibly waiving her former employer’s privilege and I object and I’ll instruct her not to answer to the extent that it involves any discussions with Xerox counsel.”
Q: Let’s go at it this way because I really don’t want to trample on what he’s saying. If you are doing it differently at Xerox for any reason, whether it’s counsel or otherwise, I don’t want to know about it and I’ll stop asking you questions, but if what you did at Xerox was simply follow the EEOC guideline in the public domain, that’s what I’m asking you about. Was the rule you were applying word for word, letter for letter, the application of the EEOC public domain guideline when you were at Xerox?
Defendant’s counsel: “I will allow you to answer that question only if it was done totally independent of Xerox’s counsel and any advice that they may have had or direction.”
A: We had an organization. It was called the Affirmative Action Department. They did all the calculations. They did it via spreadsheets. They followed the EEOC guidelines and I didn’t have to be concerned about it because it was done for me.
Deposition Excerpts of Jon Binder
Q: And the last hash mark, "Discuss individual employee circumstances resulting from legal review with execs." Do you know what that was about.
Defendant’s counsel: “I'm going to object on the basis of attorney-client privilege. I think that question may possibly call for him to disclose any understanding he has. That bullet point clearly deals with legal review. And instruct the witness not to answer unless you have some understanding, outside of information that came directly or indirectly to you from the legal department. objects and instructs the witness not to answer.”
* * * * * * * * * * *
Q: All right. And when you get an e-mail from John St. Angelo, and it says, among other action
19

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items, is to discuss individual employee circumstances resulting from legal review, did you have any understanding -- I'm just asking as a "yes" or "no," did you have any understanding as to what he meant by that legal review?
Defendant’s counsel: “And that’s where I’ll interject that same objection. You can answer that if you have an understanding, other – coming from some other source as to what your understanding was.”
* * * * * * * * * * *
Q: What is disparate impact?
Defendant’s counsel: “Object to the extent that any – if your only knowledge of that has come from -- directly or indirectly from Sprint's legal department. If you have an understanding, outside of that, you can testify to it.”
* * * * * * * * * * *
Q: Do you know whether there is a mathematical formula involved in [the sore thumb] process? Defendant’s counsel: “I'm going to object to the extent that it calls for him to reveal information protected by the attorney-client privilege. Instruct him not to answer if that knowledge would have come directly or indirectly from his work at Sprint or Sprint's legal department.”
* * * * * * * * * * *
Q: Part of that review would be reviewing in advance for disparate impact analysis, correct?
Defendant’s counsel: “I'm going to object. Instruct him not to answer any more questions about disparate impact analysis.”
Q: Was there an adverse impact study done on annual evaluations?
Defendant’s counsel: “Object on the basis of attorney-client privilege, and instruct you not to answer.”
Deposition Excerpts of Linda Gamso
Q: Let me ask you this. Do you recall ever receiving any specific training offered by Sprint or anyone else with respect to discrimination or disparate impact during the period of time 2000 through 2002?
Defendant’s counsel: “I'm going to object to that question to the extent it would invade the attorney-client privilege with respect to any communication or training
20

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communicated by or from the Law Department or any attorneys representing Sprint. If you can answer that question without, you know, separate from any discussion that you had with the lawyers you may answer the question. If you cannot do so then I'm going to instruct the witness not to answer on the basis of the attorney-client privilege.”
A: Training is a broad term. We had guidance in our discussions from HR, our Human Resources organization, about discrimination.
Q: All right, do you know what disparate impact means?
Defendant’s counsel: “Same objection.”
A: No.
Q: Do you recall receiving any sort of training, whether it be verbal training or materials given to you that describe what the term disparate impact means?
Defendant’s counsel: “Same objection. I'll instruct the witness not to answer the question to the extent that it would invade the attorney-client privilege based upon any communications from or through counsel. If you can answer the question without disclosing that conversation, you may do so.”
A: No.
Deposition Excerpts of Vicki Kolb
Q: Did you ever do a due diligence review of the 10 percent population, the bottom 10 percent list?
Defendant’s counsel: “If you could answer that question without revealing legal advice, go ahead.”
A: And I cannot.
Q: I'm not asking you for legal advice, I'm just asking whether you ever did a due diligence review of the bottom 10 percent list?
Defendant’s counsel: “And that's the same instruction.”
A: No.
Q: Did you ever participate in a due diligence review for the bottom 10 percent?
21

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A: Participation with legal. Q: Did legal do a due diligence review of the bottom 10 percent?
Defendant’s counsel: “The only way she would know that is if there was communication from legal so you're instructed not to answer that question.” A: No comment.
* * ** * * * * * Q: Did you ever see the results of any impact analysis with regard to any RIF event that
occurred in Michael Seitz's business unit? Defendant’s counsel: “Hang on, that question necessarily calls for communications from Legal so I'm instructing you not to answer the question.” Q: Do you know how to do an impact ratio analysis? Defendant’s counsel: “Again the only way she would know that is if it came from Legal. I'm instructing the witness not to answer.”
* * * * * * * * * Q: Did you communicate any adverse impact information to Loren Sprouse or his organization?
Defendant’s counsel: “Object if you're just talking generally but if you're talking about from this document.” Instruct the witness not to answer. Deposition Excerpts of Leon Lang Q: Well, what did you understand adverse impact was to be used for? Defendant’s counsel: “Well, I object. Don't answer the question. That would be privileged.”
22

 
 Case 2:03-cv-02200-JWL-DJW Document 4572 Filed 02/27/2007 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,

CIVIL ACTION No. 03-2200-JWL-DJW

Defendant.

MEMORANDUM AND ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant's decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Plaintiffs’ Motion to Compel Defendant to Produce Documents with Original Bates Numbers (doc. 4246). Plaintiffs request that Defendant reproduce the following documents with their original bates numbers: (1) documents bearing the new bates numbers 201807 through 202605, and (2) documents that Defendant included on its privilege log but later determined had been previously produced in the litigation. Defendant opposes the motion, arguing that the mental impressions of its in-house counsel will be revealed if it is required to produce these documents with their original bates numbers. For the reasons set forth below, the motion is granted.

Case 2:03-cv-02200-JWL-DJW Document 4572 Filed 02/27/2007 Page 2 of 11
I. History of the Discovery Dispute On January 23, 2006, Defendant served Plaintiffs with a privilege log with respect to the
August 12, 2005 production ordered by District Judge Lungstrum. Listed on Defendant’s privilege log were documents contained in the files of Defendant’s in-house counsel marked as “Work Product - from legal department files.” Defendant identified these documents on its privilege log by the beginning and ending bates numbers of the legal files.
After receiving Defendant’s privilege log, Plaintiffs challenged Defendant’s inclusion of the legal file documents on the log, primarily because the privilege log entries for these files were left blank. When Plaintiffs requested more information, Defendant’s counsel conceded that some of the individual documents contained in the legal file may not be privileged and offered to determine which legal file documents had already been produced to Plaintiffs from other sources, such as from a Human Resources file or a manager’s file. They also offered to produce any legal file documents that had not already been produced from another source, though without identifying the in-house attorney from whose file the document originated.
On February 27, 2006, Defendant provided Plaintiffs with a supplemental privilege log specific to the legal file documents. This supplemental privilege log included more information for the legal file documents listed.
On April 27, 2006, Defendant produced to Plaintiffs a disk of the legal file documents that had not already been produced from other sources. Prior to producing these documents, Defendant re-issued bates numbers, different from those numbers by which the documents were identified on the privilege log. The documents were re-numbered as bates numbers 201807 through 202605.
On May 30, 2006, Defendant faxed Plaintiffs an eleven-page list of bates number ranges
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reflecting documents appearing on its second supplemental August 12, 2005 privilege log which had been produced in the litigation from other sources. Defendant’s fax stated “[w]e are maintaining these documents on the privileged log because they were located in lawyers’ files inside of [Defendant’s] legal department.”1
Plaintiffs raised the issue of Defendant’s April 27 production of the non-privileged documents listed on the privilege log with their new bates numbers at the June 1, 2006 discovery conference. They requested that the Court order Defendant to produce the documents with their original bates numbers. The Magistrate Judge advised Defendant that it needed to include the original bates numbers when it produces documents once claimed as privileged, stating as follows:
It makes sense if you’re talking about producing things that were on a privilege log but shouldn’t have been, they have to have the same number that was on the privilege log. Because it doesn’t make sense to send a group of documents that you can’t figure out how it relates to the privilege log. So if that hasn’t been done, it needs to be done. And why don’t we say get it done by the next status conference. And it may be something that’s already done.2 Defendant responded that it was concerned that Plaintiffs were trying to find out what documents were located in the attorney legal files. It argued that identification of the documents contained in an attorney’s file constitutes the mental impressions of the attorney. Plaintiffs also requested that the Court order Defendant to produce all the documents it identified by bates number ranges on its May 30 eleven-page correspondence with their original bates numbers. This listing identified documents that Defendant had included on its privilege log but later determined had been previously produced in the litigation. Plaintiffs reported that
1Pls. Mot. to Compel (doc. 4246), Ex. 10. 2June 1, 2006 Discovery Conference Transcript (“Tr.”), p. 47-48.
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Defendant’s list failed to provide any bates number of any documents that correlated back to the privilege log.
After further discussion, the Magistrate Judge deferred the matter until Defendant could provide more explanation. The parties discussed the issue again at their June 22, 2006 meet and confer session, which ended with Defendant refusing to produce the documents with their original bates numbers or provide any corresponding index identifying the bates numbers where the specific documents were previously produced. Plaintiffs thereafter filed the present Motion to Compel. II. Law Regarding Work Product Protection for Attorney’s Mental Impressions
The work product doctrine, as set forth in Federal Rule of Civil Procedure 26(b)(3), protects against disclosure of the “mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the litigation.”3 As the Supreme Court stated in its oftcited Hickman v. Taylor opinion, the work product doctrine recognizes that:
It is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel. Proper preparation of a client’s case demands that [the lawyer] assemble information, sift what he considers to be the relevant from the irrelevant facts, prepare his legal theories and plan his strategy without undue and needless interference. That is the historical and the necessary way in which lawyers act within the framework of our system of jurisprudence to promote justice and to protect their clients’ interests. This work is reflected, of course, in interviews, statements, memoranda, correspondence, briefs, mental impressions, personal beliefs, and countless other tangible and intangible ways . . . .4
The work product doctrine, however, “is intended only to guard against divulging the attorney's strategies and legal impressions, it does not protect facts concerning the creation of work product
3Fed. R. Civ. P. 26(b)(3). 4Hickman v. Taylor, 329 U.S. 495, 510-11 (1947).
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or facts contained within work product.”5 Courts have generally recognized a difference between discovery of documents prepared in
anticipation of litigation setting forth factual information and discovery of documents prepared in anticipation of litigation setting forth the mental impressions, conclusions, opinions, or legal theories of an attorney.6 Documents containing factual information prepared in anticipation of litigation are generally referred to by the courts as “fact work product” and documents containing the mental impressions of an attorney are generally referred to as “opinion work product.”7
Disclosure of fact work product may only be obtained by a third party who satisfies the “substantial need/undue burden test” by demonstrating a substantial need for the material and an inability to develop the information otherwise without undue hardship.8 In contrast, there is no universally accepted standard regarding the level of protection accorded to opinion work product. The Supreme Court has indicated, however, that opinion work product is normally afforded a greater protection than other kinds of work product.9
The party asserting a work product privilege as a bar to discovery must prove the doctrine
5Resolution Trust Corp. v. Dabney, 73 F.3d 262, 266 (10th Cir. 1995). 6Frontier Refining, Inc. v. Gorman-Rupp Co., 136 F.3d 695, 704 n. 12 (10th Cir.1998). 7Simmons Foods, Inc. v. Willis, 196 F.R.D. 610, 612 (D. Kan. 2000). 8Id. 9Hickman, 329 U.S. at 511; Upjohn Co. v. United States, 449 U.S. 383, 401 (1981) (work product revealing an attorney’s mental processes cannot be disclosed simply on a showing of substantial need and inability to obtain the equivalent without undue hardship).
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is applicable.10 A mere allegation that the work product doctrine applies is insufficient.11 The party asserting the privilege must establish all elements of the asserted immunity/privilege.12 III. Discussion and Analysis
Defendant justifies its production of documents with bates numbers different from those on its privilege log on the grounds that production of the documents with their original bates numbers will reveal the mental impressions of its counsel, which are protected opinion work product. It argues that production with different bates numbers is necessary to protect the identities, and thus the mental impressions, of the in-house attorneys who selected the documents for inclusion in their work files. These documents were identified, selected, and compiled by Defendant’s in-house attorneys in anticipation of litigation both during the reductions in force and during the course of this litigation. Defendant claims that the documents reveal who these attorneys have gone to for information, and what issues they believe are important in this litigation. Permitting Plaintiffs’ counsel to make the link between the legal file documents listed on the privilege log and the particular in-house attorneys who identified, selected, and compiled those documents will necessarily reveal the mental impressions of these attorneys.
Plaintiffs argue that Defendant has made no factual showing in support of its contentions, much less a showing sufficient to sustain its burden on this issue. They further argue that Defendant’s explanation does not factually hold water given that the privilege log provided does not identify the specific in-house attorneys. According to Plaintiffs, under Defendant’s newly-contrived
10Resolution Trust Corp., 73 F.3d at 266. 11Id. 12Johnson v. Gmeinder, 191 F.R.D. 638, 643 (D. Kan. 2000).
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logic and argument, Defendant’s privilege log itself should be deemed privileged because it provides much information on what specific in-house attorneys were working on what matters and when.
Plaintiffs further claim that Defendant is now using its own self-created problem of logging these documents on the privilege log instead of producing them as an excuse to avoid its discovery obligations. They argue that Defendant did not meet its discovery obligations to originally produce these documents. Instead, it improperly withheld them from discovery, listing them as privileged and only ultimately admitting they were not privileged after challenged by Plaintiffs’ counsel.
As the Court previously stated at the June 1, 2006 discovery conference when this issue was first raised, if Defendant is producing documents that were incorrectly included on a privilege log, then it has to produce them with the same bates numbers it used on the privilege log. Defendant’s own actions in logging these non-privileged documents on the privilege log created this problem in the first instance. It should not now be able to avoid producing these documents with their original bates numbers because of its action of including them on the privilege log as part of in-house counsel’s legal files. Defendant’s production of these non-privileged documents with new bates numbers prevents Plaintiffs from being able to determine what documents, previously included on Defendant’s privilege log, are now being produced.
Defendant has not convinced the Court that production of the non-privileged documents with their original bates numbers would reveal the mental impressions of its in-house counsel. Defendant cites three cases from other jurisdictions in support of its contention that an attorney’s selection of unprivileged documents is protected work product.13 The cases cited by Defendant however are
13Shelton v. American Motors Corp., 805 F.2d 1323, 1326 (8th Cir. 1986); James Julian, Inc. v. Raytheon Co., 93 F.R.D. 138, 144 (D. Del. 1982); Sporck v. Peil, 759 F.2d 312, 315-316 (3d Cir. 1985).
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inconsistent with the District of Kansas cases holding that mere selection and grouping of information does not transform discoverable documents into work product.14
In Bohannon v. Honda Motor Co. Ltd., the plaintiff made a similar claim that counsel’s selection of documents constituted opinion work product.15 Magistrate Judge Rushfelt, noting that
neither plaintiff nor his attorney generated, grouped, or synthesized the documents, found that disclosure of the documents would not disclose the mental processes of counsel.16 The Bohannon opinion compared the Third Circuit’s holding in Sporck v Beil17 with the First Circuit’s later contrary holding in In re San Juan Dupont Plaza Hotel Fire Litigation.18 In concluding that the First
Circuit’s decision in San Juan was the sounder rule, the Court agreed that Sporck was “flawed
because it assumes that the revelatory nature of the sought-after information is, in itself, sufficient
14Raytheon Aircraft Co. v. U.S. Army Corps of Eng’rs, 183 F. Supp. 2d 1280, 1291 (D. Kan. 2001) (requiring defendant to disclose the list of public documents consulted in the compilation of two protected reports did not permit an unfair “peek” into defendant’s legal mind); Bohannon v. Honda Motor Co. Ltd., 127 F.R.D. 536, 539-40) (D. Kan. 1989) (rejecting argument that counsel’s gathering and selection of third-party documents constitutes opinion work product); Audiotext Commc’ns Network, Inc. v. U.S. Telecom, Inc., 164 F.R.D. 250, 252-53 (D. Kan. 1996) (collecting and organizing discoverable documents in a notebook did not make the notebook protected work product.”); American Cas. Co. of Reading, Pa. v. Healthcare Indem., Inc., No. CIV.A. 00-2301-DJW, 2001 WL 1718275, at *3 (D. Kan. May 21, 2001) (rejecting defendant’s claim that selection and grouping of the documents within the claims file accords the entire claims file work product protection); but, see, Aguinaga v. John Morrell & Co., 112 F.R.D. 671, 683 (D. Kan. 1986) (holding selection and compilation of documents used to refresh witness's memory were protected by work product doctrine pursuant to Fed. R. Evid. 612).
15127 F.R.D. 536, 539 (D. Kan. 1989). 16Id. 17759 F.2d 312, 319 (3d Cir.1985). 18859 F.2d 1007, 1018 (1st Cir. 1988).
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to cloak the information with the heightened protection of opinion work product.19 That is simply not the case; much depends on whether the fruits of the screening would soon be revealed in any event . . .”20
In Audiotext Communications Network, Inc. v. U.S. Telecom, Inc.,21 the plaintiff sought to compel the defendant to produce a bound notebook of documents reviewed and relied upon by a witness before the third session of his deposition.22 The court, noting that the defendant had previously produced all the documents contained in the notebook, found that the defendant had not supported its claim of work product under Fed. R. Civ. P. 26(b)(3), i.e., the material must be documents and tangible things, prepared in anticipation of litigation or for trial, and prepared by or for another party or for that other party’s representative.23 It held that collecting and organizing discoverable documents in a notebook did not make the notebook protected work product.24
In Raytheon Aircraft Co. v. U.S. Army Corps of Engineers,25 the court noted that there are conflicting authorities on whether the selection and compilation of documents warrants work product protection.26 Upon analyzing the two privileged reports at issue, the Raytheon court
19Bohannon, 127 F.R.D. at 539. 20Id. at 539 (citing In re San Juan Dupont Plaza Hotel Fire Litig., 859 F.2d 1007, 1018 (1st Cir. 1988). 21164 F.R.D. 250 (D. Kan. 1996). 22Id. at 252-53. 23Id. at 253. 24Id. 25183 F. Supp. 2d 1280 (D. Kan. 2001). 26Id. at 1290-91.
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concluded that the dissemination of a list of public documents that the reports were based upon would not reveal anything the work product doctrine sought keep sacrosanct and did not permit an unfair “peek” into the defendant’s legal mind.27 It further held that disclosing the documents underlying the two reports would not compromise counsel’s protected mental impressions.28
These decisions reiterate the general rule in this district that the mere selecting and grouping of information does not transform discoverable documents into work product. Defendant has not persuaded the Court to depart from this general rule. Defendant has not established that the mental impressions of its in-house counsel will be revealed if it is required to produce non-privileged documents with their original bates numbers. The parties agree that the documents previously listed on Defendant’s privilege log are not privileged or protected from disclosure as work product. Even assuming that Plaintiffs may be able to extrapolate backwards from the original bates numbers to Defendant’s privilege log and ascertain which particular attorney file contained the document, this does not create work product protection to preclude the production of the non-privileged documents with their original bates numbers.
IT IS THEREFORE ORDERED that Plaintiffs’ Motion to Compel Defendant to Produce Documents with Original Bates Numbers (doc. 4246) is granted. Within 10 days of the date of this Memorandum and Order, Defendant shall re-produce the following documents with their original bates numbers: (1) documents bearing the new bates numbers of 201807 through 202605, and (2) documents identified by Defendant on its May 30, 2006 eleven-page listing of bates numbers ranges appearing on the privilege log but produced in the litigation from other sources.
27Id. at 1291. 28Id.
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IT IS FURTHER ORDERED that although the Court overrules Defendant’s work product objection, the Court finds the objection to be substantially justified under Fed. R. Civ. P. 37(a)(4)(A) so that the parties shall bear their own costs incurred with making the motion.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 27th day of February, 2007.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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 Case 2:03-cv-02200-JWL-DJW Document 4573 Filed 02/27/2007 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,

CIVIL ACTION No. 03-2200-JWL-DJW

Defendant.

MEMORANDUM AND ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant's decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Plaintiffs’ Motion to Compel Defendant to Produce Document #1000194[-]203 Without Redactions (doc. 4251). For the reasons set forth below, the motion is granted. I. History of the Discovery Dispute Listed on Defendant’s “Privilege Log for 8/12/2005 Production” is a document identified with the bates number SPR-W1000194 through SPR-W1000203 and described as: “Spreadsheet illustrating the demographics of the Network Services dept. with attached graphs and charts.” The privilege log entry for this document indicates that it was withheld on the basis of attorney-client privilege as an adverse impact document. The document consists of ten pages of tables, charts, and graphs analyzing the following Network Services employee demographics as of January 2003:

Case 2:03-cv-02200-JWL-DJW Document 4573 Filed 02/27/2007 Page 2 of 6
education level, gender, ethnicity, service years, time on job, and age. On March 30, 2006, Plaintiffs requested that Defendant produce the document as the
demographic characteristics of the Network Services department was not privileged information. Plaintiffs faxed Defendant on three more occasions requesting that Defendant produce the document.
At the meet and confer on May 25, 2006, Defendant acknowledged that the document should not be on its privilege log. It asserted, however, that the document was “non-responsive” to any discovery request. Defendant ultimately agreed to produce one page of the document.
Defendant thereafter produced the entire ten pages of the document but redacted all of the document except those sections pertaining to age demographics. The sections of the document analyzing the employee demographic characteristics of education level, gender, ethnicity, service years, and time on job were all redacted. Plaintiffs request in their Motion to Compel that Defendant produce the document with no redactions. II. Defendant’s Objections to Producing the Unredacted Document
Defendant argues that Plaintiffs’ motion should be denied for at least two reasons. First, Plaintiffs are not entitled to document bates numbered SPR-W1000194 through SPR-W1000203 because they never requested the document. Their motion to compel further fails to identify any discovery request to which the document is responsive. Defendant claims that Plaintiffs are only aware of the existence of the document because it was mistakenly listed on a privilege log. Defendant states it produced the document as a good faith effort to meet Plaintiffs’ demands.
Defendant’s second argument is that Plaintiffs are not entitled to the redacted sections of the document because these sections relate to demographic characteristics other than age. Thus, according to Defendant, even if Plaintiffs were entitled to the document, they would at most be
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entitled to what they already have because plaintiffs in an age discrimination case are not entitled to discover information regarding other protected characteristics.
A. Whether the Document Has Been Requested Defendant argues that Plaintiffs cannot move to compel the production of the document for the simple reason that they have never identified any document request to which the document is responsive. In their reply memorandum, Plaintiffs claim that such materials have not only been requested but are also within those materials ordered produced by the Magistrate Judge in June of 2005 and District Judge Lungstrum in August of 2005. Although Defendant argues that Plaintiffs fail to identify the specific document request to which this document is responsive, Defendant does not dispute that it included this document on its “Privilege Log for 8/12/2005 Production.” From the title of the privilege log, the Court infers that this privilege log was created for the group of documents Defendant believed was responsive to Judge Lungstrum’s August 12, 2005 Memorandum and Order. Even if Defendant mistakenly included the document on its “Privilege Log for 8/12/2005 Production” and the document is not responsive to Judge Lungstrum’s August 12, 2005 Memorandum and Order, the Court finds that Defendant subsequently agreed to produce to the document. Defendant’s objection that the redacted document has never been requested is overruled. B. Whether Plaintiffs are Entitled to Non-Age Information Defendant next argues that even if Plaintiffs requested the document, at most they would be entitled to its age-related sections because plaintiffs in an age discrimination case are not entitled to discover information regarding other protected characteristics. Defendant claims that the redacted sections of the document mostly consist of irrelevant demographic information relating to race,
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ethnicity, and gender. Defendant maintains that its redactions were appropriate to prevent Plaintiffs from discovering information to which they have could have no right. It argues that Plaintiffs have offered no authority to satisfy their burden of demonstrating the relevance of the redacted information.
Contrary to Defendant’s contention that Plaintiffs have the burden of demonstrating the relevance of the redacted sections of the document, the Court finds that Defendant, as the party redacting sections of an otherwise discoverable document on the basis of irrelevancy, has the burden to show why these redactions were proper.1 Defendant has the burden to assert these relevancy objections to an otherwise discoverable document before or at the time the redacted document is produced. If a party produces a document pursuant to a court order or by agreement, that party has the obligation to produce the document “as is” without redactions. If, however, the party producing the document asserts that sections of the document should be redacted, then that party shall either make an objection prior to producing it redacted, move for a protective order, or obtain the agreement of the party seeking the document for the redactions. Failure to do so may result in waiver of the right to redact sections of the document.
Defendant makes the broad assertion that plaintiffs in an age discrimination case are not
1See Smith v. MCI Telecomms. Corp., 137 F.R.D. 25, 27 (D. Kan. 1991) (placing burden of substantiating its claims that the redacted materials were irrelevant on party redacting the documents); Mackey v. IBP, Inc., 167 F.R.D. 186, 204 (D. Kan. 1996) (ordering that defendant to produce the reports without redaction based on finding that defendant had not shown good reason for redaction or good cause for characterizing information as confidential or private or for limiting its use to the lawsuit); Kansas Food Packers v. Corpak, No. 99-1418-JTM, 2000 WL 33170870, at *1-2 (D. Kan. Oct. 12, 2000) (finding redacted information relevant and requiring its production); Youell v. Grimes, 202 F.R.D. 643, 655 (D. Kan. 2001) (overruled on other grounds) (requiring redacting party to explain why each reaction was made along with legal authority for making each redaction).
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entitled to discover information regarding other protected characteristics. It argues that the redacted document sought by Plaintiffs primarily consists of irrelevant demographic information relating to race, ethnicity, and gender, characteristics which are all unrelated to Plaintiffs’ age discrimination claims.
Federal Rule of Civil Procedure 26(b)(1) provides that “[p]arties may obtain discovery regarding any matter, not privileged, that is relevant to the claim or defense of any party . . . . Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.”2 Relevancy is broadly construed, and a request for discovery should be considered relevant if there is “any possibility” that the information sought may be relevant to the claim or defense of any party.3 Consequently, a request for discovery should be allowed “unless it is clear that the information sought can have no possible bearing” on the claim or defense of a party.4
The Court agrees with Defendant that if Plaintiffs, asserting an age discrimination claim, had requested information on demographic information relating to race, ethnicity, and gender, Plaintiffs would have the burden to show that the request sought relevant information. However, because Defendant has already produced the document and it contains some relevant information, Defendant, as the party withholding information, has the burden to justify any redactions of the otherwise discoverable document. Because Defendant failed to make an objection prior to producing the
2Fed. R. Civ. P. 26(b)(1). 3Cardenas v. Dorel Juvenile Group, Inc., 232 F.R.D. 377, 382 (D. Kan. 2005) (citing Owens v. Sprint/United Mgmt. Co., 221 F.R.D. 649, 652 (D. Kan. 2004); Sheldon v. Vermonty, 204 F.R.D. 679, 689-90 (D. Kan. 2001)). 4Id.
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document redacted, move for a protective order, or obtain the agreement of Plaintiffs for the redactions, the Court finds that Defendant has waived any right to assert relevancy objections regarding the non-age information it redacted. Defendant’s relevancy objection that Plaintiffs are not entitled to the non-age information on the document is therefore overruled.
IT IS THEREFORE ORDERED that Plaintiffs’ Motion to Compel Defendant to Produce Documents #1000194[-]203 Without Redactions (doc. 4251) is granted. Within 10 days of the date of this Memorandum and Order, Defendant shall produce document with bates number SPRW1000194 through SPR-W1000203 without redaction.
IT IS FURTHER ORDERED that Plaintiffs’ request for a hearing on this matter is denied. IT IS FURTHER ORDERED that although the Court overrules Defendant’s work product objection, the Court finds the objection to be substantially justified under Fed. R. Civ. P. 37(a)(4)(A) so that the parties shall bear their own costs incurred with making the motion. IT IS SO ORDERED. Dated in Kansas City, Kansas on this 27th day of February, 2007.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

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 Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 1 of 76

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS
SHIRLEY WILLIAMS, et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL-DJW

SPRINT/UNITED MANAGEMENT CO., Defendant.

MEMORANDUM AND ORDER Pending before the Court is Plaintiffs’ Second Motion to Declare Invalid Defendant Sprint’s

Assertions of Privilege where Legal Counsel Was Not Involved (doc. 3595). For the reasons stated below, Plaintiffs’ Motion will be granted in part and denied in part.

I. Relevant Procedural Background On or about August 25, 2005, Defendant provided to Plaintiffs an updated privilege log. At

the September 1, 2005 status conference, Plaintiffs submitted to the Court a document entitled “List

of Documents Withheld by Defendant Despite No Involvement of Legal Department or Counsel” (the “List”). The List identifies 426 documents in Defendant’s August 25, 2005 privilege log that were withheld from production “despite the fact that the log itself shows there to have been no involvement of Sprint legal department or counsel.” For these reasons, Plaintiffs requested that Defendant’s assertion of any privilege be overruled with regard to these documents.

The Court ultimately construed Plaintiffs’ “List” as a Motion to Compel (doc. 3203) and

ordered Defendant to submit a pleading explaining “the basis upon which it is claiming

attorney-client privilege for those documents identified in any privilege log where no attorney is listed.” Defendant submitted the pleading as directed and, in conjunction with this pleading,

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submitted a paper copy of the August 25, 2005 privilege log to the Court.

After the Motion to Compel was fully briefed, the Court requested Defendant submit a copy

of Defendant’s August 25, 2005 privilege log in electronic format.1 On January 25, 2006, a legal

assistant for the law firm representing Defendant sent two privilege logs to the Court’s law clerk as

attachments to an e-mail.2 The first attachment was designated by Defendant as the “8/12/05

Privilege Log” and consisted of a 133-page privilege log entitled “Williams vs. Sprint Privilege Log

for 8/12/2005 Production.” The second attachment was designated by Defendant as the “KC

Privilege log” and consisted of a 288-page privilege log entitled “Sprint/Williams Collective Action

Amended and Supplemental Privilege Log.” Notably, the electronic privilege logs included many

entries not included in the August 25, 2005 paper privilege log previously submitted.

On February 1, 2006, the Court issued a Memorandum and Order (doc. 3549) finding that

C

Defendant successfully met its burden to establish attorney-client privilege

protection for a portion of the 426 entries in the August 25, 2005 privilege

log and included on the List; but

C

Defendant failed to establish the elements required to invoke the

attorney-client privilege for the balance of the 426 entries in the August 25,

2005 privilege log and included on the List.

On February 16, 2006, approximately two weeks after the Court issued its Memorandum and

Order, Plaintiffs filed a “Second Motion to Declare Invalid Defendant Sprint’s Assertions of

Privilege where Legal Counsel Was Not Involved.” This second motion is purportedly based on new

entries included within the “8/12/2005 Privilege Log”and “KC Privilege Log” that were not included

in the privilege log dated August 25, 2005. Specifically, Plaintiffs seek the following relief in

1Transcript of January 19, 2006 Status conference (doc. 3546-2 at p. 86). 2See Appendix 1 for a copy of this e-mail.
2

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conjunction with this Motion3:

C

Declare no privilege exists and compel Defendant to produce the 661 documents

listed by bates number in Exhibits 1 and 2 to Plaintiffs’ Motion; and

C

Compel Defendant to produce 165 documents that Defendant acknowledges are not

privileged but instead claims are not responsive to any request.

Defendant opposes this motion on substantive grounds as well as for Plaintiffs’ alleged

failure to confer before filing the Motion. The Court will address the duty to confer before addressing

the parties’ substantive arguments.

II. Duty to Confer As a preliminary matter, Defendant asks the Court to deny Plaintiffs’ Motion to Compel

based on Plaintiffs’ alleged noncompliance with their duty to confer. Defendant claims that Plaintiffs’ efforts to resolve this dispute fail to meet the requirements of federal and local rule, as well as specific directives from the Court.
Federal Rule of Civil Procedure 37 requires the movant to make a good faith attempt to resolve the discovery dispute before filing a motion to compel discovery responses. The motion to compel must include a certification of the effort to resolve the dispute.4 In conjunction with Fed. R. Civ. P. 37, District of Kansas Rule 37.2 provides:
The court will not entertain any motion to resolve a discovery dispute pursuant to Fed.R.Civ.P. 26 through 37 . . . unless counsel for the moving party has conferred or made reasonable efforts to confer with opposing counsel concerning the matter in

3Plaintiffs also sought to compel Defendant to provide privilege log entries showing the bases for withholding 113 documents previously withheld and then produced on January 24, 2006 and nine (9) documents previously withheld and now produced with redactions, Plaintiffs, however, recently advised the Court that they are withdrawing those two requests. See Plaintiffs’ Supplemental Reply (doc. 4582).
4Fed. R. Civ. P. 37.
3

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dispute prior to the filing of the motion. A “reasonable effort to confer” . . . requires that the parties in good faith converse, confer, compare views, consult and deliberate, or in good faith attempt to do so.5 The purpose of the local rule is to encourage the parties to satisfactorily resolve their discovery disputes prior to resorting to judicial intervention.6 Meet and confer requirements are not satisfied “by requesting or demanding compliance with the requests for discovery.”7 The parties must determine precisely what the requesting party is actually seeking; what responsive documents or information the discovering party is reasonably capable of producing; and what specific, genuine objections or other issues, if any, cannot be resolved without judicial intervention.8 The Court has reviewed the parties arguments regarding Defendant’s allegation that Plaintiffs have failed to meet their duty to confer. For the reasons stated in Plaintiffs’ Reply Brief,9 the Court finds that Plaintiffs have satisfied their meet and confer obligations required by D. Kan. Rule 37.2 and Federal Rule of Civil Procedure 37. III. Discussion A. Plaintiffs’ Request for the Court to Declare No Privilege Exists and Compel
Defendant to Produce the 661 Documents Listed by Bates Number in Exhibits 1 and 2 to Plaintiffs’ Motion Plaintiffs request the Court compel Defendant to produce 511 documents identified in Defendant’s “8/12/2005 Privilege Log” and 150 documents identified in Defendant’s “KC Privilege
5D. Kan. Rule 37.2 (2006). 6Cotracom Commodity Trading Co. v. Seaboard Corp., 189 F.R.D. 456, 459 (D. Kan.1999). 7Id. 8Id. 9Plaintiffs’ Reply Memorandum (doc. 3743) at pp. 1-5.
4

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Log.” In support of this request, Plaintiffs assert Defendant fails to provide sufficient information in the privilege log to establish the elements required to invoke the attorney-client privilege or the work product doctrine for the referenced documents.
Given the sheer quantity of the privilege log entries at issue here, the Court finds it necessary for purposes of this discussion to group the privilege log documents at issue into the following eight (8) discrete categories:
1. Documents listed by bates number in Plaintiffs’ Exhibits 1 and 2 but not included within the “8/12/2005 Privilege Log” or the “KC Privilege Log”;
2. Documents listed in Exhibit 2 by page number and date only; 3. Documents described as consisting of, or transmitting, adverse impact analyses; 4. Documents described as “legal” in nature; 5. Documents described as pertaining to WARN; 6. Documents designated as “from” or “to” a Sprint attorney or Legal Assistant; 7. Documents described as related to “litigation”; and 8. Remaining Documents.
1. Documents listed by bates number in Plaintiffs’ Exhibits 1 and 2 but not included within the “8/12/2005 Privilege Log” or the “KC Privilege Log”
Plaintiffs’ Motion states that privilege log entries for the 661 documents they seek are listed by bates number in Exhibits 1 and 2 and can be found in either the “8/12/2005 Privilege Log” or the “KC Privilege Log.” Plaintiffs state in their Motion that “[b]ecause Judge Waxse already has these two lengthy privilege logs in electronic format as e-mailed to him by Defendant, Plaintiffs are not attaching the logs to this Motion.”10 Plaintiffs specifically note that the logs were e-mailed to the
10Plaintiffs’ Motion to Compel (doc. 3595) at p.5, fn 2. 5

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Court on January 25, 2006.11 Plaintiffs are correct. A legal assistant for the law firm representing Defendant sent two
privilege logs to the Court’s law clerk as attachments to an e-mail dated January 25, 2006.12 The first attachment was designated by Defendant as the “8/12/05 Privilege Log” and consisted of a 133-page privilege log entitled “Williams vs. Sprint Privilege Log for 8/12/2005 Production.” The second attachment was designated by Defendant as the “KC Privilege log” and consisted of a 288-page privilege log entitled “Sprint/Williams Collective Action Amended and Supplemental Privilege Log.”
To that end, there are literally thousands of documents listed in the two electronic privilege logs sent to the Court by e-mail on January 25, 2006. Due to the overwhelming number of disputed privilege log entries in Plaintiffs’ Motion, this Court extracted the 661 privilege log entries listed by bates number in Exhibits 1 and 2 to create a Privilege Log consisting of only those bates numbers at issue in Plaintiffs’ Motion (“Extracted Privilege Log”).13
In compiling the Extracted Privilege Log, it came to the Court’s attention that there are 176 documents listed by bates numbers in Exhibits 1 and 2 that are not included in either the “8/12/2005 Privilege Log” or the “KC Privilege log” electronically sent to the Court on January 25, 2006. The Court identifies these 176 documents by bates number in Appendix 3 to this Memorandum and Order. Because these documents cannot be found within the privilege log provided to the Court in conjunction with this Motion, the Court is not in a position to determine whether Defendant has
11Id. at p.4. 12A copy of this e-mail is attached to this Memorandum and Order as Appendix 1. 13The Extracted Privilege Logs are attached to this Memorandum and Order as Appendix 2.
6

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provided sufficient information to establish the elements required to invoke the attorney-client privilege or the work product doctrine for the referenced documents. Accordingly, Plaintiffs’ Motion will be denied with respect to these 176 documents.
2. Documents Listed in Exhibit 2 by Page Number and Date Only Fifty-one (51) of the 150 documents listed by Plaintiffs in Exhibit 2 to their Motion are not identified by bates number, but instead are identified by the page number of the privilege log and the date of the document. In attempting to extract these fifty-one (51) privilege log entries from the 288-page “KC Privilege Log,” the Court discovered that many of the page numbers designated by Plaintiffs include multiple entries for documents bearing the specific date identified by Plaintiffs. Given these circumstances, it is impossible for the Court to determine which of the entries Plaintiffs intended to be at issue in their Motion. Because the Court is unable to determine which privilege log entries are at issue, the Court is not in a position to determine whether Defendant has provided sufficient information to establish the elements required to invoke the attorney-client privilege or the work product doctrine for the referenced documents. Accordingly, Plaintiffs’ Motion will be denied with respect to these fifty-one (51) documents referenced only by privilege log page numbers and document date.
3. Adverse Impact Analyses Documents Many of the documents Plaintiffs seek to have produced are described in Defendant’s privilege logs as consisting of, or transmitting, adverse impact analyses documents. The Court has identified these adverse impact analyses documents in Appendix 4. Defendant designates all of these
7

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adverse impact documents as protected from disclosure by the attorney-client privilege14 and some as protected from disclosure by both the attorney-client privilege and the work product doctrine. Because the Court finds all of the adverse impact documents are protected from disclosure by the attorney-client privilege, the Court will not address whether these documents are protected from disclosure by the work product doctrine.
The arguments presented by the parties in support of their positions with regard to the adverse impact analyses documents are essentially identical to the arguments presented in prior briefing. Plaintiffs argue that without a showing of involvement bylegal counsel, the adverse impact documents at issue here cannot be protected by the attorney-client privilege. In response, Defendant maintains it adequately has shown the adverse impact documents to be communications made in confidence for the primary purpose of obtaining legal advice, regardless of whether or not an attorney was listed as part of the communication on the privilege log.
Notably, the Court already has resolved this issue. In its February1, 2006 Memorandum and Order, this Court held that “although written communication between corporate management employees is not necessarily protected by the attorney-client privilege, a party may be able to successfully demonstrate applicability of privilege by establishing that the communication was made in confidence for the primary purpose of obtaining legal advice.”15 Relying on Judge Lungstrum’s previous rulings with regard to adverse impact and related analyses, the Court further found
14Defendant describes some of the documents in the “Reason for Privilege” column as “Adverse Impact Analysis” instead of “Attorney-Client Privilege.” Given the Court’s previous ruling that adverse impact analyses are protected from disclosure by the attorney-client privilege in this case, the Court understands Defendant to be claiming that the attorney-client privilege is the reason Defendant will not produce the adverse impact analysis documents.
15February 1, 2006 Memorandum and Order (doc. 3549) at p. 16. 8

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Defendant had met its burden with regard to a claim of protection based on the attorney-client privilege for those documents in the privileged log containing one of several specified descriptive “adverse impact analyses” phrases.16
Upon review of the February 1, 2006 ruling, as later clarified,17 and in the context of the privilege log at issue here, the Court finds no reason to depart from its earlier holding with regard to the adverse impact analyses documents. Thus, the Court finds Defendant has met its burden of proof with regard to a claim of protection based on the attorney-client privilege for adverse impact analyses documents listed in the “8/12/2005 Privilege Log” and the “KC Privilege Log.” Accordingly, Plaintiffs’ Motion with respect to the adverse impact analyses documents identified by bates number in Appendix 4 to this Memorandum and Order will be denied.
4. Documents Described in the Log as Legal in Nature Many of the documents Plaintiffs seek to have produced are described in Defendant’s privilege log as documents related to “legal advice,” “instructions from legal,” “legal review,” “notes from legal,” “action required from legal,” “decision from legal,” “explanation from legal,” “notes from legal,” and “legal review changes.” A listing of these documents is attached to this Memorandum and Order at Appendix 5. Defendant designates some of these “legal” documents as protected from disclosure by the attorney-client privilege, some as protected from disclosure by the work product doctrine and some as protected from disclosure by both the attorney-client privilege and the work product doctrine. The Court will discuss applicability of the attorney-client privilege
16Id. 17See December 13, 2006 Memorandum and Order clarifying February 1, 2006 Memorandum and Order (doc. 4467).
9

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and then the work product doctrine to these “legal” documents. a. Attorney-Client Privilege - Documents Described as Legal
The purpose of the attorney-client privilege “is to encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice.”18 The privilege serves the client’s need for legal advice, but it also serves the attorney’s need to receive complete information in order to give the proper advice. “Not every communication between an attorney and client is privileged, only confidential communications which involve the requesting or giving of legal advice.”19 “The focal point of the protection afforded by the attorney-client privilege lies with ‘communications’ between attorneys and their clients” related to legal advice.20 Legal advice must predominate for the communication to be protected.21
The party asserting the privilege bears the burden of establishing its existence.22 The asserting party must make a “clear showing” that the asserted objection applies.23 To carry that burden, the asserting party must “describe in detail” the documents or information sought to be
18Upjohn Co. v. United States, 449 U.S. 383, 389 (1981). 19Burton v. R.J. Reynolds Tobacco Co.,, 175 F.R.D. 321, 327 (D. Kan. 1997) (citing Fisher v. United States, 425 U.S. 391, 403 (1976); United States v. Olano, 62 F.3d 1180 (9th Cir. 1995)). 20IMC Chemicals, Inc. v. Niro, Inc., No. 98-2348, 2000 WL 1466495, at *8-9 (D. Kan. July 19, 2000) (quoting Upjohn Co., 449 U.S. at 395-96). 21Burton v. R.J. Reynolds Tobacco Co., Inc., 170 F.R.D. 481, 484 (D. Kan. 1997)(citation omitted). 22Id. 23Ali v. Douglas Cable Comm., Ltd. Partnership, 890 F. Supp. 993, 994 (D. Kan. 1995).
10

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protected and provide “precise reasons” for the objection to discovery.24 In addition, the asserting

party must provide sufficient information to enable the court to determine whether each element of

the asserted objection is satisfied; a “blanket claim” as to the applicability of the privilege does not

satisfy the burden of proof.25 Defendant’s failure to meet this burden when the trial court is asked

to rule upon the existence of the privilege is not excused because the document is later shown to be

one that would have been privileged if a timely showing had been made.26

Upon review of entries in the Extracted Privilege Log for documents described as legal in

nature, the Court finds that Defendant has met the burden of proof with regard to a claim of

protection based on the attorney-client privilege with respect to documents bearing the following

bates numbers:

1050810-1050877 1062353-1062353 1070298-1070299 1070514-1070514 1140360-1140364 1352537-1352537 1352538-1352538

1353281-1353281 1428015-1428015 184644-184645 184646-184647 184648-184649 184650-184651 184655-184657

184886-184887 191591-191593 192608-192611 192613-192615 192664-192669 184652-184653 184908

The Court makes this finding on grounds that these documents are all adequately described

in Defendant’s privilege log as documents consisting of or transmitting communications made in

confidence for the primary purpose of obtaining legal advice or services. Thus, Plaintiffs’ Motion

will be denied with respect to these twenty-one (21) documents.

24McCoo v. Denny’s, Inc., 192 F.R.D. 675, 680 (D. Kan. 2000) (citing Nat’l Union Fire Ins. Co. v. Midland Bancor, Inc., 159 F.R.D. 562, 567 (D. Kan. 1994)).
25Id. (citing Jones v. Boeing Co., 163 F.R.D. 15, 17 (D. Kan. 1995) and Kelling v Bridgestone/Firestone, Inc., 157 F.R.D. 496, 497 (D. Kan. 1994)).
26Peat, Marwick, Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984).
11

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Conversely, the Court finds Defendant has failed to meet its burden of proof with regard to

a claim of protection based on the attorney-client privilege for “legal” documents bearing the

following bates numbers:

191263 191264 191265

191313-318 191319-340 191435-442

191696 192621 192710

Although these particular documents are also described as including legal advice of some

sort, Defendant fails to identify either an author or a recipient for these communications. Because

both the author and recipient of these documents are designated as “unknown,” the Court finds

Defendant has failed to meet its burden of demonstrating that the information transmitted involved the requesting or giving of legal advice.
Notably, eight (8) out of nine (9) of these documents are designated in the privilege log as being protected by both the attorney-client privilege and the work product doctrine. Accordingly, and because the Court has found that Defendant has failed to establish that these documents are

protected from disclosure by the attorney-client privilege, the Court will discuss in the next

subsection whether the work product doctrine protects documents bearing bates numbers 191263,

191264, 191265, 191313-318, 191319-340, 191435-442, 191696, and 192621. With regard to the documents bearing bates stamp 192710, however, Plaintiffs’ Motion will be granted. This is because Defendant only claimed protection for this document based on the attorney-client privilege.

b. Work Product - Documents Described as Legal With regard to the “legal” documents identified in the privilege log as attorney work product,

Plaintiffs argue again that, without a showing of involvement by legal counsel, the documents at

issue cannot be protected by the work product doctrine.

12

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To establish work product protection, a party must show that “(1) the materials sought to be protected are documents or tangible things; (2) they were prepared in anticipation of litigation or for trial; and (3) they were prepared by or for a party or a representative of that party.”27 Because there does not appear to be a dispute that the materials sought are documents or that they were prepared by or for Defendant or a representative of Defendant, the Court will address only whether the privilege log adequately describes the documents as being prepared in anticipation of litigation.
The work product doctrine, which is embodied in Rule 26(b)(3) of the Federal Rules of Civil Procedure, protects from discovery documents, things and mental impressions of a party or his representative, particularly his attorney, developed for or in anticipation of litigation or trial.28 The purpose of the doctrine is to permit attorneys to prepare for litigation with a “certain degree of privacy,” and without undue interference or fear of intrusion or exploitation of one’s work by an adversary.29 In other words, the doctrine is not intended to protect investigative work unless done so under the supervision of an attorney in preparation for the real and imminent threat of litigation or trial. Work prepared in the ordinary course of business and inserted into a protected document may still be subject to disclosure after redaction of any privileged material.
Thus, the work product doctrine only applies to those documents and tangible things prepared in anticipation of litigation, and in order for the discovery limitation to apply, there must be a
27Johnson v. Gmeinder, 191 F.R.D. 638, 643 (D. Kan. 2000) (citations omitted). 28Fed. R. Civ. P. 26(b)(3). 29Hickman v. Taylor, 329 U.S. 495, 510-11 (1947).
13

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substantial probability that litigation will ensue at the time the documents were drafted.30 “Certainly
by implication the . . . rule precludes any idea of extending the work product doctrine to reports or
statements, even if written, obtained by the client or his investigators which are not prepared under
the supervision of an attorney in preparation for trial.”31
The issue of whether documents were prepared in anticipation was extensively analyzed by
Judge Rushfelt in Marten v. Yellow Freight System, Inc.32 The court stated:
The work product standard has two components. The first is what may be called the “causation” requirement. This is the basic requirement of the Rule that the document in question be produced because of the anticipation of litigation, i.e., to prepare for litigation or for trial. The second component is what may be termed a “reasonableness” limit on a party’s anticipation of litigation. Because litigation can, in a sense, be foreseen from the time of occurrence of almost any incident, courts have interpreted the Rule to require a higher level of anticipation in order to give a reasonable scope to the immunity.
The court looks to the primary motivating purpose behind the creation of the document to determine whether it constitutes work product. Materials assembled in the ordinary course of business or for other non-litigation purposes are not protected by the work product doctrine. The inchoate possibility, or even the likely chance of litigation, does not give rise to work product. To justify work product protection, the threat of litigation must be “real and imminent.” To determine the applicability of the work product doctrine, the court generally needs more than mere assertions by the party resisting discovery that documents or other tangible items were created in anticipation of litigation.33
Upon review of entries in the Extracted Privilege Log for documents described as legal in
nature, the Court finds that Defendant has failed to meet its burden of proof with regard to a claim
30Cypress Media, Inc. v. City of Overland Park, 268 Kan. 407, 427, 997 P.2d 681 (2000); Alseike v. Miller, 196 Kan. 547, 558, 412 P.2d 1007 (1966).
31Alseike, 196 Kan. at 558. 32 No. 96-2013-GTV, 1998 WL 13244, at *10 (D. Kan. Jan. 6, 1998). 33Id. (citations and quotations omitted).
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of protection based on the work product doctrine for the seventy-one (71) documents bearing the

following bates numbers:

1020580-1020581 1021371-1021371 1064240-1064240 1130395-1130397 1156910-1156911 1157358-1157359 1158389-1158389 1188926-1188927 1205502-1205503 1205511-1205512 1211720-1211722 1211900-1211900 1211901-1211902 1211905-1211906 1211907-1211908 1232869-1232870 1232929-1232930 1233017-1233018 1233134-1233134 1233135-1233135 1233205-1233205 1236839-1236839 1237576-1237580 1238065-1238066

1239589-1239589 1245979-1245981 1248189-1248190 1262713-1262713 1263210-1263210 1263511-1263511 1263524-1263531 1263883-1263885 1263990-1263995 1264033-1264037 1264038-1264042 1264082-1264082 1264121-1264121 1264122-1264124 1265326-1265328 1295946-1295948 1296358-1296358 1296532-1296532 1315187-1315188 1330048-1330049 1340119-1340119 1351972-1351974 1352048-1352048 1352049-1352050

1352209-1352209 1352572-1352573 1352576-1352576 1352594-1352595 1352597-1352598 1352761-1352765 1353434-1353435 1353747-1353749 1353750-1353752 1356298-1356300 1356847-1356847 1356858-1356861 1365825-1365825 1365891-1365891 1426858-1426858 191263 191264 191265 191313-191318 191435-191442 191696 192621 191319-191340

Although the referenced documents are described as including “legal advice” of some sort

or another, there is no assertion by Defendant in either the privilege logs or in the briefs that the

primary motivating purpose behind the creation of the referenced documents was in anticipation of

litigation, i.e., to prepare for litigation or for trial. As noted above, the Court needs more than mere

assertions by the party resisting discovery that the documents were created in anticipation of

litigation.34 For these reasons, Plaintiffs’ Motion with respect to the documents identified by bates

34Id. 15

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number immediately above will be granted. 5. Documents Described as Pertaining to WARN
Thirteen (13) of the 661 documents Plaintiffs seek to have produced are described in Defendant’s privilege log as documents related to WARN compliance or WARN notification. Defendant claims four (4) of these thirteen (13) documents are protected from disclosure by the attorney-client privilege and nine (9) are protected from disclosure by the work product doctrine.
a. Attorney-Client Privilege - WARN Documents Defendant claims it satisfactorily has met the burden of proof with regard to a claim of protection based on the attorney-client privilege for the following “WARN” documents:

Bates
12639181263918
11572921157292
13534191353419 13662401366240

To
Ron Focht; Jill Ferrell
Ron Focht; Jill Ferrell
Michael Brill; Donna Crosswhite Ron Focht; Jill Ferrel

From

Description

Diane Shoemaker Memo regarding WARN

Diane Shoemaker Vickie Smith Diane Shoemaker

Memorandum regarding W ARN com pliance issues
E-mail regarding WARN notification
Memo regarding WARN compliance

Date
1/8/2002

Reason
A/C

1/8/2002

A/C

10/10/2001 A/C

1/8/2002

A/C

The Court agrees. As a preliminary matter, there is no dispute between the parties that Jill Ferrel and

Donna Crosswhite are both Sprint attorneys. Moreover, “WARN” is an acronym that refers to the

the Worker Adjustment and Retraining Notification Act, a federal statute that obligates certain

employers to give workers or their union 60 days’ notice before a plant closing or mass layoff.35

Based on these three entries as written, the Court finds Defendant adequately has shown these three

WARN documents to be communications made in confidence for the primary purpose of obtaining

3529 U.S.C. § 2101 et seq. 16

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legal advice. Thus, the Court deems them protected from disclosure by the attorney-client privilege. b. Work Product - WARN Documents
As opposed to attorney-client privilege, Defendant claims it satisfactorily has met the burden of proof with regard to a claim of protection based on the work product doctrine for the following “WARN” documents:

Bates
13654341365435
13654401365440
13662151366216
13662171366218
13662191366220
13662331366234
13662351366236
13662381366239
14069651406965

To Jon Binder; Sonja Ambur Jon Binder; Suzanne Driscoll Marvin Motley
Sonja Ambur; Janet Larson Sonja Ambur; Kenn Blurton Sonja Ambur
Sonja Ambur
Suzanne Driscoll; Jon Binder Jon Binder; Sonja Ambur

From Suzanne Driscoll Patrick Hulla Michael Brill Michael Brill Michael Brill Suzanne Driscoll John St. Angelo Suzanne Driscoll Catherine Johnson

Description

Date

E-mail regarding WARN 1/15/2002 compliance

E-mail regarding WARN 2/15/2002

Reason WP
WP

E-mail regarding requirements of WARN

12/18/2002 W P

E-mail regarding

4/14/2002 W P

requirements of WARN

E-mail regarding

4/13/2002 W P

requirements of WARN

E-mail regarding

4/15/2002 W P

requirements of WARN

E-mail regarding

4/14/2002 W P

requirements of WARN

E-mail regarding WARN 1/18/2002 W P compliance

E-mail regarding WARN 1/15/2002 W P compliance

Although the referenced documents are described as relating to the requirements of, and compliance with, a federal statute, there is no assertion by Defendant in either the privilege logs or in the briefs that the primary motivating purpose behind the creation of these WARN documents was in anticipation of litigation, i.e., to prepare for litigation or for trial. As noted above, the Court needs more than mere assertions by the party resisting discovery that the documents were created in anticipation of litigation. For these reasons, Plaintiffs’ Motion with respect to the nine (9)

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documents identified by bates number immediately above will be granted. 6. Documents Designated as “From” or “To” a Sprint Attorney
Fifty-seven (57) of the 661 documents Plaintiffs seek to have produced are described in Defendant’s privilege log as being sent “from” or “to” a Sprint attorney. A listing of these documents is attached to this Memorandum and Order at Appendix 6. Of the fifty-seven (57) entries, Defendant claims protection from disclosure by the attorney-client privilege for forty-three (43) of these documents, protection from disclosure by the work product doctrine for six (6) of these documents, and protection from disclosure by both the attorney-client privilege and the work product doctrine for eight (8) of these documents.
a. Attorney-Client Privilege - “From” or “To” a Sprint Attorney The issue presented here is whether a document that was “sent from” or “sent to” a Sprint lawyer automatically protects that document from disclosure by the attorney-client privilege. The Court, as it has done in the past, rejects this position. “Not every communication between an attorney and client is privileged, only the requesting or giving of legal advice.”36 Minutes of meetings attended by attorneys are not automatically privileged, and business documents sent to attorneys are not automatically privileged.37 Likewise, the privilege does not apply where legal advice does not predominate the communication or where legal advice is merely incidental to business advice.38 Here, the Court finds that, as described, the documents at issue fail to establish any
36In re Universal Serv. Fund Tel. Billing Practices, 232 F.R.D. 669, 674 (D. Kan. 2005). (quoting Burton v. R.J. Reynolds Tobacco Co., 175 F.R.D. 321, 327 (D. Kan.1997)).
37Id. 38Id.
18

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 19 of 76

connection between the subject of the communication and the rendering of legal – as opposed to, for example, business-related – advice.39 Because the documents in this category are not described in the privilege log as related in any way to legal advice, the Court finds the Defendant has failed to establish the elements required to invoke the attorney-client privilege for such documents.
b. Work Product - “From” or “To” a Sprint Attorney Although the referenced documents are described as having been “sent from” or “sent to” a Sprint attorney, there is no assertion by Defendant in either the privilege logs or in the briefs that the primary motivating purpose behind the creation or transmission of these documents was in anticipation of litigation, i.e., to prepare for litigation or for trial. As noted above, the Court needs more than mere assertions by the party resisting discovery that the documents were created in anticipation of litigation. For these reasons, the Court finds Defendant has failed to establish the elements required to invoke work product protection.
7. Documents Described as Related to “Litigation” The following six (6) privilege log entries are at issue in this category:

191081191083
191186

unknown unknown

191218191220

unknown

unknown unknown unknown

hand written no tes Litigatio n file unknown A /C ; W P

table with handwritten notes related to notice of litigation

unknown A /C ; W P

handwritten notes employee comparisons, related to notice of litigation

7/18/2002

A /C ; W P

39Burton v. R.J. Reynolds Tobacco Co., 200 F.R.D. 661, 669 (D. Kan.2001) (court found documents written or prepared by attorneys for client were not protected by attorney-client privilege because they did not relate to seeking or giving legal advice but to public relations and public image issues); see, also, Linde Thomson Langworthy Kohn & Van Dyke, P.C. v. Resolution Trust Corp., 5 F.3d 1508 (D.C. Cir.1993) (no privilege if what is sought is not legal advice but insurance advice).
19

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 20 of 76

191221

unknown

191223191227

Kim Mattingly John Carter

191229

unknown

unknown Chip W oods unknown

typed document employee comparisons, related to notice of litigation

unknown

A /C ; W P

fax handwritten notes from meeting with employee, related to notice of litigation

7/19/2002 A /C ; W P

table with handwritten notes re employee comparison, related to notice of litigation

unknown

A /C ; W P

a. Attorney-Client Privilege - “Litigation” Documents The Court finds that the descriptions for the documents in this category fail to establish any connection between the subject of the communication and the rendering of legal advice. That the documents are described as relating to litigation, or the notice of litigation, does not mean that the communications are related to legal advice. Thus, the Court finds the Defendant has failed to establish the elements required to invoke the attorney-client privilege for such documents.

b. Work Product - “Litigation” Documents As noted above, to establish work product protection, a party must show that “(1) the materials sought to be protected are documents or tangible things; (2) they were prepared in anticipation of litigation or for trial; and (3) they were prepared by or for a party or a representative of that party.”40 To that end, the Court finds that the privilege log describes the materials sought to be protected as documents that were prepared in anticipation of litigation. Thus, the only issue is whether the documents were prepared by or for a party or a representative of that party. Given the “sent from” and “sent to” columns fail to identify any person for five (5) of the six (6) documents, the Court cannot find that those five (5) documents were prepared by or for a party or a

40Johnson v. Gmeinder, 191 F.R.D. 638, 643 (D. Kan. 2000) (citations omitted). 20

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 21 of 76

representative of that party. Conversely, the document bearing bates stamps 191223-191227

designates a Sprint employee in both the “sent from” and “sent to” columns. The Court finds this description adequately indicates that the documents were prepared by or for Defendant or a

representative of Defendant. Accordingly, the Court holds that in this category, the document bearing bates stamp 191223-191227 is the only document adequately described as being protected

from disclosure by the work product doctrine.

8. Remaining Documents Eighty-one (81) of the 661 documents do not fit into any of the categories described above.

These documents are listed in Appendix 7 to this Memorandum and Order. Upon individual review of each of these eighty-one (81) entries, the Court finds Defendant has failed to establish the

elements required to invoke the attorney-client privilege or the work product doctrine. This is because

C

none of the entries indicate that the documents are related in any way to

obtaining legal advice; and

C

none of the entries indicate the documents were prepared in anticipation of

litigation.

Thus, Plaintiffs’ Motion will be granted with respect to these eighty-one (81) documents.

21

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B. Plaintiffs’ Request for the Court to Compel Defendant to produce 165 Documents for which Defendant Allegedly Withdrew a Privilege Objection
Plaintiffs ask the Court to compel Defendant to produce 165 documents that Defendant claims are not responsive to any discovery request. The parties agree that these 165 documents were never listed in any privilege log provided to Plaintiffs.
By way of background, Defendant asserts it mistakenly placed these 165 documents on the privilege log as it was being assembled. Defendant states that upon later review, Defendant determined the documents were not actually privileged and were not actually responsive to any request. Thus, Defendant removed the 165 documents from the privilege log before the log was sent to Plaintiffs. Defendant states it did not subsequently produce the documents to Plaintiffs on grounds that the documents were not actually responsive to any request.
The removal of the documents from the log left gaps in the bates numbering. In order to explain the gaps in bates numbering, Defendant states it sent a cover letter to Plaintiffs attaching a list of the missing bates numbers and noting that documents had been included in the original log by mistake. Defendant also noted in this cover letter that it would not be producing these 165 documents because the documents were not actually responsive to any request.
Notably, many of the 165 documents are so-called “demographic documents.” Defendant states it did not produce these demographic documents because at the time Plaintiffs’ Motion was filed, Plaintiffs had not requested the “demographic documents.” Notwithstanding this fact, Defendant voluntarily allowed Plaintiffs to view a sample of the 165 documents at issue as part of a meet and confer process regarding whether the documents were responsive to any of Plaintiffs’ document requests. After this viewing, Plaintiffs propounded to Defendant their 13th Request for
22

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 23 of 76
Production of Documents, which included a formal request for the demographic documents.41 On December 22, 2006, Plaintiffs filed a Motion to Compel, which included a request to
compel the demographic documents.42 That Motion was referred to the Special Master. In response to Plaintiffs’ Motion, Defendant agreed to produce all of the demographic documents, subject to its objection, in a nonnative format redacting all information other than age, which is all Plaintiffs allegedly requested. Taking into account this agreement, the Special Master then resolved all other issues relating to the 13th Request for Production of Documents on January 18, 2007.43 The demographic documents were subsequently produced to Plaintiffs and, on March 6, 2007, Defendant filed a second supplemental brief informing the Court that the demographic documents had been produced.44
In light of the fact that the demographic documents have now been produced, it appears the remaining issue for resolution by the Court is whether Defendant should be compelled to produce non-demographic documents that were part of the 165 documents removed from the privilege log by Defendant before the privilege log was transmitted to Plaintiffs. Defendant maintains it should not have to produce the documents because they are not responsive to any document request. Plaintiffs maintain that it does not matter whether a document request was submitted because the documents are relevant on grounds that Defendant has failed to explain how it is that each one of these documents was considered responsive at the time it was designated as privileged, but
41See Doc. 4369. 42Docs. 4488-89. 43Doc. 4534. 44Doc. 4580.
23

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 24 of 76
subsequently considered non-responsive when the privilege is withdrawn. Federal Rule of Civil Procedure 26(b)(1) governs the scope of discovery. It provides that [p]arties may obtain discovery regarding any matter, not privileged, that is relevant to the claim or defense of any party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. . . . Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.45 Relevancy is broadly construed, and a request for discovery should be considered relevant
if there is “any possibility” that the information sought may be relevant to the claim or defense of any party.46 When the discovery sought appears relevant on its face, the party resisting the discovery has the burden to establish the lack of relevance by demonstrating that the requested discovery does not come within the broad scope of relevance as defined under Rule 26(b)(1), or is of such marginal relevance that the potential harm the discovery may cause would outweigh the presumption in favor of broad disclosure.47 Conversely, when relevancy is not apparent on the face of the interrogatory or request, the party seeking the discovery has the burden to show the relevancy of the information or documents sought.48
Here, the Court is unable to engage in a relevancy analysis because (1) there is no pending request upon which to assess such relevancy; and (2) the parties have failed to submit to the Court any description of the non-demographic documents at issue. That the referenced documents were
45Fed. R. Civ. P. 26(b)(1). 46McCoy v. Whirlpool Corp., 214 F.R.D. 642, 643 (D. Kan. 2003) (citation omitted). 47Id. (citation omitted). 48Id. (citation omitted).
24

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 25 of 76
initially placed on a privilege log and then subsequently removed from a privilege log before the privilege log was produced to the opposing party is – in and of itself – insufficient to establish relevancy. There must be some indicia that the documents sought are relevant to the claim or defense of any party or some indicia that the documents are reasonably calculated to lead to the discovery of admissible evidence. Because there is no pending request and because the parties have failed to submit to the Court any description of the non-demographic documents, the Court finds the parties have failed to present any legal or factual issue for determination. Thus, Plaintiffs’ Motion will be denied with respect to these 165 documents. IV. Sanctions
The Court will now consider the issues of sanctions. Federal Rule of Civil Procedure 37(a)(4) governs the imposition of sanctions in connection with motions to compel. Subsection (a)(4)(A) provides that when a motion to compel is granted, “the court shall, after affording an opportunity to be heard, require the party . . . whose conduct necessitated the motion or the party or attorney advising such conduct or both of them to pay to the moving party the reasonable expenses incurred in making the motion including attorney’s fees, unless the court finds that . . . the opposing party’s . . . response or objection was substantially justified, or that other circumstances make an award of expenses unjust.”49 Moreover, Federal Rule of Civil Procedure 37(a)(4)(C) allows a court to impose sanctions where, as here, a motion to compel is granted in part and denied in part. Under that rule, the court may “apportion the reasonable expenses incurred in relation to the motion among the parties and persons in a just manner.”50
49Fed. R. Civ. P. 37(a)(4)(A) (emphasis added). 50Fed. R. Civ. P. 37(a)(4)(C).
25

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 26 of 76

Upon consideration of the circumstances presented here, the Court finds that an award of expenses to either party in conjunction with this Motion would be unjust. Although many portions of Plaintiffs’ Motion were granted, many portions of Plaintiffs’ Motion were denied. Simply put, the Court finds that each of the parties here contributed to the need for Court intervention: Plaintiffs by failing to submit a request for designated categories of documents after the meet and confer and Defendant by failing to properly justify its assertion of privilege for various documents. For these reasons, the Court declines to impose sanctions.

V. Summary of Ruling

Based on the discussion above, it is hereby ordered that Plaintiffs’ Motion to Compel is

granted in part and denied in part. More specifically, Plaintiffs’ Motion is

C

granted with respect to the one (1) document described as “legal” in nature and bearing bates

number:

192710

C

granted with respect to the following seventy-one (71) documents described as “legal” in

nature and bearing bates numbers:

1020580-1020581 1021371-1021371 1064240-1064240 1130395-1130397 1156910-1156911 1157358-1157359 1158389-1158389 1188926-1188927 1205502-1205503 1205511-1205512 1211720-1211722 1211900-1211900 1211901-1211902 1211905-1211906 1211907-1211908

1232869-1232870 1232929-1232930 1233017-1233018 1233134-1233134 1233135-1233135 1233205-1233205 1236839-1236839 1237576-1237580 1238065-1238066 1239589-1239589 1245979-1245981 1248189-1248190 1262713-1262713 1263210-1263210 1263511-1263511

1263524-1263531 1263883-1263885 1263990-1263995 1264033-1264037 1264038-1264042 1264082-1264082 1264121-1264121 1264122-1264124 1265326-1265328 1295946-1295948 1296358-1296358 1296532-1296532 1315187-1315188 1330048-1330049 1340119-1340119

26

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 27 of 76

1351972-1351974 1352048-1352048 1352049-1352050 1352209-1352209 1352572-1352573 1352576-1352576 1352594-1352595 1352597-1352598 1352761-1352765

1353434-1353435 1353747-1353749 1353750-1353752 1356298-1356300 1356847-1356847 1356858-1356861 1365825-1365825 1365891-1365891 1426858-1426858

191263 191264 191265 191313-191318 191435-191442 191696 192621 191319-191340

C

granted with respect to the following nine (9) WARN documents bearing bates numbers

1365434-1365435 1365440-1365440 1366215-1366216 1366217-1366218 1366219-1366220 1366233-1366234 1366235-1366236 1366238-1366239 1406965-1406965

C

granted with respect to the fifty-seven (57) documents “sent to” or “received from” a Sprint

attorney as identified in Appendix 6;

C

granted with respect to the following five (5) documents described as related to “litigation”

bearing bates numbers

191081-191083 191186 191218-191220 191221 191229

C

granted with respect to the eighty-one (81) “remaining” documents as identified in

Appendix 7;

C

denied with respect to the 176 documents listed by bates numbers in Exhibits 1 and 2 that

are not included in the privilege logs sent to the Court on January 25, 2006, as identified by

bates number in Appendix 3;

C

denied with respect to the fifty-one (51) documents identified by page number of privilege

log and date of the document only, as set forth in Exhibit 2 to Plaintiffs’ Motion;

27

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 28 of 76

C

denied with respect to the 184 adverse impact analyses documents identified by bates number

in Appendix 4;

C

denied with respect to the following twenty-one (21) documents described as “legal” in

nature and bearing bates numbers

1050810-1050877 1062353-1062353 1070298-1070299 1070514-1070514 1140360-1140364 1352537-1352537 1352538-1352538 1353281-1353281 1428015-1428015 184644-184645 184646-184647 184648-184649 184650-184651 184655-184657 184886-184887 191591-191593 192608-192611 192613-192615 192664-192669 184652-184653 184908

C

denied with respect to the following one (1) document described as related to “litigation” and

bearing bates number

191223-191227

C

denied with respect to the following four (4) WARN documents bearing bates numbers

1263918-1263918 1157292-1157292 1353419-1353419 1366240-1366240

C

denied with respect to those non-demographic documents within the pool of 165 documents

initially placed on a privilege log and then subsequently removed from a privilege log before

the privilege log was produced

28

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 29 of 76

IT IS SO ORDERED. Dated in Kansas City, Kansas on this 19th day of March, 2007.

cc: All counsel and pro se parties

s/ David J. Waxse David J. Waxse United States Magistrate Judge

29

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 30 of 76
APPENDIX 1
<Krista.Embree@Husch"> <Melissa_Taylor_Standridge@ksd.uscourts.uscourts.gov> 01/25/2006 04:23 PM
Subject 8-12-05 and KC Privilege Logs
If these don't come thru, please let me know and I will e-mail them separately. Thanks, Krista Embree
-----Original Message---From: Melissa_Taylor_Standridge@ksd.uscourts.gov [mailto:Melissa_Taylor_Standridge@ksd.uscourts.gov] Sent: Wednesday, January 25, 2006 4:22 PM To: krista.embree@husch.com Subject: test
Melissa Taylor Standridge Law Clerk to Judge Waxse 219 United States Courthouse 500 State Avenue Kansas City, Kansas 66101 (913)551-5435
Circular 230 Disclosure: In compliance with requirements imposed by the IRS pursuant to IRS Circular 230, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
This e-mail message from the law firm of Husch & Eppenberger, LLC is intended only for named recipients. It contains information that may be confidential, privileged, attorney work product, or otherwise exempt from disclosure under applicable law. If you have received message in error, are not a named recipient, or are not the employee or agent responsible for delivering this message to a named recipient, be advised that any review, disclosure, use, dissemination, distribution, or reproduction of this message or its contents is strictly prohibited.
Please notify us immediately at 314.480.1500 or at helpdesk@husch.com that you have received this message in error, and delete the message. Thank you.
30

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 31 of 76

Message from "Embree, Krista" <Krista.Embree@Husch.com> on Wed, 25 Jan 2006 16:12:24 -0600

To: "'Melissa_Standridge@ksd.uscourts.gov'" <Melissa_Standridge@ksd.uscourts.gov>
cc: <sdennis@pophamlaw.com>," (dhubbard@kh-law.com)" <dhubbard@kh-law.com>, Steve Dennis "'mmyers@myerslaw.com'" <mmyers@myerslaw.com>
Subject: Williams v. Sprint, 03-2200, Privilege Logs attached
Melissa:
Pursuant to Judge Waxse's request, I am attaching the two privilege logs discussed at the status conference last Thursday, January 19, 2006. If you have any questions or problems with the attachments, please do not hesitate to let me know and other arrangements will be made to get the documents to the Court.

<<KC Privilege Log.pdf>>

<<8-12-05 privilege log.pdf>>

Very Truly Yours,

Krista Embree Legal Assistant
Husch & Eppenberger, LLC 1200 Main Street, Suite 2300 Kansas City, Missouri 64105-2122 Direct Dial: 816-329-4724 Toll Free: 1-877-539-3450
Fax: 816-421-0596

Krista.Embree@Husch.com

31

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 32 of 76

APPENDIX 2: EXTRACTED PRIVILEGE LOG

Bates
1 0 0 0 0 1 3 -1 0 0 0 0 1 3 1 0 0 0 0 2 6 -1 0 0 0 0 3 9 1 0 0 0 0 4 0 -1 0 0 0 0 7 4 1 0 0 0 0 7 5 -1 0 0 0 1 2 1 1 0 0 0 1 2 2 -1 0 0 0 1 2 3 1 0 0 0 1 3 3 -1 0 0 0 1 9 1 1 0 0 0 1 9 4 -1 0 0 0 2 0 3 1 0 0 0 2 0 4 -1 0 0 0 2 1 9 1 0 0 0 2 2 0 -1 0 0 0 2 7 8 1 0 0 0 3 1 6 -1 0 0 0 9 6 3 1 0 0 1 1 2 1 -1 0 0 1 1 2 5 1 0 0 9 9 0 8 -1 0 0 9 9 0 8 1 0 0 9 9 1 2 -1 0 0 9 9 1 2

To
None None Gre g Coop er Kenna Osburn T er ry Yor k None None None None Peter Dillon Da ve Iery Melannie Schultz Ric W alter

1 0 0 9 9 1 4 -1 0 0 9 9 1 5 1 0 0 9 9 1 6 -1 0 0 9 9 1 6

Jerry Usry Jerry Usrey

1 0 0 9 9 2 0 -1 0 0 9 9 2 0

Mic hael B ril

1 0 0 9 9 2 1 -1 0 0 9 9 2 1 1009922 1 0 0 9 9 2 4 -1 0 0 9 9 2 4 1 0 0 9 9 6 1 -1 0 0 9 9 6 3 1 0 0 9 9 7 6 -1 0 0 9 9 7 8 1 0 0 9 9 9 5 -1 0 1 0 0 1 9 1 0 1 0 0 2 0 -1 0 1 0 0 3 0 1 0 1 0 1 0 3 -1 0 1 0 1 0 3 1 0 1 0 1 0 4 -1 0 1 0 1 0 5 1 0 1 0 2 5 0 -1 0 1 0 2 5 4

Jerry Usrey Jerry Usrey Jerry Usrey Jerry Usrey Kathleen McBee None None Jerry Usrey Jerry Usrey Melannie Schultz

1 0 1 0 5 3 3 -1 0 1 0 5 3 6

Kate Fisher

1 0 1 3 0 3 5 -1 0 1 3 3 0 6 1 0 1 3 5 2 4 -1 0 1 3 5 2 5

John Shannon Lynn Simpson

From
Unknown Unknown Peter Dillon Peter Dillon Peter Dillon Unknown Unknown Unknown Unknown Eric Rice Janet Ca shwe ll Ch ris Hu bert Gre g Coop er Kim Ma ttingly Gre gory P lante Kevin Wilson
Greg Cooper Kate Fisher Ric W alter Bill Benner Gre gory P lante Gregory Plante Lynn Simpson Unknown Unknown Frank Hickey Frank Hickey Kip Downey Faith Palmer Janet Larson Pa trick Hu lla Allison Reed Janet Gonzales

Extractions from 8/12/2005 Log
D e s c ri p ti o n
Tem plate reflecting AI analysis Spreadsheet reflecting AI Analysis AI analysis sp readsheet E-mail & spreadsheets re: network director E - m ai l tr an s m it ti ng sp re a ds h ee ts re A I AI Analysis Spreadsheet Spreadsheet: Network Dept demographics AI analysis for network director selection AI analysis for network director selection E-mail spreadsheet re: finance selection pool E-mail with attached separation information E-m ail transmitting AI A nalysis Spreadsheet E-m ail re: total # e mployee separation s in O ct.

Date
0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 2 / 1 9 /0 3 1 2 / 2 7 /0 2 1 2 / 4 /0 2 0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 2 / 3 /0 3 1 1 / 1 4 /0 3 1 / 3 0 /0 3 5 / 2 4 /0 2 1 0 / 3 1 /0 2

E-mail re: downsizing of employees in region E-mail transmitting word document from m gr staffing meeting for the engineering dept. E-m ail re: timeline for restructuring of C PE Field O p e r a t io n s E-mail regarding CPE reductions E-mail re: downsizing in Pacific region E-mail re: employee reductions in each market E-m ail re: reco mmend ations for Atlantic reo rg E-mail containing info related to the RIF Spreadsheet: Headcount Reduction Spreadsheet: Voluntary Headcount Reduction E-mail re: workforce reduction E-mail re: workforce reduction E-mail with updates on how the RIF is being conducted

6 / 1 4 /0 2 9 / 2 4 /0 2
9 / 2 6 /0 2
7 / 3 /0 2 6 / 1 4 /0 2 6 / 1 0 /0 2 5 / 1 4 /0 2 1 / 5 /0 2 0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 6 / 1 0 /0 2 6 / 1 1 /0 2 6 / 4 /2 0 0 2

Handwritten Note and E-mail containing RIF information

7 / 2 3 /2 0 0 2

E-mail transmitting a list of employees for redeployment E-m ail reg arding Ad verse Imp act ana lysis

4 / 2 /2 0 0 2 1 1 / 2 2 /2 0 0 2

P r iv i le g e
AI Full Privilege AI Full Privilege AI Part Privileged AI Part Privileged AI Full Privilege AI Part Privileged AI Full Privilege AI Part Privileged AI Part Privileged AI Part Privileged AI Part Privileged AI Full Privilege A/C Part Privileged
A/C Part Privileged A/C Part Privileged
A/C Part Privileged
A/C Part Privileged A/C Part Privileged A/C Part Privileged A/C Part Privileged W P Part Privileged AI Full Privilege AI Full Privilege A/C Part Privileged A/C Part Privileged A/C Part Privileged
A/C Full Privilege
A/C Full Privilege AI Full Privilege

32

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 33 of 76

1 0 2 0 3 8 0 -1 0 2 0 4 2 3 1 0 2 0 5 0 4 -1 0 2 0 5 0 4

Chris Thompson Debra Aubuchon

1 0 2 0 5 8 0 -1 0 2 0 5 8 1

Kate Fish er

1 0 2 0 9 9 8 -1 0 2 0 9 9 8 1 0 2 0 9 9 9 -1 0 2 0 9 9 9

Sh eryl B ow lin Tami Keasling

1 0 2 1 1 0 9 -1 0 2 1 1 0 9 1 0 2 1 1 6 8 -1 0 2 1 1 7 0 1 0 2 1 2 3 3 -1 0 2 1 2 3 3 1 0 2 1 3 7 1 -1 0 2 1 3 7 1

Deonna Sharp Denice Aissa Mic hael B rill Kate Fisher

1 0 3 4 2 2 9 -1 0 3 4 2 2 9 1 0 5 0 8 1 0 -1 0 5 0 8 7 7

Kate Fish er Angie Foltz

1 0 5 2 7 9 4 -1 0 5 2 7 9 6

Gre g Coop er

1 0 6 2 2 4 5 -1 0 6 2 2 4 5 1 0 6 2 2 4 7 -1 0 6 2 2 4 7 1 0 6 2 3 1 8 -1 0 6 2 3 1 8 1 0 6 2 3 1 9 -1 0 6 2 3 2 0 1 0 6 2 3 2 1 -1 0 6 2 3 2 2 1 0 6 2 3 2 3 -1 0 6 2 3 2 4 1 0 6 2 3 4 1 -1 0 6 2 3 4 3 1 0 6 2 3 5 3 -1 0 6 2 3 5 3 1 0 6 2 5 2 5 -1 0 6 2 5 2 7 1 0 6 2 5 2 8 -1 0 6 2 5 3 1 1 0 6 2 6 3 2 -1 0 6 2 6 4 1 1 0 6 4 2 4 0 -1 0 6 4 2 4 0 1 0 6 4 2 5 2 -1 0 6 4 2 5 3 1 0 6 4 2 5 6 -1 0 6 4 2 5 6

Mic hael M achell Mic hael M achell Melannie Schultz Melannie Schultz Melannie Schultz Melannie Schultz Melannie Schultz Shelley Porter De b S prayberry De b S prayberry Unknown Nan cy Fox De irdre Moore Ann Rhoads

1 0 6 5 2 1 8 -1 0 6 5 2 1 8 1 0 7 0 0 9 9 -1 0 7 0 1 0 1

Sarah Urich Eric Rice

1 0 7 0 1 4 0 -1 0 7 0 1 4 0 1 0 7 0 1 4 3 -1 0 7 0 1 4 3

Karin Miller Karin Miller

1 0 7 0 2 9 8 -1 0 7 0 2 9 9

Sonja A mbur

Ron Gier John Shannon Ron Gier Mic hael M achell
Jan Price Jan Price Elle n M artin Vic ki K olb C o rp o ra te E R Ken Blurton Greg Cooper Mic hael B rill Mic hael M achell Lisa Lieb Twilla Skelton Frederick Ha rris Paula Zuzich Jeffry Chavez Louise Elrod Ch ris Hu lbert Ch ris Hu lbert Ch ris Hu bert Ch ris Hu bert Hu bert Ch ris De b Godd ard Suzan S inclair Suzan S inclair Unknown Unknown Ann Rhoads Jim Kissinger Ron Gier

E-m ail transm itting transition team materials E-mail re revised timeline for November action

1 2 / 2 3 /2 0 0 2 1 0 / 2 6 /2 0 0 2

E-mail giving legal advice to HR regarding how to treat e m p lo ye es on LO A
E-mail transmitting AI Analysis spreadsheet
E-mail containing updated instructions for the RIF

1 1 / 7 /2 0 0 1
1 0 / 3 0 /2 0 0 1 1 0 / 2 4 /2 0 0 1

E-m ail rega rding releas e agreem ents E-mail explaining the separation plan E-mail containing follow up information on RIFs E-mail re: advice from legal on separation of employee

1 / 2 3 /2 0 0 1 1 1 / 2 0 /2 0 0 1 5 / 2 4 /2 0 0 2 4 / 1 1 /2 0 0 2

E-m ail transm itting Ad verse Imp act Ma trix

4 / 8 /2 0 0 2

E-mail containing legal advice on severance information 5/1/2002

E-mail with attached RIF list
E-m ail reflecting Ad verse Imp act An alysis E-m ail reflecting Ad verse Imp act An alysis E-m ail reflecting Ad verse Imp act An alysis E-mail reflecting Adverse Impact E-mail reflecting Adverse Impact E-mail reflecting Adverse Impact E-m ail reflecting Ad verse Imp act An alysis E-m ail re: RIF instruc tions from legal dept E-m ail transmitting adverse im pact sprea dsheet E-m ail transm itting adv erse im pact an alysis spreadsheet showing adverse impact analysis E-m ail rega rding legal review update E-mail regarding marketing organization E-mail regarding selection decisions

7 / 1 9 /2 0 0 2
3 / 9 /2 0 0 2 3 / 8 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 7 /2 0 0 2 5 / 2 2 /2 0 0 2 0 0 0 0 - 0 0 -0 0 1 1 / 7 /2 0 0 2 0 0 0 0 - 0 0 -0 0 0 0 0 0 - 0 0 -0 0 1 1 / 5 /2 0 0 2 1 1 / 1 /2 0 0 2

Jim McNaughton Steve Furgason Pa trick Hu lla Susan W aldron Kelly Mortensen

E-mail regarding Adverse Impact E-m ail rega rding Dallas im pacts
E-m ail reflecting adv erse im pact an alysis E-m ail rega rding instructions o n RIF lists

2 / 5 /2 0 0 2 1 2 / 1 0 /2 0 0 2
1 / 2 9 /2 0 0 3 1 / 3 0 /2 0 0 3

Mic hael B rill Kenn Blurton

E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n W A R N requirem ents

4 / 1 3 /2 0 0 2

W P Full Privilege W P Full Privilege
W P Full Privilege
AI/ W P Full Privilege A/C Full Privilege
W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege
AI Full Privilege A/C Full Privilege
AI Part Privileged
AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C Part Privileged AI Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege W P Full Privilege WP A/C Full Privilege AI Full Privilege A/C Full Privilege
AI Full Privilege WP A/C Full Privilege WP A/C Full Privilege

33

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 34 of 76

1 0 7 0 4 5 4 -1 0 7 0 4 5 4

Chris Thompson

1 0 7 0 5 1 4 -1 0 7 0 5 1 4

Ma ynard D anny

1 0 8 3 9 6 3 -1 0 8 3 9 6 3 1 0 8 3 9 6 4 -1 0 8 3 9 6 4 1 1 0 9 2 5 3 -1 1 0 9 2 5 3 1 1 3 0 3 9 5 -1 1 3 0 3 9 7

Sheryl Bowlin Sheryl Bowlin Sh eryl B ow lin Faith Palmer

Julie Moylan Ron Gier Colby Gilson Trinder Betsy
Linda Picke tt Linda Picke tt Jan Price Kip Do wn ey

1 1 4 0 3 6 0 -1 1 4 0 3 6 4

Renee Finks

Ca rrie R othye

E-mail regarding RIF process documentation

1 / 2 9 /2 0 0 3

E-mail regarding instructions from legal on policy waiver request

1 2 / 1 0 /2 0 0 2

E-m ail reflecting adv erse im pact an alysis E-mail identifying list for adverse impact analysis E-mail with instructions on visa and patent reports E-mail regarding savings worksheet for finance and instructions from legal spreadsheet prepared for lega l revie w and e-m ail

1 0 / 1 5 /2 0 0 1 1 0 / 1 5 /2 0 0 1 1 1 / 7 /2 0 0 1 7 / 1 0 /2 0 0 2
3 / 2 8 /2 0 0 2

1 1 4 0 3 6 5 -1 1 4 0 3 7 3 1 1 4 0 3 8 2 -1 1 4 0 3 8 6 1 1 4 0 6 2 9 -1 1 4 0 6 2 9 1 1 4 1 3 2 1 -1 1 4 1 3 2 2 1 1 5 6 9 1 0 -1 1 5 6 9 1 1 1 1 5 7 2 9 2 -1 1 5 7 2 9 2 1 1 5 7 3 5 8 -1 1 5 7 3 5 9 1 1 5 8 1 1 2 -1 1 5 8 1 1 3 1 1 5 8 1 1 5 -1 1 5 8 1 1 6 1 1 5 8 1 3 1 -1 1 5 8 1 3 2 1 1 5 8 1 3 3 -1 1 5 8 1 3 4 1 1 5 8 1 5 6 -1 1 5 8 1 5 7 1 1 5 8 2 3 2 -1 1 5 8 2 3 3 1 1 5 8 3 8 6 -1 1 5 8 3 8 7 1 1 5 8 3 8 9 -1 1 5 8 3 8 9 1 1 8 8 9 2 6 -1 1 8 8 9 2 7 1 1 9 1 3 9 0 -1 1 9 1 3 9 0 1 1 9 3 7 1 7 -1 1 9 3 7 1 7

John Shannon; R enee Finks
R enee Finks

Carrie Rothove John Shannon

Lynn Simpson Do nna Crossw hite
Gene Lampe

Diane Shoemaker
Scott W inkler

Joan Vanderhelde; Susan Cheney
Ro n Focht; Jill Fe rrell
Mic hael B rill

Rick Mears
Diane Shoemaker Mic hael M achell

Sherrie Bowlin; Do nna Crossw hite
De nice Ais sa; Jill Fe rrell
Denice Aissa; Do nna Crossw hite
Sherly Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Mic hael B rill; Do nna Crossw hite
Kimberly Klosak

Vick ie Sm ith C o rp o ra te E R C o rp o ra te E R Vick ie Sm ith Su zan ne Dris coll Vick ie Sm ith Da n C hojnack i

Shirley Fox; Suzy Keolling Linda Picke tt
Shirley Fox; Linda Abbet Ron Focht

Janet Larson
Sonja A mburH a r t le y Jerry Harris
Da nette N orris

E-mail regarding list of legal pools and reasons for adverse impact an alysis E-mail regarding legal lists with pools and reasons for adverse impact an alysis E-m ail rega rding revise d tem plate
E-mail regarding draft release language
E-mail regarding instructions from legal on records c o l le c t io n Memorandum regarding W ARN com pliance issues

4 / 1 /2 0 0 2 4 / 3 /2 0 0 2 1 / 4 /2 0 0 2 1 0 / 3 1 /2 0 0 1 1 2 / 2 6 /2 0 0 2 1 / 8 /2 0 0 2

E-mail regarding legal review changes E-m ail rega rding update on corporate hando uts

4 / 1 0 /2 0 0 2 1 0 / 2 6 /2 0 0 1

E-mail regarding current workforce reduction guidelines

9 / 1 9 /2 0 0 1

E-mail regarding separation guidelines

1 1 / 2 0 /2 0 0 1

E-m ail rega rding updated letter tem plate

1 0 / 2 4 /2 0 0 1

E- m ai l r egar di ng additional pr oc es s c hec k s

1 0 / 3 0 /2 0 0 1

E-mail regarding template letter overview

1 0 / 1 7 /2 0 0 1

E-mail regarding adverse impact analysis E - m ai l r eg a rd in g re s po n se fr om l eg a l o n W A R N

6 / 2 4 /2 0 0 2 9 / 6 /2 0 0 2

E-mail regarding legal review on RIFs

2 / 9 /2 0 0 3

E-m ail rega rding revise d adverse im pact analysis repo rt

1 1 / 1 2 /2 0 0 1

E-mail regarding Adverse Impact on distribution center a s s o c ia t e s

4 / 2 4 /2 0 0 2

A/C Full Privilege
A /C ; W P Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege W P Part Privileged A /C W P Full Privilege AI Full Privilege AI Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege A/C Full Privilege
W P Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege AI Full Privilege W P Full Privilege
W P Full Privilege AI Full Privilege
AI Full Privilege

34

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 35 of 76

1 1 9 3 7 1 8 -1 1 9 3 7 1 8

Dick S um mers

1 1 9 9 4 7 9 -1 1 9 9 4 7 9 1 2 0 5 5 0 2 -1 2 0 5 5 0 3

John St. Angelo; Kate Fisher
Faith Palmer

1 2 0 5 5 0 7 -1 2 0 5 5 1 0 1 2 0 5 5 1 1 -1 2 0 5 5 1 2

Faith Palmer; Kip Downey
Faith Palmer

1 2 0 5 5 2 0 -1 2 0 5 5 2 3 1 2 0 5 5 4 3 -1 2 0 5 5 4 3

Faith Palmer; Kip Downey
Faith Palmer

1 2 0 5 6 0 2 -1 2 0 5 6 0 2

De b Sprayberry

1 2 0 5 6 0 4 -1 2 0 5 6 0 4

De b Sprayberry

1 2 0 9 7 8 8 -1 2 0 9 7 8 8 1 2 1 0 1 7 7 -1 2 1 0 1 7 8

Cody Krause; Co rey Ke pha rt
Debra Simpson

1 2 1 0 2 2 7 -1 2 1 0 2 2 8

Eric Rice

1 2 1 0 2 5 3 -1 2 1 0 2 5 3 1 2 1 0 2 9 6 -1 2 1 0 2 9 6

Gene Lampe Da vid M cElligott
Cody Krause

1 2 1 0 4 2 7 -1 2 1 0 4 2 7

Gene Lampe

1 2 1 1 4 9 7 -1 2 1 1 4 9 9

Kenn Blurton

1 2 1 1 7 1 8 -1 2 1 1 7 1 9

Justin Cro ssw hite

1 2 1 1 7 2 0 -1 2 1 1 7 2 2

Justin Cro ssw hite

1 2 1 1 9 0 0 -1 2 1 1 9 0 0 1 2 1 1 9 0 1 -1 2 1 1 9 0 2 1 2 1 1 9 0 5 -1 2 1 1 9 0 6

Sonja C olbert; Mari Byrne
Eric R ice; Mari Byrne
Sonja C olbert

1 2 1 1 9 0 7 -1 2 1 1 9 0 8 1 2 1 4 2 9 5 -1 2 1 4 2 9 5

Eric R ice; Mari Byrne
Lynn Stange

1 2 3 2 8 6 4 -1 2 3 2 8 6 4 1 2 3 2 8 6 9 -1 2 3 2 8 7 0

Sharri Evenson; Tonya Johnston
Mari Byrne

Da nette N orris Ric W alter Kip Downey Ch ris Hu bert
Kip Downey Ch ris Hu bert
Ch ris Hu bert Joan V o n d e r h e id e Joan V o n d e r h e id e Eric Rice Eric Rice Gene Lampe Eric Rice
Eric Rice Eric Rice Ric W alter Julie Moylan Julie Moylan Eric Rice
Sonja C olbert
Eric Rice Sonja C olbert
Adriane Hacke tt Mel Moyer Eric Rice

E-mail regarding Adverse Impact on distribution center r e d u c ti o n
E-mail regarding adverse impact

4 / 2 4 /2 0 0 2 1 1 / 1 1 /2 0 0 1

E-m ail reg arding bud get cha llenge and note s from lega l E-mail regarding adverse impact

7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2

E-mail regarding budget and notes from legal E-mail regarding adverse impact

7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2

E-mail regarding adverse impact E-mail regarding adverse impact review E-m ail reg arding adv erse im pact an alysis E-mail regarding Adverse Impact E-m ail reg arding Ad verse Imp act m atrix E-m ail reg arding Ad verse Imp act m atrix E-m ail reg arding Ad verse Imp act m atrix

5 / 1 0 /2 0 0 2 1 1 / 7 /2 0 0 2 1 1 / 7 /2 0 0 2 1 0 / 1 2 /2 0 0 1 1 1 / 1 /2 0 0 1 1 1 / 2 /2 0 0 1 1 1 / 2 /2 0 0 1

E-m ail rega rding Adverse Impact E-mail regarding Adverse Impact E-mail regarding adverse impact E-m ail with attache d adverse im pact tem plate E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n W A R N E-m ail reg arding instru ctions from lega l

1 1 / 2 /2 0 0 1 1 1 / 6 /2 0 0 1 1 1 / 1 2 /2 0 0 1 1 1 / 1 1 /2 0 0 2 1 1 / 1 1 /2 0 0 2 1 0 / 7 /2 0 0 2

E-m ail reg arding instru ctions from lega l

1 0 / 8 /2 0 0 2

E-mail regarding instructions from legal E-mail regarding instructions from legal

1 0 / 9 /2 0 0 2 1 0 / 9 /2 0 0 2

E-mail transmitting Adverse Impact spreadsheet E-mail regarding revised templates E-mail regarding advice from legal on RIF action

1 2 / 1 8 /2 0 0 2 1 2 / 1 8 /2 0 0 2 1 0 / 7 /2 0 0 2

AI Full Privilege AI Full Privilege W P Full Privilege AI Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege AI Full Privilege W P Full Privilege W P Full Privilege

35

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 36 of 76

1 2 3 2 9 2 9 -1 2 3 2 9 3 0 1 2 3 2 9 5 7 -1 2 3 2 9 5 8 1 2 3 3 0 1 7 -1 2 3 3 0 1 8

Sheryl Bowlin; Elaine Bishop
Sheryl Bowlin; Do nna Crossw hite
Mari Byrne

Vick ie Sm ith Vick ie Sm ith Janet Larson

1 2 3 3 0 1 9 -1 2 3 3 0 1 9 1 2 3 3 0 2 0 -1 2 3 3 0 2 1 1 2 3 3 1 3 4 -1 2 3 3 1 3 4

Sonja C olbert; Mari Byrne
Eric Rice; Mari Byrne
R enee Finks

Eric Rice Sonja C olbert John Shannon

1 2 3 3 1 3 5 -1 2 3 3 1 3 5

John Shannon

Stacey La bou eff

1 2 3 3 2 0 5 -1 2 3 3 2 0 5

June Hastert

Laurie Reed

1 2 3 3 2 5 5 -1 2 3 3 2 5 5 1 2 3 5 2 1 3 -1 2 3 5 2 1 4

Janet Larson; Do nna Crossw hite
Shirley Fox

Vick ie Sm ith Mari Burger

1 2 3 5 2 4 2 -1 2 3 5 2 4 3

Shirley Fox

Mari Burger

1 2 3 6 5 1 1 -1 2 3 6 5 1 2

Mari Byrne

1 2 3 6 5 6 2 -1 2 3 6 5 6 2

Eric Rice

1 2 3 6 8 3 9 -1 2 3 6 8 3 9

Vic ki H atfield

1 2 3 7 4 9 3 -1 2 3 7 5 3 7 1 2 3 7 5 5 6 -1 2 3 7 5 5 8

Jerry Usry; Mic hael B rill
Mari Burger

Eric Rice Mari Byrne Gene Lampe Greg Cooper Shirley Fox

1 2 3 7 5 7 6 -1 2 3 7 5 8 0 1 2 3 7 7 2 5 -1 2 3 7 7 2 5 1 2 3 7 9 1 7 -1 2 3 7 9 1 8 1 2 3 8 0 6 5 -1 2 3 8 0 6 6 1 2 3 8 0 7 7 -1 2 3 8 0 7 7 1 2 3 8 0 8 3 -1 2 3 8 0 8 3 1 2 3 9 4 5 2 -1 2 3 9 4 5 2 1 2 3 9 5 8 9 -1 2 3 9 5 8 9

Kimberly Klosak; Janet Larson
Ro n Focht; Jill Ferrel
Steven Fergason; Pa trick Hu lla
Ge ne Lam pe; John St. A ngelo
Eric R ice; Scott W inkler
Ge ne Lam pe; Scott W inkler
Mich ael B rill; Ron Focht
Lynn Simpson

Zaidi L o r e n zi -M a t te i Susan Ott Eric Rice Michael Motley Gene Lampe Eric Rice Ron Focht Christy Milroy

E-mail regarding instructions from legal on process checks E-m ail rega rding letter tem plate
E- m ai l r egar di ng notes fr om legal on proc es s c hec k s
E-mail regarding adverse impact analysis

1 0 / 3 0 /2 0 0 1 1 0 / 2 4 /2 0 0 1 7 / 3 0 /2 0 0 2 1 0 / 7 /2 0 0 2

E-mail regarding adverse impact analysis

1 0 / 8 /2 0 0 2

E - m ai l r eg a rd in g ad v ic e f ro m le g al o n PC S disp lace m ents E - m ai l r eg a rd in g ad v ic e f ro m le g al o n PC S disp lace m ents E-mail regarding legal restructure reserve
E-m ail rega rding revise d RIF letter
E-mail with attached spreadsheet for adverse impact an alysis E-mail transmitting spreadsheet for adverse impact an alysis E-mail regarding Adverse Impact lists
E-m ail rega rding Adverse Impact lists
E-m ail rega rding legal analysis of AD EA requirem ents
E-m ail transm itting list for a dverse im pact an alysis

1 / 9 /2 0 0 3 1 / 9 /2 0 0 3 1 / 1 1 /2 0 0 2 1 0 / 3 /2 0 0 1 4 / 2 3 /2 0 0 2 4 / 2 3 /2 0 0 2 1 / 5 /2 0 0 3 1 / 3 /2 0 0 3 1 0 / 4 /2 0 0 1 9 / 2 5 /2 0 0 2

E-mail transmitting spreadsheet reflecting adverse im pact an alysis

2 / 1 4 /2 0 0 2

E-m ail rega rding instructions from legal on RIF in Pu erto Rico

2 / 1 0 /2 0 0 3

E-mail regarding severance plan changes

1 1 / 9 /2 0 0 1

E-mail regarding Dallas impacts E-mail regarding legal advice on 60-day notice

1 2 / 1 0 /2 0 0 2 1 2 / 6 /2 0 0 2

E-m ail rega rding Adverse Impact

1 0 / 7 /2 0 0 1

E-m ail rega rding Adverse Impact

1 0 / 8 /2 0 0 1

E-mail regarding adverse impact analysis

1 0 / 5 /2 0 0 1

E-mail regarding legal review of ECO change

6 / 6 /2 0 0 2

W P Full Privilege A/C Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege A/C Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege

36

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 37 of 76

1 2 4 5 9 7 9 -1 2 4 5 9 8 1 1 2 4 6 0 0 6 -1 2 4 6 0 0 7 1 2 4 8 1 8 9 -1 2 4 8 1 9 0 1 2 6 0 8 7 8 -1 2 6 0 8 7 8 1 2 6 2 7 0 6 -1 2 6 2 7 0 7 1 2 6 2 7 0 8 -1 2 6 2 7 0 9 1 2 6 2 7 1 0 -1 2 6 2 7 1 1 1 2 6 2 7 1 3 -1 2 6 2 7 1 3 1 2 6 3 2 1 0 -1 2 6 3 2 1 0 1 2 6 3 5 1 1 -1 2 6 3 5 1 1 1 2 6 3 5 2 4 -1 2 6 3 5 3 1 1 2 6 3 7 9 8 -1 2 6 3 7 9 8 1 2 6 3 8 2 1 -1 2 6 3 8 2 1 1 2 6 3 8 2 3 -1 2 6 3 8 2 4 1 2 6 3 8 7 0 -1 2 6 3 8 7 1 1 2 6 3 8 8 3 -1 2 6 3 8 8 5 1 2 6 3 9 0 4 -1 2 6 3 9 0 5 1 2 6 3 9 1 8 -1 2 6 3 9 1 8 1 2 6 3 9 9 0 -1 2 6 3 9 9 5 1 2 6 3 9 9 6 -1 2 6 4 0 0 2 1 2 6 4 0 3 3 -1 2 6 4 0 3 7 1 2 6 4 0 3 8 -1 2 6 4 0 4 2 1 2 6 4 0 7 5 -1 2 6 4 0 7 8
1 2 6 4 0 8 2 -1 2 6 4 0 8 2

Mari Byrne
LaQuita Collier
Jan Price
Janet Larson
Da vid M cElligott; Marvin Motley Vonya McCann; Ma rvin Mo tley Vonya McCann; Ma rvin Mo tley Da vidM cElligott; Marvin Motley Janet Larson

Lynn Simpson Kathleen McBee Linda Picke tt Vick ie Sm ith Vonya McCann Da vid M cElligott Da vid M cElligott Janet Larson Scott Jensen

Janet Larson De b Sprayberry

Diane Shoemaker
Janet Larson

Janet Larson; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Sheryl Bowlin; Pa trick Hu lla
Janet Larson

Vick ie Sm ith Vick ie Sm ith Vick ie Sm ith Su zan ne Dris coll Vick ie Sm ith

Sheryl Bowlin; Do nna Crossw hite
Ro n Focht; Jill Fe rrell
Janet Larson

Vick ie Sm ith
Diane Shoemaker Kathryn Larison

Kathryn Larison; Pa trick Hu lla
Janet Larson

Janet Larson Elaine Bishop

Elaine Bishop

Janet Larson

Anthony Byergo; Diane S hoe makerKa tz
Teresa Toal

Anita Edwards Amy Oberkrom

E - m ai l r eg a rd in g le g al i ns tr uc ti on s o n W A R N E-mail regarding adverse impact analysis E-mail regarding legal review of reduction in force E-m ail reg arding adv erse im pact an alysis E-mail regarding summary numbers requested

1 0 / 1 8 /2 0 0 1 2 / 4 /2 0 0 2 1 0 / 3 1 /2 0 0 1 1 0 / 6 /2 0 0 1 1 2 / 1 1 /2 0 0 2

E-mail regarding summary numbers requested

1 2 / 1 1 /2 0 0 2

E-mail regarding summary numbers requested

1 2 / 1 1 /2 0 0 2

E-m ail with ins truction s from legal on summary num bers r e q u e s te d

1 2 / 1 1 /2 0 0 2

E-mail with advice from legal on int Broadband Video R e t e n ti o n

1 1 / 1 9 /2 0 0 2

E-mail regarding involving legal on WA RN act paym ents

2 / 1 2 /2 0 0 2

E-mail with advice from legal on new separation code

2 / 2 6 /2 0 0 2

E-m ail rega rding revise d RIF letter

1 0 / 3 /2 0 0 1

E-mail regarding letter template update

1 0 / 2 4 /2 0 0 1

E- m ai l r egar di ng additional pr oc es s c hec k s

1 0 / 3 0 /2 0 0 1

E- m ai l r egar di ng additional pr oc es s c hec k s

1 0 / 3 0 /2 0 0 1

E-mail regarding instructions from legal on separation plan
E-m ail rega rding letter tem plate

1 2 / 3 /2 0 0 1 1 0 / 2 4 /2 0 0 1

M e m o re g ar di ng W A R N

1 / 8 /2 0 0 2

E-mail regarding explanation from legal on termination in C alifornia
E-m ail reg arding term inations in C alifornia

1 2 / 5 /2 0 0 2 1 2 / 9 /2 0 0 2

E-m ail reg arding instru ctions from lega l on re duction in force
E-m ail reg arding instru ctions from lega l on re duction in force
E-mail regarding separation issue

1 2 / 1 8 /2 0 0 2 1 2 / 1 8 /2 0 0 2 2 / 7 /2 0 0 3

E-mail regarding conference call and decision from legal

2 / 3 /2 0 0 3

W P Full Privilege AI Full Privilege W P Full Privilege AI Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege A/C ; W P Full Privilege W P Full Privilege W P Full Privilege A/C Full Privilege
W P Full Privilege

37

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 38 of 76

1 2 6 4 1 2 1 -1 2 6 4 1 2 1

Sharon Hardy

Ma rissa T hie

1 2 6 4 1 2 2 -1 2 6 4 1 2 4

Sharon Hardy

Ma rissa T hie

1 2 6 4 2 4 1 -1 2 6 4 2 4 1 1 2 6 4 3 9 8 -1 2 6 4 3 9 9 1 2 6 4 9 4 9 -1 2 6 4 9 5 0 1 2 6 4 9 5 1 -1 2 6 4 9 5 2 1 2 6 5 1 1 8 -1 2 6 5 1 1 8 1 2 6 5 3 2 6 -1 2 6 5 3 2 8 1 2 6 5 6 8 5 -1 2 6 5 6 9 0 1 2 7 2 1 6 4 -1 2 7 2 1 6 8

Sheryl Bowlin; Do nna Crossw hite
Vonya McCann; Marvin Motley
Suzanne McVey
Su zan ne McVe y; Ch arles M oore
Tami Keasling; Elle n M artin
Su zan ne Dris coll; Jan Price
Linda Picke tt; Curtis Thornton
Mari Burger

Vick ie Sm ith Bill W hite De nnis Armstrong Da wn Mitchell Sh eryl B ow lin Ma ry Hu ll Jim Hannan Shirley Fox

1 2 8 1 5 3 2 -1 2 8 1 5 3 3

Jed Dodd

Randy Bryson

1 2 8 1 5 4 3 -1 2 8 1 5 4 3

Jerry U sry

Gre gory P iante

1 2 8 1 5 4 6 -1 2 8 1 5 5 0

Jerry U sry

Frank Hickey

1 2 8 1 5 5 1 -1 2 8 1 5 5 1

Jerry U sry

Ga ry Ga rcia

1 2 8 1 5 5 8 -1 2 8 1 5 5 9

Jerry U sry

Ga ry Ga rcia

1 2 8 1 5 6 4 -1 2 8 1 5 6 4

Jerry Usry

Ga ry Ga rcia

1 2 9 5 6 4 8 -1 2 9 5 6 4 8 1 2 9 5 6 4 9 -1 2 9 5 6 4 9

Gre g Coop er; Kim berly Ma ttingly
Jerry U sry

Frank Hickey Ric W alter

1 2 9 5 6 5 0 -1 2 9 5 6 5 0

Jerry U sry

Gre gory P lante

1 2 9 5 6 5 1 -1 2 9 5 6 5 1 1 2 9 5 6 5 2 -1 2 9 5 6 5 2 1 2 9 5 6 5 3 -1 2 9 5 6 5 3 1 2 9 5 6 5 4 -1 2 9 5 6 5 5

Frank Hic ke y; Jerry U sry
CPE Managers; Jerry U sry
Ric W alter; Kim berly Ma ttingly
Jerry U sry

Greg Cooper Frank Hickey Greg Cooper Gre gory P lante

1 2 9 5 6 5 6 -1 2 9 5 6 5 6

Jerry U sry

James Bergner

1 2 9 5 6 5 7 -1 2 9 5 6 5 7

Kim berly Ma ttingly

Frank Hickey

1 2 9 5 6 5 8 -1 2 9 5 6 5 9

Jerry U sry

Ga ry Ga rcia

E-mail regarding action required from legal dept E-mail regarding action required per legal dept E-mail regarding RIF impact on imm igration issues
E-m ail rega rding separation sum mary by state
E-mail regarding adverse impact
E-mail regarding adverse impact
E-mail regarding employees identified at selection meeting E-mail regarding instructions from legal on records c o l le c t io n E-m ail rega rding manp owe r inform ation w ith handwritten notes regarding adverse impact E-m ail reg arding adv erse im pact an alysis E-mail regarding business stack ranking E-mail regarding downsizing information E-m ail transm itting adv erse im pact an alysis CPE Managers E-mail regarding RIF list E-m ail rega rding staffing work sheet CPE Ma na ge rs E -m ail re ga rdin g C en tral Re gio n R IF d o c u m e n t a ti o n E-mail regarding downgrades
E-mail regarding field operations down-sizing E-mail regarding headcount E-mail regarding RIF timing issues
E-m ail reg arding Ad verse Imp act m atrix
E-mail regarding CPE reductions
E-mail regarding downsizing E-mail regarding downsizing E-mail regarding RIF packages E-mail regarding additional RIF list

2 / 5 /2 0 0 3 2 / 1 1 /2 0 0 3 1 0 / 2 4 /2 0 0 1 1 2 / 1 2 /2 0 0 2 2 / 2 0 /2 0 0 2 2 / 2 0 /2 0 0 2 1 0 / 2 8 /2 0 0 1 1 2 / 1 9 /2 0 0 2 1 0 / 5 /2 0 0 1 1 2 / 1 8 /2 0 0 2 8 / 1 6 /2 0 0 2 1 0 / 1 4 /2 0 0 2 1 0 / 1 4 /2 0 0 2 1 0 / 1 1 /2 0 0 2 1 0 / 2 /2 0 0 2 9 / 2 7 /2 0 0 2 1 0 / 1 0 /2 0 0 2 6 / 1 1 /2 0 0 2 7 / 3 /2 0 0 2 1 0 / 9 /2 0 0 2 9 / 2 3 /2 0 0 2 1 0 / 3 1 /2 0 0 2 6 / 1 4 /2 0 0 2 6 / 1 3 /2 0 0 2 1 0 / 2 4 /2 0 0 2 6 / 1 4 /2 0 0 2

W P Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege AI Full Privilege AI Full Privilege A/C Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege A/C Part privileged. A/C Part privileged. AI Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. AI Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged.

38

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 39 of 76

1 2 9 5 7 2 9 -1 2 9 5 7 3 0

Chris Thompson

1 2 9 5 7 6 7 -1 2 9 5 7 6 7

Chris Thompson

1 2 9 5 8 8 3 -1 2 9 5 8 8 3 1 2 9 5 9 2 1 -1 2 9 5 9 2 3

Chris Sharp; De onn a Sharp
Chris Thompson

1 2 9 5 9 4 0 -1 2 9 5 9 4 0 1 2 9 5 9 4 1 -1 2 9 5 9 4 2

Randy Bryson; Margie Paxson
Margie Paxson

1 2 9 5 9 4 6 -1 2 9 5 9 4 8

Russ Highflower

1 2 9 5 9 7 2 -1 2 9 5 9 7 4 1 2 9 6 3 5 8 -1 2 9 6 3 5 8 1 2 9 6 3 6 6 -1 2 9 6 3 6 7 1 2 9 6 5 2 5 -1 2 9 6 5 2 6

Jackie Ashworth; Jerry U sry
Gh eryl G lidewe ll; Jerry B att
Da vid H ank s; Ted Stock
Kimberly Klosak

1 2 9 6 5 3 2 -1 2 9 6 5 3 2 1 2 9 7 0 7 6 -1 2 9 7 0 7 6 1 3 1 5 1 7 4 -1 3 1 5 1 7 5

Kimberly Klosak; Carin McFadden
Ric W alter; Tim Dinsiage
Sarah Urich

1 3 1 5 1 8 7 -1 3 1 5 1 8 8

Renee Finks

1 3 1 5 1 9 2 -1 3 1 5 1 9 3 1 3 1 5 2 0 6 -1 3 1 5 2 0 7 1 3 1 5 3 2 8 -1 3 1 5 3 2 8

Jerry B att; Ron Gier
Cloene Davis; Ch eryl G lidewe ll
Vic ki K olb

1 3 1 5 3 5 5 -1 3 1 5 3 5 5 1315643 1321776 1 3 2 9 5 1 6 -1 3 2 9 5 3 6
1 3 2 9 5 9 5 -1 3 2 9 5 9 6
1 3 3 0 0 2 1 -1 3 3 0 0 2 5 1 3 3 0 0 4 8 -1 3 3 0 0 4 9 1 3 3 0 2 2 5 -1 3 3 0 2 2 9 1 3 3 3 8 6 9 -1 3 3 3 8 6 9 1 3 3 5 4 0 0 -1 3 3 5 4 1 3

Faith Palmer
Renee Finks
Kenna Osburn
Peter Dillon; Chris Thompson
Sara Urich; Jim Hansen
An ne Kin ney; Pa trick Hu lla Janie Simon Chris Thompson Shelly Johnson Julie Nurski

John Shannon Ron Gier Cindy Dove

E-mail regarding pool reductions E-mail regarding activity status sheet E-mail regarding process outlines

Peter Dillon Steve Mueller

E-m ail rega rding realign ment works hee ts E-mail regarding Stack Ranking

Randy Bryson Gina Eisler Frank Hickey

E-m ail rega rding HQ Business S ales & S upp ort E-mail regarding realignment with notes from legal E-mail regarding HR contacts for separation meetings

John Shannon

E-m ail reg arding lega l revie w of poo ls

Lisa Livingston

E-m ail reg arding adv erse im pact an alysis

Kathryn Hanson

E-mail regarding adverse impact

Julie Moylan Linda Mccoy

E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n C A r e q u ir e m e n t
E-mail regarding 2003 budget

Vic ki K olb

E-m ail reg arding adv erse im pact an alysis

Pin chback Ga vin

E-mail regarding legal review

John Shannon

E-mail regarding adverse impact

John Shannon
Mic hael B rill
Kip Downey Lisa Livingston Ne sa He lm Lavonda Anderson John Lauster

E-mail re timing and legal review update with adverse im pact an alysis E-m ail reg arding adv erse im pact an alysis
E-m ail reg arding adv erse im pact an alysis
E-m ail reg arding adv erse im pact an alysis E-mail regarding adverse impact list E-mail regarding access management organizational charts
E-mail regarding adverse impact

1 1 / 4 /2 0 0 2 1 2 / 1 1 /2 0 0 2 1 / 2 8 /2 0 0 3 1 1 / 8 /2 0 0 2 8 / 1 4 /2 0 0 2 1 1 / 1 /2 0 0 2 3 / 2 8 /2 0 0 2 1 0 / 2 4 /2 0 0 2 3 / 2 9 /2 0 0 2 4 / 2 5 /2 0 0 2 1 1 / 2 6 /2 0 0 2 1 2 / 5 /2 0 0 2 9 / 1 9 /2 0 0 2 1 0 / 1 8 /2 0 0 1 1 1 / 7 /2 0 0 2 1 1 / 1 8 /2 0 0 2 9 / 2 0 /2 0 0 2 1 0 / 9 /2 0 0 1 5 / 6 /2 0 0 2 1 0 / 1 5 /2 0 0 2 1 1 / 1 9 /2 0 0 2 3 / 1 0 /2 0 0 3 1 2 / 5 /2 0 0 1

Diane Shoem aker-Katz Janet Larson Peter Dillon Marion W illiams Peter Dillon

E-mail regarding separation plan
E-m ail reg arding list of com petito1330230rs from lega l E-m ail rega rding RIF list E-mail regarding adverse impact analysis E-mail reflecting adverse impact analysis

7 / 1 9 /2 0 0 2
8 / 2 /2 0 0 2 2 / 1 9 /2 0 0 3 3 / 5 /2 0 0 2 1 / 2 4 /2 0 0 3

A/C Full Privilege A/C Full Privilege A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. W P Full Privilege A/C Part privileged. W P Full Privilege AI Full Privilege
AI Full Privilege W P Full Privilege A/C Part privileged.
AI Full Privilege W P Full Privilege AI Full Privilege
AI Part privileged. AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C Full Privilege
AI Full Privilege
A/C Full Privilege W P Full Privilege A/C Full Privilege AI Full Privilege AI Full Privilege

39

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 40 of 76

1 3 3 5 7 0 6 -1 3 3 5 7 0 6 1 3 3 5 7 1 4 -1 3 3 5 7 1 4 1 3 4 0 1 1 9 -1 3 4 0 1 1 9 1 3 4 0 5 5 2 -1 3 4 0 5 5 2 1 3 4 4 4 1 4 -1 3 4 4 4 1 5 1 3 4 6 0 3 2 -1 3 4 6 0 3 3 1 3 4 6 1 5 8 -1 3 4 6 1 5 8 1 3 4 6 1 6 0 -1 3 4 6 1 6 0 1 3 4 6 1 6 2 -1 3 4 6 1 6 2 1 3 4 6 5 0 3 -1 3 4 6 5 0 3
1 3 4 7 5 5 7 -1 3 4 7 5 5 8 1 3 4 7 6 9 9 -1 3 4 7 6 9 9 1 3 4 7 8 1 9 -1 3 4 7 8 2 1
1 3 4 7 9 5 5 -1 3 4 7 9 5 5
1 3 5 1 2 4 2 -1 3 5 1 2 4 2 1 3 5 1 2 4 6 -1 3 5 1 2 4 6 1 3 5 1 2 8 9 -1 3 5 1 2 9 1

Vick ie Sm ith Jan Price Julie Moylan Kimberly Klosak Sarah Urich John Gray Gene Lampe Eric Rice Eric Rice Gene Lampe; Da vid M cElligott Unknown Melanie S chultz Shirley Fox; Tonya Johnston Keith Woods; Tonya Johnston Eric Rice Eric Rice Mic hael M achell

Jan Price Vick ie Sm ith Janet Larson De b Sprayberry Vic ki K olb Eric Rice Eric Rice Co rey Ke pha rt Unknown Eric Rice
Scott Jensen Ch ris Hu bert Scott Jensen

E-m ail rega rding adverse imp act E-mail regarding adverse impact E-mail regarding legal instructions on imm igration E-m ail rega rding adverse imp act E-m ail reg arding adv erse im pact an alysis E-mail regarding adverse impact analysis E-m ail reg arding adv erse im pact an alysis E-m ail rega rding Adverse Impact E-m ail regarding A dverse Impact ma trix E-m ail rega rding Adverse Impact
E-m ail rega rding adverse imp act E-m ail rega rding adverse imp act E-m ail reg arding adv erse im pact an alysis

Scott Jensen
Gene Lampe Gene Lampe Unknown

E-mail regarding impact analysis
E-mail regarding adverse impact analysis E-m ail rega rding Adverse Impact E-m ail rega rding Adverse Impact

1 0 / 4 /2 0 0 1 1 0 / 4 /2 0 0 1 1 1 / 8 /2 0 0 2 1 1 / 4 /2 0 0 2 1 0 / 1 8 /2 0 0 1 1 0 / 1 9 /2 0 0 1 1 0 / 8 /2 0 0 1 1 0 / 1 2 /2 0 0 1 1 0 / 1 4 /2 0 0 1 1 1 / 2 /2 0 0 1
1 0 / 2 5 /2 0 0 2 5 / 3 0 /2 0 0 2 7 / 2 2 /2 0 0 2
3 / 1 2 /2 0 0 2
1 0 / 5 /2 0 0 1 1 0 / 5 /2 0 0 1 4 / 1 4 /2 0 0 3

1 3 5 1 6 4 5 -1 3 5 1 6 4 5 1 3 5 1 7 1 6 -1 3 5 1 7 1 7 1 3 5 1 9 5 7 -1 3 5 1 9 5 7 1 3 5 1 9 7 2 -1 3 5 1 9 7 4 1 3 5 1 9 9 3 -1 3 5 1 9 9 4 1 3 5 2 0 0 6 -1 3 5 2 0 0 7 1 3 5 2 0 2 8 -1 3 5 2 0 2 9 1 3 5 2 0 4 8 -1 3 5 2 0 4 8 1 3 5 2 0 4 9 -1 3 5 2 0 5 0 1 3 5 2 1 0 3 -1 3 5 2 1 0 4 1 3 5 2 1 0 7 -1 3 5 2 1 0 7 1 3 5 2 1 1 3 -1 3 5 2 1 1 5 1 3 5 2 1 2 5 -1 3 5 2 1 2 9 1 3 5 2 1 3 3 -1 3 5 2 1 3 5 1 3 5 2 1 6 8 -1 3 5 2 1 6 8 1 3 5 2 2 0 9 -1 3 5 2 2 0 9 1 3 5 2 5 3 7 -1 3 5 2 5 3 7

Vic ki K olb
Gene Lampe
Eric Rice; Da vid M cElligott
Cody Krause
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Sonja C olbert; Mari Byrne
Sonja C olbert; Mari Byrne
Steven Furgason; Pa trick Hu lla
Steven Furgason; Pa trick Hu lla
Eric R ice; Pa trick Hu lla
Jon Bind er; Tonya Johnston
Shirley Fox; Tonya Johnston
Sharri Evenson; Tonya Johnston
Janet Larson; Marvin Motley
Jen Baughman; Da nnette No rris

Mic hael B rill Cody Krause Gene Lampe

E-mail regarding adverse impact analysis E-mail regarding adverse impact analysis E-m ail rega rding adverse imp act

Gene Lampe Vick ie Sm ith Vick ie Sm ith Vick ie Sm ith Eric Rice

E-m ail with ins truction s from legal on tem plate letter E-mail regarding RIF E-mail regarding RIF E-mail regarding additional process checks E-mail regarding instructions from legal on impacts

Eric Rice

E-mail regarding instructions from legal on impacts

Eric Rice

E-mail regarding RIF clarification

Eric Rice

E-mail regarding down grade justification

Steven Furgason E-mail regarding Dallas impacts

Kip Downey

E-mail regarding RIF process

Shirley Fox

E-mail regarding center closing

Mel Moyer

E-mail regarding revised templates

Da vid M cElligott Bar bre Clar k

E-mail regarding summary numbers request from legal dep t
E-mail regarding advice from legal on military leave

1 0 / 9 /2 0 0 1 1 0 / 1 5 /2 0 0 1 1 1 / 1 /2 0 0 1 1 0 / 1 8 /2 0 0 1 1 0 / 2 6 /2 0 0 1 1 0 / 2 6 /2 0 0 1 1 0 / 3 0 /2 0 0 1 1 0 / 7 /2 0 0 2 1 0 / 7 /2 0 0 2 1 2 / 1 0 /2 0 0 2 1 2 / 1 0 /2 0 0 2 1 2 / 1 0 /2 0 0 2 6 / 2 6 /2 0 0 2 1 2 / 1 9 /2 0 0 2 1 2 / 1 8 /2 0 0 2 1 1 / 1 2 /2 0 0 2 5 / 2 /2 0 0 2

AI Full Privilege AI Full Privilege W P Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege
A/C Full Privilege
AI Full Privilege AI Full Privilege AI P artially p r iv i le g e d . AI Full Privilege AI Full Privilege. AI Full Privilege
W P Full Privilege A/C Full Privilege
A/C Full Privilege
A/C Full Privilege
W P Full Privilege
W P Full Privilege
A/C Full Privilege
A/C Full Privilege
A/C Full Privilege
A/C Full Privilege
A/C Full Privilege
A/C Full Privilege
W P Full Privilege
A/C Full Privilege

40

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 41 of 76

1 3 5 2 5 3 8 -1 3 5 2 5 3 8 1 3 5 2 5 7 2 -1 3 5 2 5 7 3 1 3 5 2 5 7 6 -1 3 5 2 5 7 6 1 3 5 2 5 9 0 -1 3 5 2 5 9 1 1 3 5 2 5 9 4 -1 3 5 2 5 9 5 1 3 5 2 5 9 6 -1 3 5 2 5 9 6
1 3 5 2 5 9 7 -1 3 5 2 5 9 8
1 3 5 2 6 9 1 -1 3 5 2 6 9 1 1 3 5 2 6 9 2 -1 3 5 2 6 9 2 1 3 5 2 6 9 3 -1 3 5 2 6 9 4 1 3 5 2 7 6 1 -1 3 5 2 7 6 5
1 3 5 3 2 8 1 -1 3 5 3 2 8 1 1 3 5 3 4 1 9 -1 3 5 3 4 1 9 1 3 5 3 4 3 4 -1 3 5 3 4 3 5 1 3 5 3 7 4 7 -1 3 5 3 7 4 9 1 3 5 3 7 5 0 -1 3 5 3 7 5 2 1 3 5 6 2 9 8 -1 3 5 6 3 0 0 1 3 5 6 8 4 7 -1 3 5 6 8 4 7 1 3 5 6 8 5 8 -1 3 5 6 8 6 1
1 3 6 3 5 7 7 -1 3 6 3 5 7 7 1 3 6 3 6 7 3 -1 3 6 3 6 7 3 1 3 6 3 6 7 6 -1 3 6 3 6 7 8 1 3 6 5 4 3 4 -1 3 6 5 4 3 5
1 3 6 5 4 3 6 -1 3 6 5 4 3 7
1 3 6 5 4 3 8 -1 3 6 5 4 3 8 1 3 6 5 4 4 0 -1 3 6 5 4 4 0 1 3 6 5 4 4 7 -1 3 6 5 4 4 7
1 3 6 5 7 4 9 -1 3 6 5 7 4 9 1 3 6 5 8 2 5 -1 3 6 5 8 2 5 1 3 6 5 8 3 6 -1 3 6 5 8 3 6 1 3 6 5 8 4 0 -1 3 6 5 8 4 0 1 3 6 5 8 4 3 -1 3 6 5 8 4 3

Jen Baughman; Da nnette No rris Su zan ne Dris coll
Todd Young Debra Aubuchon; John Shannon Deb Aubuchon; Beth Forwald er Renee Finks; Beth Forwalder Tom O`D ea; Jerry B att John Ca mpanelli; Ellen Martin John Ca mpanelli; Elle n M artin John Ca mpanelli; Cin dy B lim John Garcia; Jim Kissinger Julie Moylan
Mic hael B rill; Do nna Crossw hite Sonja A mbur; Janet Larson Janet Larson
Mic hael B rill Ch eryl G lidewe ll
Su zan ne Dris coll Dick G reen; Gene Lampe R enee Finks
Twilla Skelton Christy Milroy
Jon Bind er; Sonja A mbur Lynn Berding; Tim Hearshman John St. Angelo; Tim Hearshman Jon Bind er; Su zan ne Dris coll Sonja A mbur; Tim Hearshman Lavonda Anderson; Beth Forwalder Vic ki H atfield
Da vid M cElligott; Do nna Crossw hite Cody Krause; Do nna Crossw hite Cody Krause

Barbre C lark
Deborah Goddard De borah Godd ard Beth Forwalder
John Shannon
Janet Larson
John Shannon
Cynthia TaylorW right Cynthia TaylorW right Cynthia TaylorW right Ann Rhoads
Janet Larson
Vick ie Sm ith
Mic hael B rill
Mic hael B rill Janie Simon John Shannon De borah Godd ard Suzanne W illiams Lisa Livingston Mic hael M achell Kim Ma ttingly Su zan ne Dris coll
Susan Schen ewe rk Greg Cooper
Pa trick Hu lla
John St. A ngelo
Peter Dillon
Gene Lampe Vick ie Sm ith
Gene Lampe
Gene Lampe

E-mail regarding advice from legal on military leave
E-mail regarding legal advice on separation letters E-mail regarding legal advice on RIF E-mail regarding revised timeline for November action
E-mail regarding revised timeline for November action
E-mail regarding RIF
E- m ai l r egar di ng r esul ts of l egal r evi ew
E-m ail rega rding Adverse Impact
E-m ail rega rding Adverse Impact
E-mail regarding Adverse Impact
E-mail regarding advice from legal on PCS Plans
E-mail regarding advice from legal on immigration i s s u es E-mail regarding W ARN notification
E-mail regarding legal advice on W ARN act
E-m ail rega rding legal advice on W AR N act E-m ail rega rding legal advice on W AR N act E-mail regarding advice from legal on pool reductions E-m ail rega rding legal advice on se paration letters E-mail regarding advice from legal on RIF list
E-mail with adverse impact list E-m ail rega rding adverse imp act rep ort E-mail regarding adverse impact on retirement policy E-mail regarding W ARN com pliance
E-mail regarding RIF in network engineering
E-mail regarding RIF in Network Engineering
E - m ai l r eg a rd in g W A R N
E-mail regarding RIF in network engineering
E-mail regarding instructions from hum an resources on selection process E-m ail rega rding legal analysis of AD EA requirem ents E-mail regarding letter templates
E-mail regarding letter templates
E-m ail reg arding adv erse im pact an alysis

5 / 2 /2 0 0 2 1 1 / 1 4 /2 0 0 1 1 1 / 8 /2 0 0 1 1 0 / 2 6 /2 0 0 2 1 0 / 3 1 /2 0 0 2 1 1 / 5 /2 0 0 2
1 1 / 5 /2 0 0 2
1 1 / 2 9 /2 0 0 1 1 1 / 2 9 /2 0 0 1 1 1 / 2 9 /2 0 0 1 1 0 / 2 2 /2 0 0 1
1 1 / 7 /2 0 0 2 1 0 / 1 0 /2 0 0 1 4 / 1 4 /2 0 0 2 4 / 1 5 /2 0 0 2 4 / 1 5 /2 0 0 2 4 / 1 8 /2 0 0 2 1 1 / 1 4 /2 0 0 1 1 0 / 2 6 /2 0 0 1
1 1 / 1 8 /2 0 0 2 1 0 / 2 9 /2 0 0 1 2 / 2 5 /2 0 0 2 1 / 1 5 /2 0 0 2
5 / 2 0 /2 0 0 2
5 / 1 7 /2 0 0 2 2 / 1 5 /2 0 0 2 5 / 2 0 /2 0 0 2
1 / 1 6 /2 0 0 3 1 0 / 4 /2 0 0 1 1 0 / 1 1 /2 0 0 1 1 0 / 1 1 /2 0 0 1 1 0 / 9 /2 0 0 1

A/C Full Privilege W P Full Privilege W P Full Privilege A/C Full Privilege W P Full Privilege A/C Full Privilege
W P Full Privilege
A/C Full Privilege A/C; AI Full Privilege A/C; AI Full Privilege W P Full Privilege
Full Privilege A/C Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege W P Full Privilege
W P Full Privilege
W P Full Privilege W P Full Privilege W P Full Privilege
A/C Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege AI Full Privilege

41

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 42 of 76

1 3 6 5 8 9 1 -1 3 6 5 8 9 1
1 3 6 5 8 9 2 -1 3 6 5 8 9 2
1 3 6 5 9 6 1 -1 3 6 5 9 6 2
1 3 6 5 9 8 2 -1 3 6 5 9 8 2
1 3 6 6 2 1 5 -1 3 6 6 2 1 6 1 3 6 6 2 1 7 -1 3 6 6 2 1 8
1 3 6 6 2 1 9 -1 3 6 6 2 2 0
1 3 6 6 2 3 3 -1 3 6 6 2 3 4 1 3 6 6 2 3 5 -1 3 6 6 2 3 6 1 3 6 6 2 3 8 -1 3 6 6 2 3 9
1 3 6 6 2 4 0 -1 3 6 6 2 4 0
1 4 0 6 0 6 0 -1 4 0 6 0 6 1
1 4 0 6 5 1 8 -1 4 0 6 5 1 8 1 4 0 6 9 6 5 -1 4 0 6 9 6 5
1 4 1 2 6 4 8 -1 4 1 2 6 5 3
1 4 1 2 6 5 8 -1 4 1 2 6 6 1 1 4 1 2 6 6 2 -1 4 1 2 6 6 6 1 4 1 2 6 6 7 -1 4 1 2 6 6 8
1 4 1 2 7 1 5 -1 4 1 2 7 2 0 1 4 1 2 7 2 1 -1 4 1 2 7 2 2 1 4 1 2 7 7 6 -1 4 1 2 7 7 7 1 4 1 2 7 7 8 -1 4 1 2 7 7 9 1 4 1 2 7 8 0 -1 4 1 2 7 8 1 1 4 1 2 7 8 2 -1 4 1 2 7 8 4 1 4 1 2 7 8 8 -1 4 1 2 7 9 4 1 4 1 2 7 9 5 -1 4 1 2 7 9 6 1 4 1 2 8 0 0 -1 4 1 2 8 0 3
1 4 1 2 8 0 4 -1 4 1 2 8 0 5
1 4 1 2 8 2 0 -1 4 1 2 8 3 2 1 4 1 2 9 3 9 -1 4 1 2 9 4 2 1 4 1 2 9 4 5 -1 4 1 2 9 4 8
1 4 2 2 6 2 6 -1 4 2 2 6 2 6
1 4 2 3 2 0 2 -1 4 2 3 2 0 3
1 4 2 3 6 9 0 -1 4 2 3 6 9 0

Rachel Griebling; Janet Larson Rachel Griebling; Janet Larson Sheryl Bowlin; Do nna Crossw hite Sheryl Bowlin; Do nna Crossw hite Marvin Motley Sonja A mbur; Janet Larson Sonja A mbur; Kenn Blurton Sonja Ambur Sonja Ambur Su zan ne Dris coll; Jon Binder Ro n Focht; Jill Ferrel Eric Rice
Suzanne Mcvey Jon Bind er; Sonja A mbur De b S prayberry; Patrick King Da n Oimetti Da n Oimetti Lisa W atson; Da n Oimetti Pat D`Agostino Pat D`Agostino Pat D`Agostino Pat D`Agostino Pat D`Agostino Kevin Heater Pat D`Agostino Pat D`Agostino Kevin H eater; Bill Esrey De b S prayberry; Bill Esrey Pat D'Agostino Elaine Bishop Joe Vida l; Joan VonderHeide Julie M oylan; De b Sprayberry Pat D`Agostino; De b Sprayberry Gene Lampe; Da vid M cElligott

Vick ie Sm ith
Vick ie Sm ith
Vick ie Sm ith
Vick ie Sm ith
Mic hael B rill Mic hael B rill
Mic hael B rill
Su zan ne Dris coll John St. A ngelo Su zan ne Dris coll
Diane Shoemaker Heather T h o r nd i k e Unknown C a t h e r in e Johnson David Coombs
Michael Wodzisz Michael Wodzisz Craig Ca rroll
De b Sprayberry De b Sprayberry De b Sprayberry De b Sprayberry De b Sprayberry Steve Gerevas De b Sprayberry De b Sprayberry Eric Kle in
Dewey Garner
De b Sprayberry De b Sprayberry De b Sprayberry
Pat D`Agostino
Joan V o n d e r h e id e Eric Rice

E-mail regarding E-grade package information from legal E-mail regarding E-grade packages
E-m ail rega rding letter tem plate
E-m ail rega rding letter tem plate
E - m ai l r eg a rd in g re q ui re m e n ts of W A R N E - m ai l r eg a rd in g re q ui re m e n ts of W A R N
E - m ai l r eg a rd in g re q ui re m e n ts of W A R N
E - m ai l r eg a rd in g re q ui re m e n ts of W A R N E - m ai l r eg a rd in g re q ui re m e n ts of W A R N E-mail regarding W ARN compliance
Mem o regarding W ARN compliance
E-mail regarding Adverse Impact
E-mail regarding adverse impact E-mail regarding W ARN compliance
E-mail transmitting list for adverse impact
E-m ail transm itting list for a dverse im pact an alysis E-m ail atta ching list for a dverse im pact an alysis E-mail transmitting adverse impact list
E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-mail transmitting adverse impact list E-m ail transm itting adv erse im pact an alysis E-mail transmitting adverse impact list
E-m ail transm itting list for a dverse im pact an alysis
E-mail transmitting list for adverse impact E-mail transmitting adverse impact list E-mail regarding director separations
E-mail regarding adverse impact
E-m ail reg arding adv erse im pact an alysis
E-mail regarding Adverse Impact

1 0 / 1 5 /2 0 0 1 1 0 / 1 5 /2 0 0 1 1 0 / 2 4 /2 0 0 1 1 0 / 2 4 /2 0 0 1 1 2 / 1 8 /2 0 0 2 4 / 1 4 /2 0 0 2 4 / 1 3 /2 0 0 2 4 / 1 5 /2 0 0 2 4 / 1 4 /2 0 0 2 1 / 1 8 /2 0 0 2 1 / 8 /2 0 0 2

W P Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege A/C Full Privilege

1 1 / 1 /2 0 0 1
3 / 2 1 /2 0 0 2 1 / 1 5 /2 0 0 2

AI Full Privilege
AI Full Privilege W P Full Privilege

1 1 / 5 /2 0 0 2
1 1 / 3 /2 0 0 2 1 1 / 3 /2 0 0 2 1 1 / 4 /2 0 0 2

AI Full Privilege
AI Full Privilege Full Privilege AI Full Privilege

1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 0 / 1 8 /2 0 0 2 1 1 / 8 /2 0 0 2 1 1 / 5 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

1 1 / 1 /2 0 0 2
1 0 / 1 8 /2 0 0 2 1 / 2 8 /2 0 0 2 2 / 4 /2 0 0 2

AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege

1 1 / 8 /2 0 0 2

AI Full Privilege

1 1 / 8 /2 0 0 2 1 1 / 7 /2 0 0 1

AI Full Privilege AI Full Privilege

42

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 43 of 76

1 4 2 4 0 1 4 -1 4 2 4 0 1 4 1 4 2 4 0 1 8 -1 4 2 4 0 1 9 1 4 2 4 0 2 3 -1 4 2 4 0 2 4 1 4 2 4 0 2 8 -1 4 2 4 0 2 9 1 4 2 4 0 3 5 -1 4 2 4 0 3 5 1 4 2 4 0 3 9 -1 4 2 4 0 4 0 1 4 2 4 0 4 8 -1 4 2 4 0 4 8 1 4 2 4 0 5 2 -1 4 2 4 0 5 2 1 4 2 4 0 5 9 -1 4 2 4 0 5 9 1 4 2 4 0 6 6 -1 4 2 4 0 6 6 1 4 2 4 0 8 0 -1 4 2 4 0 8 0
1 4 2 4 1 1 8 -1 4 2 4 1 1 9
1 4 2 4 1 4 0 -1 4 2 4 1 4 0 1 4 2 4 1 4 4 -1 4 2 4 1 4 5 1 4 2 4 1 4 9 -1 4 2 4 1 5 0 1 4 2 4 1 5 4 -1 4 2 4 1 5 5 1 4 2 4 1 6 3 -1 4 2 4 1 6 3 1 4 2 4 1 7 0 -1 4 2 4 1 7 1
1 4 2 6 7 8 4 -1 4 2 6 7 8 5
1 4 2 6 8 5 8 -1 4 2 6 8 5 8 1 4 2 7 7 3 4 -1 4 2 7 7 3 7
1 4 2 7 7 5 7 -1 4 2 7 7 5 8 1 4 2 8 0 1 5 -1 4 2 8 0 1 5

Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Schultz Melannie Schultz Melannie Schultz H ow ard Bin gh am ; Jen Baughman Keith Woods; Su zan ne Dris coll
Melannie Schultz H ow ard Bin gh am Melannie Schultz Melannie Schultz Melannie Schultz Jen Baughman; Tonya Johnston Steve Debusk; Beth Forwald er De b Sprayberry Kevin H eater; Bill E srey Co rey Ke pha rt De b S prayberry

Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Da nette N orris
Scott Jensen
Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Da nette N orris
Ann Rhoads
Anita Otto Dewey Garner
Gene Lampe Janet Larson

1 4 2 8 2 2 1 -1 4 2 8 2 2 1

Jen Baughman; Tonya Johnston

Danette Norris

Sp readsheet reflecting adv erse im pact an alysis E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-m ail rega rding adverse imp act E-m ail rega rding adverse imp act E-mail regarding adverse impact analysis E-m ail rega rding adverse imp act
E-mail regarding adverse impact analysis
E-mail regarding adverse impact analysis E-mail regarding adverse impact E-mail regarding adverse impact E-m ail rega rding adverse imp act Spreadsheet reflecting adverse impact analysis E-mail regarding selection process
E-mail regarding position elimination
E-mail regarding advice from legal on realignment E-mail transmitting list for adverse impact analysis
E-mail regarding adverse impact analysis E-mail regarding notice period for RIF instructed by leg al E-mail regarding RIF guidelines

5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 1 1 /2 0 0 2 6 / 1 1 /2 0 0 2 6 / 6 /2 0 0 2 6 / 6 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 7 / 3 1 /2 0 0 2
4 / 1 9 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C; AI Full Privilege AI Full Privilege AI Full Privilege
A/C; AI Full Privilege

5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 1 2 /2 0 0 2 8 / 1 /2 0 0 2
4 / 1 7 /2 0 0 2
9 / 1 9 /2 0 0 2 1 1 / 5 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C Full Privilege
A/C Full Privilege
W P Full Privilege AI Full Privilege

1 1 / 1 2 /2 0 0 1 1 / 2 1 /2 0 0 2
8 / 1 /2 0 0 2

AI Full Privilege Full Privilege
A/C Full Privilege

Bates
184552

From
Tina Peek

To
Tasha Reed

Extractions from KC Log D e s c ri p ti o n
e-mail ISSC RIF Preparation-East

1 8 4 5 5 5 - 18 4 5 5 6

Tina Peek

Tasha Reed

e-mail ISSC RIF Preparation-East

1 8 4 5 5 7 - 18 4 5 5 9

Tasha Reed

Mari Burg er

e-mail ISSC RIF Preparation-East

184567

Scott Jensen

Keith Woods

e-m ail Analysis S um mary

43

Date
1 / 6 /2 0 0 3 1 / 6 /2 0 0 3 37628 [sic] 1 / 2 8 /2 0 0 2

P r iv i le g e
W P tran sm its legal advice from legal dept to those responsible for implem enting it
W P tran sm its legal advice from legal dept to those responsible for implem enting it
W P transmits legal advice from legal dept to those responsible for implem enting it
A/C; W P AI a n a l y s is

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 44 of 76

184591 1 8 4 5 9 2 - 18 4 5 9 3
1 8 4 5 9 4 - 18 4 5 9 5 1 8 4 5 9 8 - 18 4 5 9 9 1 8 4 6 0 0 - 18 4 6 0 1 1 8 4 6 0 5 - 18 4 6 0 6 1 8 4 6 0 7 - 18 4 6 0 8 1 8 4 6 0 9 - 18 4 6 1 0 1 8 4 6 1 9 - 18 4 6 2 0
1 8 4 6 4 2 - 18 4 6 4 3 1 8 4 6 4 4 - 18 4 6 4 5 1 8 4 6 4 6 - 18 4 6 4 7
1 8 4 6 4 8 - 18 4 6 4 9 1 8 4 6 5 0 - 18 4 6 5 1 1 8 4 6 5 2 - 18 4 6 5 3
1 8 4 6 5 5 - 18 4 6 5 7 184658

Scott Jensen

Kip Do wn ey

e-mail Analysis Per Our Discussion

Erica Olive r Barb Chapman Lisa Watson
Ch ris Hu bert
Ch ris Hu bert

Kent Pe tit Lisa Watson Lisa Reid Tabitha B ritt
Faith P alm er K ip Downey
Faith Palmer

e -m a il C e n tr al -J u ly 2 0 02 & N ov e m be r 2 0 02 B S S R
e-mail Adverse Impact % - D3G 7-15 e -m a il A d v er se Im p a ct - D 3C D

Ch ris Hu bert

Faith Palmer

e -m a il A d v er se Im p a ct - Ma c D ow e ll - D 3C D

Ch ris Hu bert

Faith P alm er K ip Downey

e-mail Adverse Impact % - D3G 7-15

Ch ris Hu bert .

Faith P alm er K ip Downey

e-mail Adverse Impact % - D3TJ 7-15

Ch ris Hu bert

Faith P alm er K ip Downey

e-mail Adverse Impact % - D3TJ + D3G 7-15

Re becca Ho liday Barb Chapman Lisa Watson

Kevin Kappler De nise Barrett Tim Dusek Kent Pe tit Lisa Watson Lisa Reid Tabitha B ritt

e-mail Documents related to RIF decisions

Lisa Watson Barb Chapman Erica Oliver

Kent Petit Lisa W atson Lisa Reid Tabitha B ritt

e-mail July and November 2002 Realignment work sheets

Barb Chapman

HR personnel

e-mail partial redaction legal dept comm unication

Barb Chapman Lisa Watson

Lisa Watson Lisa Reid Kent Pe tit Tabitha B ritt

e-mail partial redaction legal dept comm unication

Jeanne Boughton Barb Chapman

Lisa Re id Gary Rurup

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (New Orleans Nov. 2002 RIF)

Am y Pe rri Barb Chapman

Lisa Reid

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Southwest Nov. 2002 RIF)

Lisa Reid
Brian Burlinguette Barb Chapman

Lisa Re id

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Califoria Account Executives RIF)

Lisa Reid Chelli Wolford G o l d w a t er
Davette Bates

Lisa Reid
Belinda Barlow Mel Moyer Catherine Davis Tina Peek

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Las Vegas)
e-mail Adverse Impact Updates

4 / 5 /2 0 0 2 1 / 3 1 /2 0 0 3

A/C; W P AI a n a l y s is
A/C; W P

7 / 1 0 /2 0 0 2 5 / 1 0 /2 0 0 2 5 / 2 4 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 1 / 2 4 /2 0 0 3 1 / 2 7 /2 0 0 3

A/C; W P AI a n a l y s is
A/C; W P AI analysis .
A/C; W P AI analysis .
A/C; W P AI analysis .
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C ; W P

1/31 /200 31/2 7/20031 /24/2 003
2 / 5 /2 0 0 3
1 / 2 4 /2 0 0 3 1 / 2 7 /2 0 0 3

A/C; W P
A/C; W P A/C; W P

1 / 2 7 /2 0 0 3 1 / 2 4 /2 0 0 3

A/C; W P

1/27 /200 31/2 4/2003

A/C; W P

1 / 2 4 /2 0 0 3 2 / 5 /2 0 0 3 2 / 6/ 2003
2/11 /200 32/1 3/2003

W ork Comm unication P r iv il eg e W P : comm unication from legal dept and documen ts
A/C; W P

6 / 2 8 /2 0 0 2

A/C; W P AI a n a l y s is

44

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 45 of 76

184659 184881 1 8 4 8 8 6 - 18 4 8 8 7 184908
1 8 4 9 6 2 - 18 4 9 6 3 184973 184974 1 8 4 9 8 6 - 18 4 9 8 7 1 8 4 9 8 8 - 18 4 9 8 9 1 8 4 9 9 0 - 18 4 9 9 1 1 8 5 0 0 2 - 18 5 0 0 3
185194
185210

Davette Bates
Lisa Watson Ann Rhoads De b S prayberry Lisa Watson Barb Chapman Lisa Watson
Chris Hu bert Ch ris Hu bert

Belinda Barlow Mel Moyer Catherine Davis Tina Peek

e-mail Adverse Impact Updates

Ba rbara Chapm an Lisa W atson
De b S prayberry

e-m ail A dverse Im pact A nalysis

Kent Petit Lisa W atson Lisa Reid Tabitha B ritt

e-mail July and November 2002 Realignment W orksheets; partial redaction legal communication

Craig Ca rroll Elisa Piph er
Kathy Gaylord Kevin H eater Steve Smetana Richard Cremona Da niel Olm ett i Edward Aaronson Jayna Anderson Phillip Bowman Bill Esrey

e-mail Feb. 2002 RIF; partial redaction legal comm unication

Faith P alm er K ip Downey

e-mail Adverse Impact Analysis - D3G 7-15

Faith P alm er

e -m a il A d v er se Im p a ct A n a ly si s D E C D

Chris Hu bert

Faith Palmer

e -m a il R e v is e d A d ve rs e Im p a ct A n a ly si s D E C D

Ch ris Hu bert

Faith Palmer

e-mail Adverse Impact Analysis D3G 7-15

Ch ris Hu bert Ch ris Hu bert Roger Parkinson
John St. Angelo Tina Peek

Faith Palmer Kip Downey
Faith P alm er K ip Downey
Kip Do wn ey Tonya Johnston Maggie Beaton B ill B ro ug ha m Denise Fleming Deborah Keating Roger Parkinson Na ncy S hae ffer
Do n H allacy Len Lauer Ma rvin Mo tley Ric W alter Megan Yea rout
Tasha Reed

e -m a i l A d v er se Im p a c t A n a ly si s D 3 T J e-mail Adverse Impact Analysis D3TJ + D3G e-mail Budget Challenge - HR Calculation
e-m ail Summary List e-mail ISSC RIF Preparation-East

7 / 2 /2 0 0 2

A/C; W P AI a n a l y s is

6 / 1 4 /2 0 0 2

A/C; W P AI a n a l y s is

1/24 /200 31/2 7/2003

A/C; W P docum ents ;

2 / 2 1 /2 0 0 2

W P: comm unication from legal dept

7 / 1 0 /2 0 0 2 5 / 1 0 /2 0 0 2 5 / 2 4 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2

A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C: partial r e d a c ti o n

1 0 / 1 2 /2 0 0 1

A/C :partial r e d a c ti o n

1 / 6 /2 0 0 3

A/C :

45

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 46 of 76

1 8 5 2 4 6 - 18 5 2 4 7
185459
185521 185522 185523 185547 185548 1 8 5 7 1 6 - 18 5 7 1 8

Jan Price
Lynn Simpson Vicki Smith
Karin Miller Karin Miller Karin Miller Scott W inkler Gene Lampe Scott W inkler Scott Jensen

Elaine Bishop Ta m m ie C alys Sh aron H ardy Ka ren Ka ck ley Mar gie Linck Kelly Mortenson Alan Nelis
Elaine Tang
Sh eryl B ow lin Kate Fish er
Ma ry Hu ll
Kathi Kerste Janet Larson Karen W indes
Marni Byrne LaQuita Collier Kelly Carlisle Su zan ne Dris coll Kate Fish er Nan cy Fox
Kim Ganote Scott Jensen Tamm i Keasling Vicki Kolb
Cody Krause Gene Lampe Mic hael M achell Michael Marino Da vid M cElligott Jan Price
Elaine Bishop James H ayes Pa trick Hu lla
Jo Renda
Debra Simpson Sarah Urich
Lisa Jameson Janet Larson M ar gie Linck
Mitzi Miller
Jan Schon wette r Teresa Sw arts Karen W indes
Elaine Tang Karen Kackley

e-mail RIF Term Data Process e- m ail Addi ti onal Pr oc es s C hec k s
e-mail PCS R IF List

Elaine Tang Karen Kackley

e-mail PCS R IF List

Elaine Tang Karen Kackley

e-mail PCS R IF List

Gene Lampe
Gene Lampe Scott W inkler Eric Rice
Jon Bind er Sharri Evenson Su zan ne Dris coll

Denton Roberts List )Denton Roberts List Revisions
Sprint E-Solutions Impacted List for ER Review and Comm ents; partial redaction

7 / 1 9 /2 0 0 2

A/C; W P

1 0 / 3 0 /2 0 0 1 1 0 / 3 1 /2 0 0 1

A/C ;

1 / 6 /2 0 0 3

A /C :

1 / 6 /2 0 0 3

A /C :

1 / 6 /2 0 0 3

A/C

1 0 / 1 /2 0 0 1 1 0 / 8 /2 0 0 1

A/C; W P A I A/C; W P

7 / 2 0 /2 0 0 2

A/C ; W P

46

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 47 of 76

1 8 6 4 7 2 - 18 6 4 7 3
187246 188306 188307 188309 188324 188326 188446 188454 1 8 8 4 5 8 - 18 8 4 5 9

Gene Lampe Vicki Smith
Anita Edwards Gene Lampe Scott W inkler Gene Lampe Scott W inkler Gene Lampe Scott W inkler Gene Lampe Scott W inkler Gene Lampe Scott W inkler Eric Rice Davette Bates Ch ris Hu bert

Cody Krause Leon Lang
Da vid M cElligott Su zan ne McVe y Debra Simpson H. Thorndike Marcia Valenzeno Burke W alke r Scott W inkler Sheryl Bowlin Ke lly Ca rlisle Su zan ne Dris coll Kate Fish er Nan cy Fox
Kim Ganote Scott Jensen Tami Keasling Vicki Kolb
Gene Lampe Mic hael M achell Michael Marino Jan Price
Jo Renda
Debra Simpson Lynn Simpson Sarah Urich Elaine Bishop James Hayes Patrick Hulla Lisa Jameson Janet Larson Mitzi Miller Mar gie Linck
Jan Schon wette r Teresa Swarts Karen W indes

Addi ti onal Pr oc es s C hec k s

Justin Crosswhite Denna Bow les

M o rr is S T D

Eric Rice
Scott W inkler Gene Lampe

De nton Roberts Lists

Eric Rice
Scott W inkler Gene Lampe

De nton Roberts Lists

Eric Rice
Scott W inkler Gene Lampe

De nton Roberts Lists

Eric Rice
Scott W inkler Gene Lampe

De nton Roberts Lists

Eric Rice
Scott W inkler Gene Lampe

De nton Roberts Lists

Gene Lampe

Alan Sykes RIF revision after 10 /5/01meeting with Ric hard D evlin

Mel M oyer Belinda Barlow Catherine Davis T i n aP e e k

Adverse Impact

Faith Palmer Kip Downey

Adverse Impact % - D3G 7-15

1 0 / 3 0 /2 0 0 1

A /C :

1 2 / 1 7 /2 0 0 2

A/C; W P

1 0 / 1 /2 0 0 1 1 0 / 7/2001

A/C; WP partial r e d a c ti o n

1 0 / 1 /2 0 0 1 1 0 / 7/2001

A/C; WP partial r e d a c ti o n

1 0 / 1 /2 0 0 1 1 0 / 7/2001

A/C; WP partial r e d a c ti o n

1 0 / 1 /2 0 0 1 1 0 / 7/2001

A/C; WP partial r e d a c ti o n

1 0 / 1 /2 0 0 1 1 0 / 7/2001

A/C; WP partial r e d a c ti o n

1 0 / 8 /2 0 0 1 6 / 2 6 /2 0 0 2
7 / 1 0 /2 0 0 2

A/C; W P AI a n a l y s is
W ork Comm unication P r iv il eg e W P : AI a n a l y s is
A/C; W P AI a n a l y s is

47

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 48 of 76

1 8 8 4 6 0 - 18 8 4 6 1 1 8 8 4 6 2 - 18 8 4 6 3 188467 188468 1 8 8 4 7 1 - 18 8 4 7 2 1 9 1 0 8 1 - 19 1 0 8 3 191186 191206 1 9 1 2 1 8 - 19 1 2 2 0 191221 191222 1 9 1 2 2 3 - 19 1 2 2 7 191228 191229 1 9 1 2 5 7 - 19 1 2 6 0 191262 191263 191264 191265 1 9 1 3 1 3 - 19 1 3 1 8 1 9 1 3 1 9 - 19 1 3 4 0 191385 1 9 1 4 1 4 - 19 1 4 1 6
1 9 1 4 3 5 - 19 1 4 4 2

Ch ris Hu bert
Ch ris Hu bert
Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert
unknown unknown unknown unknown unknown unknown Kim Ma ttingly John Carter unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown

Faith Palmer Kip Downey Faith Palmer Kip Downey Faith Palmer
Faith Palmer
Faith Palmer Kip Downey unknown unknown unknown
unknown
unknown
unknown
Chip W oods
unknown
unknown
unknown
unknown
unknown
unknown unknown unknown unknown
unknown unknown

unknown

unknown

Adverse Impact % - D3TJ 7-15

7 / 1 0 /2 0 0 2

Adverse Impact % - D3TJ + D3G 7-15

7 / 1 0 /2 0 0 2

A d v er se Im p a ct - Ma c D ow e ll - D 3C D A d v er se Im p a ct - D 3C D Adverse Impact % - D3G 7-15

5 / 2 4 /2 0 0 2 5 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2

handwritte n no tes Litiga tion file

unknown

table with handwritten notes related to notice of litigation unk now n

handwritte n no tes re 7/2 2/2002 m eeting with Tim Hearshman (SL)

unknown

han dwritten notes em ployee com pariso ns related to notice of litigation

7 / 1 8 /2 0 0 2

typed docum ent employee com pariso ns related to notice of litigation

unknown

handwritten notes either written by Tim Hearshman (SL)or taken from meeting with Tim Hearshman(SL)

7 / 2 2 /2 0 0 1

fax handwritten notes from m eeting with employee related to notice of litigation

7 / 1 9 /2 0 0 2

table inform ation to conduct AI ana lysis; related to notice of litigation

unknown

table w ith han dwritten notes ha ndw ritten notes re employee comparison related to notice of litigation

unknown

handwritten notes handwritten notes prepared for meeting with Tim Hearshman (SL)

1 0 / 1 7 /2 0 0 2

handwritten notes handwritten notes prepared for meeting with Tim Hearshman (SL)

unknown

table with handwritten notes from m eeting with legal dept

unknown

table with handwrittennotes from m eeting with legal dept unk now n

table for meeting with legal dept

unknown

notes from m eeting with legal dept

unknown

handwritten notes re employee comparison and ratings from m eeting with legal dept

1 0 / 1 7 /2 0 0 2

han dwritten notes ha ndw ritten notes re O sam a Ata

6 / 6 /2 0 0 2

employee job data printout and handwritten notes handwritten notes from conversation with Elaine Tang (SL)

4 / 1 6 /2 0 0 2

typed S um m ary typed Su m m ary of Un ity II AAR S urvey: partial redaction legal review

5 / 8 /2 0 0 2

A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is A/C; W P A/C; W P A/C; W P
A/C; W P
A/C; W P
A/C; W P
A/C; W P
A/C ; W P ;
A/C ; W P ;
A/C; W P
A/C; W P
A/C; W P
A/C; W P A/C; W P A/C; W P A/C; W P
A/C; W P A/C; W P
A/C; W P

48

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 49 of 76

1 9 1 5 9 1 - 19 1 5 9 3
191696 191722 1 9 2 6 0 8 - 19 2 6 1 1
1 9 2 6 1 3 - 19 2 6 1 5
192621 1 9 2 6 6 4 - 19 2 6 6 9 192710 192736 192737

Gre g Coop er Charles W arren Mic hael M achell
unknown unknown Jan Price
Jan Price
unknown Gre g Coop er unknown unknown unknown

Kim Ma ttingly Jody Brann Mic hael M achell Greg Cooper Terry Allan Frank DeNap Re nee Keffer Charles W arren Gayle Bayes John Montross David Flessas Sandy Skeels Terry Madden James Jennings James Charlton Richard Berger Kevin Gardiner Ga ry Fow ler M ike Hendr icks Jody Luce Gary Davis Ed W alke Joseph Roach W illiam Brid ges Janie Simon Louise Elrod Ann Poehler Mic hael B rill
unknown
unknown
Sonja A mbur Jon Binder Mic hael B rill Gre g Coop er Su zan ne Dris coll Cathy Johnson Gene Lampe Sho em aker-Katz Megan Yea rout Marvin Motley Pam Johnson
Sonja A mbur Jon Binder Mic hael B rill Gre g Coop er Su zan ne Dris coll Cathy Johnson Gene Lampe Sho em aker-Katz Megan Yea rout Marvin Motley Pam Johnson
unknown
Paula Zuzich
unknown
unknown
unknown

e-mails and survey Unity II After Action Review and Survey: Only legal review of survey redacted
handwritten notes re legal review handwritte n no tes from con versation with Tim Hearshman (SL) Meeting Notes: legal strategy redacted
Meeting Notes: legal strategy redacted
handwritten notes containing legal advice fax Immigration docum ents from legal dept with handwritten notes handwritten notes with question for legal dept redacted han dwritten notes ad verse im pact analysis with handwritten notes han dwritten notes ad verse im pact analysis with handwritten notes

4/25 /200 24/2 9/2002

A/C; W P

5 / 9 /2 0 0 2 unknown
7 / 9 /2 0 0 2

A/C; W P A/C; W P
A/C; W P

7 / 9 /2 0 0 2

A/C; W P

7 / 8 /2 0 0 2 7 / 1 8 /2 0 0 2
unknown unknown
unknown

A/C; W P A/C ; W P
A/C A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is

49

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 50 of 76

1 9 2 8 9 0 - 19 2 9 1 2 1 9 2 9 1 3 - 19 2 9 1 9 1 9 2 9 2 0 - 19 2 9 3 4 1 9 2 9 3 5 - 19 2 9 4 1 1 9 2 9 7 0 - 19 2 7 9 6 1 9 2 9 7 7 - 19 2 9 8 8 1 9 3 1 6 8 - 19 3 1 7 1 1 9 3 1 7 2 - 19 3 1 8 1 1 9 3 1 8 2 - 19 3 1 8 4 1 9 3 1 8 5 - 19 3 1 8 8 1 9 3 1 8 9 - 19 3 1 9 3 1 9 3 1 9 4 - 19 3 1 9 8

Kathy Losbaugh unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown

Anthony Krueck Kimberly Klosak Carin McFadden unknown unknown
unknown unknown
unknown
unknown
unknown unknown unknown unknown unknown

e-mail adverse impact analysis and table comparing employees with handwritten notes; partial redaction social security num bers
adverse impact analysis handwritten notes notes on table listing em ployee s; partial redac tion so cial security num bers
spreadsheet and handwritten notes adverse impact ana lysis and table com paring em ployee s with han dwritten notes; pa rtial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes
spreadsheet and handwritten notes adverse impact ana lysis and table com paring em ployee s with han dwritten notes; pa rtial redaction social secu rity num bers
spreadsheet and handwritten notes adverse impact ana lysis and table com paring em ployee s with han dwritten notes; pa rtial redaction social secu rity num bers
spreadsheet and handwritten notes adverse impact ana lysis and table com paring em ployee s with han dwritten notes; pa rtial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes; partial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes; partial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes; partial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes; partial redaction social secu rity num bers
handwritte n no tes adv erse im pact an alysis and table comparing employees with handwritten notes; partial redaction social secu rity num bers

3 / 1 3 /2 0 0 2 unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown

A/C; W P AI a n a l y s is
A/C; W P AI an alysis
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is
A/C; W P AI a n a l y s is

50

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 51 of 76
APPENDIX 3 - DOCUMENTS LISTED BUT NOT IN PRIVILEGE LOGS
1063544-1063546 1064612-1064615 1065219 1069223 1070737 1070738-1070768 1113498-1113500 1139825-1139825 1139918-1139919 1140239-1140241 1140279-1140279 1140280-1140282 1140349-1140351 1140356-1140358 1140406-1140410 1140633-1140635 1140636-1140637 1140863-1140864 1141501-1141501 1141564 1141636-1141637 1141657-1141659 1141695-1141698 1144951-1144951 1156827-1156831 1158630-1158664 1158665-1158823 1189183-1189224
51

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 52 of 76
1205559-1205560 1205561-1205561 1211274-1211274 1226861-1226861 1237596-1237599 1248254-1248254 1263405-1263407 1263554-1263554 1263881-1263882 1263945-1263946 1265288-1265292 12653291265329 1265345-1265346 1269330-1269330 1281614 1281616 1281619-1281621 1281622 1281642 1281647 1281662 1281663 1281666-1281669 1281670-1281673 1281674 1281675-1281679 1291540-1291541 1292137 1292139 1292142-1292146
52

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 53 of 76
1295185-1295187 1295188 1295190-1295192 1295662 1295663 1295664 1295665-1295666 1295667 1295668-1295669 1295670 1295671-1295673 1295674 1295675 1295676 1295677 1295678 1295706 1295978 1295979 1296328-1296329 1296370-1296372 1296819-1296835 1296836-1296842 1297155-1297156 1297226-1297227 1302305 1302310 1315204-1315205 1315232-1315233 1315244-1315245
53

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 54 of 76
1315643-1315643 1315796-1315797 1315822-1315823 1329468-1329469 1329537-1329540 1329639-1329642 1329643 1329644-1329648 1329649-1329655 1329710-1329713 1329722-1329726 1329937 1330064 1330068-1330069 1330070-1330071 1330072 1330074-1330076 1330230-1330233 1335367-1335375 1338636-1338639 1338640 1338641-1338645 1340448-1340450 1341617-1341619 1351231 1351257-1351258 1351618-1351624 1351625-1351631 1352105-1352106 1353283 1353291
54

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 55 of 76
1353363-1353364 1353533-1353536 1365361-1365363 1365364-1365365 1365399-1365400 1365403-1365404 1365511-1365512 1365864-1365865 1365946 1413049 1413067-1413068 1413094 1413121 1413158 1413185 1413188 1413191 1413200 1413229 1413236 1413265-1413266 1413269 1413284-1413285 1413286 1427062-1427063 1427065-1427066 1427722 1427740 1428098 1428099-1428100 1428117-1428118
55

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 56 of 76
1428271-1428272 1428273 1428274-1428276 1428538-1428539 1450367 1454498-1454500 1455666-1455667 1455923 1456008 1456009 1456011 1456013 1460854 1460859 1460881 1460882 1460883 1460894 1460910-1460911 1460999-1461000 1461022 1461023-1461025 1461033-1461034 1461095-1461096 1461164-1461165 1461253-1461303
56

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 57 of 76

APPENDIX 4 - ADVERSE IMPACT ANALYSIS DOCUMENTS

Bates
1 0 0 0 0 1 3 -1 0 0 0 0 1 3 1 0 0 0 0 2 6 -1 0 0 0 0 3 9 1 0 0 0 0 4 0 -1 0 0 0 0 7 4 1 0 0 0 1 2 2 -1 0 0 0 1 2 3 1 0 0 0 1 3 3 -1 0 0 0 1 9 1 1 0 0 0 2 0 4 -1 0 0 0 2 1 9 1 0 0 0 2 2 0 -1 0 0 0 2 7 8 1 0 0 9 9 0 8 -1 0 0 9 9 0 8 1 0 1 3 5 2 4 -1 0 1 3 5 2 5 1 0 2 0 9 9 8 -1 0 2 0 9 9 8 1 0 3 4 2 2 9 -1 0 3 4 2 2 9 1 0 6 2 2 4 5 -1 0 6 2 2 4 5 1 0 6 2 2 4 7 -1 0 6 2 2 4 7 1 0 6 2 3 1 8 -1 0 6 2 3 1 8 1 0 6 2 3 1 9 -1 0 6 2 3 2 0 1 0 6 2 3 2 1 -1 0 6 2 3 2 2 1 0 6 2 3 2 3 -1 0 6 2 3 2 4 1 0 6 2 3 4 1 -1 0 6 2 3 4 3 1 0 6 2 5 2 5 -1 0 6 2 5 2 7 1 0 6 2 5 2 8 -1 0 6 2 5 3 1 1 0 6 2 6 3 2 -1 0 6 2 6 4 1 1 0 6 5 2 1 8 -1 0 6 5 2 1 8 1 0 7 0 0 9 9 -1 0 7 0 1 0 1

To
None None Gre g Coop er T er ry Yor k None None None Melannie Schultz Lynn Simpson Sh eryl B ow lin Kate Fish er Mic hael M achell Mic hael M achell Melannie Schultz Melannie Schultz Melannie Schultz Melannie Schultz Melannie Schultz De b S prayberry De b S prayberry Unknown Sarah Urich Eric Rice

1 0 7 0 1 4 0 -1 0 7 0 1 4 0 1 0 8 3 9 6 3 -1 0 8 3 9 6 3 1 0 8 3 9 6 4 -1 0 8 3 9 6 4 1 1 4 0 3 6 5 -1 1 4 0 3 7 3
1 1 4 0 3 8 2 -1 1 4 0 3 8 6

Karin Miller Sheryl Bowlin Sheryl Bowlin John Shannon; Renee Finks Renee Finks

1 1 5 8 3 8 6 -1 1 5 8 3 8 7

Kimberly Klosak

8/12/2005 Log

From
Unknown Unknown Peter Dillon Peter Dillon Unknown Unknown Unknown Ch ris Hu bert Janet Gonzales Jan Price Mic hael M achell Jeffry Chavez Louise Elrod Ch ris Hu lbert Ch ris Hu lbert Ch ris Hu bert Ch ris Hu bert Hu bert, Ch ris Suzan S inclair Suzan S inclair Unknown Jim McNaughton Steve Furgason Pa trick Hu lla Susan W aldron Linda Picke tt Linda Picke tt Carrie Rothove
John Shannon
Da n C hojnack i

Description
Tem plate reflecting AI analysis Spreadsheet reflecting AI Analysis AI analysis sp readsheet E - m ai l tr an s m it ti ng sp re a ds h ee ts re A I AI Analysis Spreadsheet AI analysis for network director selection AI analysis for network director selection E-m ail transmitting AI A nalysis Spreadsheet E-m ail reg arding Ad verse Imp act ana lysis E-mail transmitting AI Analysis spreadsheet E-m ail transm itting Ad verse Imp act Ma trix E-m ail reflecting Ad verse Imp act An alysis E-m ail reflecting Ad verse Imp act An alysis E-m ail reflecting Ad verse Imp act An alysis E-mail reflecting Adverse Impact E-mail reflecting Adverse Impact E-mail reflecting Adverse Impact E-m ail reflecting Ad verse Imp act An alysis E-m ail transmitting adverse im pact sprea dsheet E-m ail transm itting adv erse im pact an alysis spreadsheet showing adverse impact analysis E-mail regarding Adverse Impact E-m ail rega rding Dallas im pacts
E-m ail reflecting adv erse im pact an alysis E-m ail reflecting adv erse im pact an alysis E-mail identifying list for adverse impact analysis E-mail regarding list of legal pools and reasons for adverse impact an alysis E-mail regarding legal lists with pools and reasons for adverse impact an alysis E-mail regarding adverse impact analysis

Date
0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 2 / 1 9 /0 3 1 2 / 4 /0 2 0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 2 / 3 /0 3 5 / 2 4 /0 2 1 1 / 2 2 /2 0 0 2 1 0 / 3 0 /2 0 0 1 4 / 8 /2 0 0 2 3 / 9 /2 0 0 2 3 / 8 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 7 /2 0 0 2 0 0 0 0 - 0 0 -0 0 1 1 / 7 /2 0 0 2 0 0 0 0 - 0 0 -0 0 2 / 5 /2 0 0 2 1 2 / 1 0 /2 0 0 2

Reason
AI Full Privilege AI Full Privilege AI Part Privileged AI Full Privilege AI Part Privileged AI Part Privileged AI Part Privileged AI Full Privilege AI Full Privilege AI/ W P Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C Full Privilege

1 / 2 9 /2 0 0 3 1 0 / 1 5 /2 0 0 1 1 0 / 1 5 /2 0 0 1 4 / 1 /2 0 0 2 4 / 3 /2 0 0 2 6 / 2 4 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege
AI Full Privilege
AI Full Privilege

57

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 58 of 76

1 1 9 1 3 9 0 -1 1 9 1 3 9 0 1 1 9 3 7 1 7 -1 1 9 3 7 1 7

Shirley Fox; Linda Abbet
Ron Focht

1 1 9 3 7 1 8 -1 1 9 3 7 1 8

Dick S um mers

1 1 9 9 4 7 9 -1 1 9 9 4 7 9 1 2 0 5 5 0 7 -1 2 0 5 5 1 0 1 2 0 5 5 2 0 -1 2 0 5 5 2 3 1 2 0 5 5 4 3 -1 2 0 5 5 4 3

John St. Angelo; Kate Fisher
Faith Palmer; Kip Downey
Faith Palmer; Kip Downey
Faith Palmer

1 2 0 5 6 0 2 -1 2 0 5 6 0 2

De b Sprayberry

1 2 0 5 6 0 4 -1 2 0 5 6 0 4

De b Sprayberry

1 2 0 9 7 8 8 -1 2 0 9 7 8 8 1 2 1 0 1 7 7 -1 2 1 0 1 7 8

Cody Krause; Co rey Ke pha rt
Debra Simpson

1 2 1 0 2 2 7 -1 2 1 0 2 2 8

Eric Rice

1 2 1 0 2 5 3 -1 2 1 0 2 5 3 1 2 1 0 2 9 6 -1 2 1 0 2 9 6

Gene Lampe Da vid M cElligott
Cody Krause

1 2 1 0 4 2 7 -1 2 1 0 4 2 7

Gene Lampe

1 2 1 1 4 9 7 -1 2 1 1 4 9 9

Kenn Blurton

1 2 1 1 7 1 8 -1 2 1 1 7 1 9

Justin Cro ssw hite

1 2 1 4 2 9 5 -1 2 1 4 2 9 5

Lynn Stange

1 2 3 3 0 1 9 -1 2 3 3 0 1 9 1 2 3 3 0 2 0 -1 2 3 3 0 2 1 1 2 3 5 2 1 3 -1 2 3 5 2 1 4

Sonja C olbert; Mari Byrne
Eric Rice; Mari Byrne
Shirley Fox

1 2 3 5 2 4 2 -1 2 3 5 2 4 3

Shirley Fox

1 2 3 6 5 1 1 -1 2 3 6 5 1 2

Mari Byrne

1 2 3 6 5 6 2 -1 2 3 6 5 6 2

Eric Rice

1 2 3 7 4 9 3 -1 2 3 7 5 3 7

Jerry Usry; Mic hael B rill

Jerry Harris
Da nette N orris Da nette N orris Ric W alter Ch ris Hu bert
Ch ris Hu bert
Ch ris Hu bert Joan V o n d e r h e id e Joan V o n d e r h e id e Eric Rice Eric Rice Gene Lampe Eric Rice
Eric Rice Eric Rice Ric W alter Julie Moylan Adriane Hacke tt Eric Rice
Sonja C olbert
Mari Burger Mari Burger Eric Rice Mari Byrne Greg Cooper

E-m ail rega rding revise d adverse im pact analysis repo rt

1 1 / 1 2 /2 0 0 1

E-mail regarding Adverse Impact on distribution center a s s o c ia t e s E-mail regarding Adverse Impact on distribution center r e d u c ti o n E-mail regarding adverse impact
E-mail regarding adverse impact

4 / 2 4 /2 0 0 2 4 / 2 4 /2 0 0 2 1 1 / 1 1 /2 0 0 1 7 / 1 0 /2 0 0 2

E-mail regarding adverse impact

7 / 1 0 /2 0 0 2

E-mail regarding adverse impact E-mail regarding adverse impact review E-m ail reg arding adv erse im pact an alysis E-mail regarding Adverse Impact E-m ail reg arding Ad verse Imp act m atrix E-m ail reg arding Ad verse Imp act m atrix E-m ail reg arding Ad verse Imp act m atrix

5 / 1 0 /2 0 0 2 1 1 / 7 /2 0 0 2 1 1 / 7 /2 0 0 2 1 0 / 1 2 /2 0 0 1 1 1 / 1 /2 0 0 1 1 1 / 2 /2 0 0 1 1 1 / 2 /2 0 0 1

E-m ail rega rding Adverse Impact E-mail regarding Adverse Impact E-mail regarding adverse impact E-m ail with attache d adverse im pact tem plate E-mail transmitting Adverse Impact spreadsheet E-mail regarding adverse impact analysis

1 1 / 2 /2 0 0 1 1 1 / 6 /2 0 0 1 1 1 / 1 2 /2 0 0 1 1 1 / 1 1 /2 0 0 2 1 2 / 1 8 /2 0 0 2 1 0 / 7 /2 0 0 2

E-mail regarding adverse impact analysis

1 0 / 8 /2 0 0 2

E-mail with attached spreadsheet for adverse impact an alysis E-mail transmitting spreadsheet for adverse impact an alysis E-mail regarding Adverse Impact lists
E-m ail rega rding Adverse Impact lists
E-m ail transm itting list for a dverse im pact an alysis

4 / 2 3 /2 0 0 2 4 / 2 3 /2 0 0 2 1 / 5 /2 0 0 3 1 / 3 /2 0 0 3 9 / 2 5 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

58

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 59 of 76

1 2 3 7 5 5 6 -1 2 3 7 5 5 8

Mari Burger

1 2 3 7 9 1 7 -1 2 3 7 9 1 8 1 2 3 8 0 7 7 -1 2 3 8 0 7 7 1 2 3 8 0 8 3 -1 2 3 8 0 8 3 1 2 3 9 4 5 2 -1 2 3 9 4 5 2 1 2 4 6 0 0 6 -1 2 4 6 0 0 7 1 2 6 0 8 7 8 -1 2 6 0 8 7 8 1 2 6 4 9 4 9 -1 2 6 4 9 5 0

Steven Fergason; Pa trick Hu lla
Eric R ice; Scott W inkler
Ge ne Lam pe; Scott W inkler
Mich ael B rill; Ron Focht
LaQuita Collier
Janet Larson
Suzanne McVey

1 2 6 4 9 5 1 -1 2 6 4 9 5 2 1 2 6 5 6 8 5 -1 2 6 5 6 9 0 1 2 7 2 1 6 4 -1 2 7 2 1 6 8

Su zan ne McVe y; Ch arles M oore
Linda Picke tt; Curtis Thornton
Mari Burger

Shirley Fox Eric Rice Gene Lampe
Eric Rice
Ron Focht
Kathleen McBee Vick ie Sm ith De nnis Armstrong Da wn Mitchell Jim Hannan Shirley Fox

E-mail transmitting spreadsheet reflecting adverse im pact an alysis E-mail regarding Dallas impacts
E-m ail rega rding Adverse Impact
E-m ail rega rding Adverse Impact
E-mail regarding adverse impact analysis
E-mail regarding adverse impact analysis E-m ail reg arding adv erse im pact an alysis E-mail regarding adverse impact
E-mail regarding adverse impact
E-m ail rega rding manp owe r inform ation w ith handwritten notes regarding adverse impact E-m ail reg arding adv erse im pact an alysis

1 2 8 1 5 4 6 -1 2 8 1 5 5 0

Jerry U sry

Frank Hickey

E-m ail transm itting adv erse im pact an alysis

1 2 9 5 6 5 2 -1 2 9 5 6 5 2 1 2 9 6 3 6 6 -1 2 9 6 3 6 7 1 2 9 6 5 2 5 -1 2 9 6 5 2 6

CPE Managers; Jerry U sry
Da vid H ank s; Ted Stock
Kimberly Klosak

Frank Hickey

E-m ail reg arding Ad verse Imp act m atrix

Lisa Livingston

E-m ail reg arding adv erse im pact an alysis

Kathryn Hanson

E-mail regarding adverse impact

1 3 1 5 1 7 4 -1 3 1 5 1 7 5

Sarah Urich

Vic ki K olb

E-m ail reg arding adv erse im pact an alysis

1 3 1 5 1 9 2 -1 3 1 5 1 9 3 1 3 1 5 2 0 6 -1 3 1 5 2 0 7 1 3 1 5 3 2 8 -1 3 1 5 3 2 8

Jerry B att; Ron Gier
Cloene Davis; Ch eryl G lidewe ll
Vic ki K olb

John Shannon John Shannon Mic hael B rill

E-mail regarding adverse impact
E-mail re timing and legal review update with adverse im pact an alysis E-m ail reg arding adv erse im pact an alysis

1 3 1 5 3 5 5 -1 3 1 5 3 5 5 1315643 1321776 1 3 2 9 5 9 5 -1 3 2 9 5 9 6
1 3 3 3 8 6 9 -1 3 3 3 8 6 9 1 3 3 5 4 0 0 -1 3 3 5 4 1 3 1 3 3 5 7 0 6 -1 3 3 5 7 0 6 1 3 3 5 7 1 4 -1 3 3 5 7 1 4 1 3 4 0 5 5 2 -1 3 4 0 5 5 2 1 3 4 4 4 1 4 -1 3 4 4 4 1 5

Faith Palmer
Renee Finks Kenna Osburn Sara Urich; Jim Hansen
Shelly Johnson Julie Nurski Vick ie Sm ith Jan Price Kimberly Klosak Sarah Urich

Kip Downey Lisa Livingston Ne sa He lm John Lauster

E-m ail reg arding adv erse im pact an alysis E-m ail reg arding adv erse im pact an alysis E-mail regarding adverse impact list E-mail regarding adverse impact

Marion W illiams Peter Dillon Jan Price Vick ie Sm ith De b Sprayberry Vic ki K olb

E-mail regarding adverse impact analysis E-mail reflecting adverse impact analysis E-m ail rega rding adverse imp act E-mail regarding adverse impact E-m ail rega rding adverse imp act E-m ail reg arding adv erse im pact an alysis

2 / 1 4 /2 0 0 2 1 2 / 1 0 /2 0 0 2 1 0 / 7 /2 0 0 1 1 0 / 8 /2 0 0 1 1 0 / 5 /2 0 0 1 2 / 4 /2 0 0 2 1 0 / 6 /2 0 0 1 2 / 2 0 /2 0 0 2 2 / 2 0 /2 0 0 2 1 0 / 5 /2 0 0 1 1 2 / 1 8 /2 0 0 2 1 0 / 1 4 /2 0 0 2 9 / 2 3 /2 0 0 2 4 / 2 5 /2 0 0 2
1 1 / 2 6 /2 0 0 2 1 0 / 1 8 /2 0 0 1 1 1 / 1 8 /2 0 0 2 9 / 2 0 /2 0 0 2 1 0 / 9 /2 0 0 1 5 / 6 /2 0 0 2 1 0 / 1 5 /2 0 0 2 1 1 / 1 9 /2 0 0 2 1 2 / 5 /2 0 0 1

AI Full Privilege A/C Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Part privileged. AI Part privileged. AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Part privileged. AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

3 / 5 /2 0 0 2 1 / 2 4 /2 0 0 3 1 0 / 4 /2 0 0 1 1 0 / 4 /2 0 0 1 1 1 / 4 /2 0 0 2 1 0 / 1 8 /2 0 0 1

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

59

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1 3 4 6 0 3 2 -1 3 4 6 0 3 3 1 3 4 6 1 5 8 -1 3 4 6 1 5 8 1 3 4 6 1 6 0 -1 3 4 6 1 6 0 1 3 4 6 1 6 2 -1 3 4 6 1 6 2 1 3 4 6 5 0 3 -1 3 4 6 5 0 3
1 3 4 7 5 5 7 -1 3 4 7 5 5 8 1 3 4 7 6 9 9 -1 3 4 7 6 9 9 1 3 4 7 8 1 9 -1 3 4 7 8 2 1
1 3 4 7 9 5 5 -1 3 4 7 9 5 5
1 3 5 1 2 4 2 -1 3 5 1 2 4 2 1 3 5 1 2 4 6 -1 3 5 1 2 4 6 1 3 5 1 2 8 9 -1 3 5 1 2 9 1 1 3 5 1 6 4 5 -1 3 5 1 6 4 5 1 3 5 1 7 1 6 -1 3 5 1 7 1 7 1 3 5 1 9 5 7 -1 3 5 1 9 5 7
1 3 5 2 1 1 3 -1 3 5 2 1 1 5
1 3 5 2 6 9 1 -1 3 5 2 6 9 1
1 3 5 2 6 9 2 -1 3 5 2 6 9 2
1 3 5 2 6 9 3 -1 3 5 2 6 9 4
1 3 6 3 5 7 7 -1 3 6 3 5 7 7 1 3 6 3 6 7 3 -1 3 6 3 6 7 3 1 3 6 3 6 7 6 -1 3 6 3 6 7 8 1 3 6 5 8 4 3 -1 3 6 5 8 4 3 1 4 0 6 0 6 0 -1 4 0 6 0 6 1

John Gray Gene Lampe Eric Rice Eric Rice Gene Lampe; Da vid M cElligott Unknown Melanie S chultz Shirley Fox; Tonya Johnston Keith Woods; Tonya Johnston Eric Rice Eric Rice Mic hael M achell Vic ki K olb Gene Lampe Eric Rice; Da vid M cElligott Eric R ice; Pa trick Hu lla John Ca mpanelli; Ellen Martin John Ca mpanelli; Elle n M artin John Ca mpanelli; Cin dy B lim Renee Finks Twilla Skelton Christy Milroy Cody Krause Eric Rice

1 4 0 6 5 1 8 -1 4 0 6 5 1 8 1 4 1 2 6 4 8 -1 4 1 2 6 5 3
1 4 1 2 6 5 8 -1 4 1 2 6 6 1 1 4 1 2 6 6 2 -1 4 1 2 6 6 6 1 4 1 2 6 6 7 -1 4 1 2 6 6 8
1 4 1 2 7 1 5 -1 4 1 2 7 2 0 1 4 1 2 7 2 1 -1 4 1 2 7 2 2 1 4 1 2 7 7 6 -1 4 1 2 7 7 7 1 4 1 2 7 7 8 -1 4 1 2 7 7 9 1 4 1 2 7 8 0 -1 4 1 2 7 8 1 1 4 1 2 7 8 2 -1 4 1 2 7 8 4 1 4 1 2 7 8 8 -1 4 1 2 7 9 4 1 4 1 2 7 9 5 -1 4 1 2 7 9 6 1 4 1 2 8 0 0 -1 4 1 2 8 0 3

Suzanne Mcvey De b S prayberry; Patrick King Da n Oimetti Da n Oimetti Lisa W atson; Da n Oimetti Pat D`Agostino Pat D`Agostino Pat D`Agostino Pat D`Agostino Pat D`Agostino Kevin Heater Pat D`Agostino Pat D`Agostino Kevin H eater; Bill Esrey

Eric Rice Eric Rice Co rey Ke pha rt Unknown Eric Rice
Scott Jensen Ch ris Hu bert Scott Jensen

E-mail regarding adverse impact analysis E-m ail reg arding adv erse im pact an alysis E-m ail rega rding Adverse Impact E-m ail regarding A dverse Impact ma trix E-m ail rega rding Adverse Impact
E-m ail rega rding adverse imp act E-m ail rega rding adverse imp act E-m ail reg arding adv erse im pact an alysis

Scott Jensen
Gene Lampe Gene Lampe Unknown Mic hael B rill Cody Krause Gene Lampe

E-mail regarding impact analysis
E-mail regarding adverse impact analysis E-m ail rega rding Adverse Impact E-m ail rega rding Adverse Impact E-mail regarding adverse impact analysis E-mail regarding adverse impact analysis E-m ail rega rding adverse imp act

Steven Furgason E-mail regarding Dallas impacts

Cynthia TaylorW right Cynthia TaylorW right Cynthia TaylorW right Lisa Livingston
Mic hael M achell
Kim Ma ttingly
Gene Lampe
Heather T h o r nd i k e Unknown
David Coombs

E-m ail rega rding Adverse Impact
E-m ail rega rding Adverse Impact
E-mail regarding Adverse Impact
E-mail with adverse impact list E-m ail rega rding adverse imp act rep ort E-mail regarding adverse impact on retirement policy E-m ail reg arding adv erse im pact an alysis E-mail regarding Adverse Impact
E-mail regarding adverse impact E-mail transmitting list for adverse impact

Michael Wodzisz Michael Wodzisz Craig Ca rroll

E-m ail transm itting list for a dverse im pact an alysis E-m ail atta ching list for a dverse im pact an alysis E-mail transmitting adverse impact list

De b Sprayberry De b Sprayberry De b Sprayberry De b Sprayberry De b Sprayberry Steve Gerevas De b Sprayberry De b Sprayberry Eric Kle in

E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-m ail transm itting list for a dverse im pact an alysis E-mail transmitting adverse impact list E-m ail transm itting adv erse im pact an alysis E-mail transmitting adverse impact list

1 0 / 1 9 /2 0 0 1 1 0 / 8 /2 0 0 1 1 0 / 1 2 /2 0 0 1 1 0 / 1 4 /2 0 0 1 1 1 / 2 /2 0 0 1
1 0 / 2 5 /2 0 0 2 5 / 3 0 /2 0 0 2 7 / 2 2 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege

3 / 1 2 /2 0 0 2
1 0 / 5 /2 0 0 1 1 0 / 5 /2 0 0 1 4 / 1 4 /2 0 0 3 1 0 / 9 /2 0 0 1 1 0 / 1 5 /2 0 0 1 1 1 / 1 /2 0 0 1

A/C Full Privilege
AI Full Privilege AI Full Privilege AI Part Privileged. AI Full Privilege AI Full Privilege. AI Full Privilege

1 2 / 1 0 /2 0 0 2

A/C Full Privilege

1 1 / 2 9 /2 0 0 1
1 1 / 2 9 /2 0 0 1
1 1 / 2 9 /2 0 0 1
1 1 / 1 8 /2 0 0 2 1 0 / 2 9 /2 0 0 1 2 / 2 5 /2 0 0 2 1 0 / 9 /2 0 0 1 1 1 / 1 /2 0 0 1
3 / 2 1 /2 0 0 2 1 1 / 5 /2 0 0 2
1 1 / 3 /2 0 0 2 1 1 / 3 /2 0 0 2 1 1 / 4 /2 0 0 2

A/C Full Privilege
A/C; AI Full Privilege
A/C; AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege
AI Full Privilege AI Full Privilege
AI Full Privilege Full Privilege AI Full Privilege

1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 1 / 5 /2 0 0 2 1 0 / 1 8 /2 0 0 2 1 1 / 8 /2 0 0 2 1 1 / 5 /2 0 0 2

AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

60

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 61 of 76

1 4 1 2 8 0 4 -1 4 1 2 8 0 5
1 4 1 2 8 2 0 -1 4 1 2 8 3 2 1 4 1 2 9 3 9 -1 4 1 2 9 4 2 1 4 2 2 6 2 6 -1 4 2 2 6 2 6
1 4 2 3 2 0 2 -1 4 2 3 2 0 3
1 4 2 3 6 9 0 -1 4 2 3 6 9 0
1 4 2 4 0 1 4 -1 4 2 4 0 1 4 1 4 2 4 0 1 8 -1 4 2 4 0 1 9 1 4 2 4 0 2 3 -1 4 2 4 0 2 4 1 4 2 4 0 2 8 -1 4 2 4 0 2 9 1 4 2 4 0 3 5 -1 4 2 4 0 3 5 1 4 2 4 0 3 9 -1 4 2 4 0 4 0 1 4 2 4 0 4 8 -1 4 2 4 0 4 8 1 4 2 4 0 5 2 -1 4 2 4 0 5 2 1 4 2 4 0 5 9 -1 4 2 4 0 5 9 1 4 2 4 0 6 6 -1 4 2 4 0 6 6 1 4 2 4 0 8 0 -1 4 2 4 0 8 0
1 4 2 4 1 1 8 -1 4 2 4 1 1 9
1 4 2 4 1 4 0 -1 4 2 4 1 4 0 1 4 2 4 1 4 4 -1 4 2 4 1 4 5 1 4 2 4 1 4 9 -1 4 2 4 1 5 0 1 4 2 4 1 5 4 -1 4 2 4 1 5 5 1 4 2 4 1 6 3 -1 4 2 4 1 6 3 1 4 2 7 7 3 4 -1 4 2 7 7 3 7
1 4 2 7 7 5 7 -1 4 2 7 7 5 8

De b S prayberry; Bill Esrey Pat D'Agostino Elaine Bishop Julie M oylan; De b Sprayberry Pat D`Agostino; De b Sprayberry Gene Lampe; Da vid M cElligott Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Sc hultz Melannie Schultz Melannie Schultz Melannie Schultz H ow ard Bin gh am ; Jen Baughman Keith Woods; Su zan ne Dris coll
Melannie Schultz H ow ard Bin gh am Melannie Schultz Melannie Schultz Melannie Schultz Kevin H eater; Bill E srey Co rey Ke pha rt

Dewey Garner
De b Sprayberry De b Sprayberry Pat D`Agostino
Joan V o n d e r h e id e Eric Rice
Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Da nette N orris
Scott Jensen
Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Dewey Garner
Gene Lampe

E-m ail transm itting list for a dverse im pact an alysis
E-mail transmitting list for adverse impact E-mail transmitting adverse impact list E-mail regarding adverse impact
E-m ail reg arding adv erse im pact an alysis
E-mail regarding Adverse Impact
Sp readsheet reflecting adv erse im pact an alysis E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-mail regarding adverse impact E-m ail rega rding adverse imp act E-m ail rega rding adverse imp act E-mail regarding adverse impact analysis E-m ail rega rding adverse imp act
E-mail regarding adverse impact analysis
E-mail regarding adverse impact analysis E-mail regarding adverse impact E-mail regarding adverse impact E-m ail rega rding adverse imp act Spreadsheet reflecting adverse impact analysis E-mail transmitting list for adverse impact analysis
E-mail regarding adverse impact analysis

1 1 / 1 /2 0 0 2
1 0 / 1 8 /2 0 0 2 1 / 2 8 /2 0 0 2 1 1 / 8 /2 0 0 2

AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege

1 1 / 8 /2 0 0 2
1 1 / 7 /2 0 0 1
5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 1 1 /2 0 0 2 6 / 1 1 /2 0 0 2 6 / 6 /2 0 0 2 6 / 6 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 7 / 3 1 /2 0 0 2
4 / 1 9 /2 0 0 2
5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 5 / 3 0 /2 0 0 2 6 / 1 2 /2 0 0 2 1 1 / 5 /2 0 0 2

AI Full Privilege
AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege A/C; AI Full Privilege AI Full Privilege AI Full Privilege
A/C; AI Full Privilege
AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege AI Full Privilege

1 1 / 1 2 /2 0 0 1

AI Full Privilege

Bates
184594184595
184598184599
184600184601
184605184606
184607184608

From Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert .

To Faith Palmer , Kip Downey Faith Palmer Faith Palmer Faith Palmer , Kip Downey Faith Palmer , Kip Downey

KC Privilege Log
D e s c r i p ti o n e -m a il A d ve rs e Im p a ct % - D 3 G , 7-15 e -m a il A d v er se Im p a ct - D 3C D

Da te 7 / 1 0 /2 0 0 2
5 / 1 0 /2 0 0 2

e-m ail A dverse Im pact - MacDo we ll - D 3C D ,

5 / 2 4 /2 0 0 2

e -m a il A d ve rs e Im p a ct % - D 3 G , 7-15

7 / 1 0 /2 0 0 2

e-mail Adverse Impact % - D3TJ, 7-15

7 / 1 0 /2 0 0 2

Reason
A/C; WP ; AI analysis gathered at request of legal dept
A/C; WP ; AI analysis prepared at request of legal de pt.
A/C; WP ; AI analysis gathered at request of legal de pt.
A/C; WP ; AI analysis prepared at request of legal de pt.
A/C; WP ; AI analysis gathered at request of legal dept

61

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 62 of 76

184609184610 184658
184659
184881
184962184963 184973
184974
184986184987 184988184989 184990184991 188446
188454

Ch ris Hu bert Davette Bates Davette Bates Lisa Watson , Ann Rhoads, Deb Sp rayberry Chris Hu bert Ch ris Hu bert Chris Hu bert Ch ris Hu bert Ch ris Hu bert Ch ris Hu bert Eric Rice
Davette Bates Attorn ey/Client

Faith Palmer , Kip Downey
Belinda B arlow , Mel M oyer, Cather ine Davis , TinaPeek Belinda B arlow , Mel M oyer, Cather ine Davis , Tina Peek Barbara Chapm an , Lisa W atson , De b S prayberry
Faith Palmer , Kip Downey
Faith P alm er
Faith Palmer
Faith Palmer
Faith P alm er , K ip D ow ney
Faith Palmer , Kip Downey
Gene Lampe
M el Moyer , Belinda Barlow, Cather ine Davis TinaPeek

e-mail Adverse Impact % - D3TJ + D3G, 7-15
e-mail Adverse Impact Updates
e-mail Adverse Impact Updates
e-m ail A dverse Im pact A nalysis
e-mail Adverse Impact Analysis D3G, 7-15
e-m ail A dverse Im pact A nalysis DECD
e-mail Revised Adverse Impact A n a ly si s D E C D
e-m ail A dverse Im pact A nalysis D3G, 7-15
e-m ail A dverse Im pact A nalysis D3TJ
e-m ail A dverse Im pact A nalysis D3TJ + D3G
e-mail re Alan Sykes RIF revision after 10 /5/01meeting with R ichard De vlin
Adverse Impact

7 / 1 0 /2 0 0 2 6 / 2 8 /2 0 0 2 7 / 2 /2 0 0 2 6 / 1 4 /2 0 0 2
7 / 1 0 /2 0 0 2 5 / 1 0 /2 0 0 2 5 / 2 4 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 1 0 / 8 /2 0 0 1
6 / 2 6 /2 0 0 2

188458188459
188460188461
188462188463
188467
188468

Ch ris Hu bert
Ch ris Hu bert
Ch ris Hu bert
Ch ris Hu bert Fa ith Pa lm er Ch ris Hu bert

Faith Palmer , Kip Downey Faith Palmer , Kip Downey Faith Palmer , Kip Downey
Faith Palmer

Adverse Impact % - D3G, 7-15

7 / 1 0 /2 0 0 2

Adverse Impact % - D3TJ, 7-15

7 / 1 0 /2 0 0 2

A d ve rs e Im p a ct % - D 3 T J + D 3G , 7-15
Ad verse Imp act - Ma cD ow ell D3CD
A d v er se Im p a ct - D 3C D

7 / 1 0 /2 0 0 2 5 / 2 4 /2 0 0 2 5 / 1 0 /2 0 0 2

188471188472
191228

Ch ris Hu bert unknown

192736

unknown

192737

unknown

192890192912

Kathy Losbaugh

Faith Palmer , Kip Downey unknown
unknown unknown An thony K rueck , Kim berly Klosak , Carin McFadden

Adverse Impact % - D3G, 7-15

7 / 1 0 /2 0 0 2

table inform ation g athered to conduct AI ana lysis; related to notice of litigation
handwritten notes adverse impact analysis with handwritten notes
handwritten notes adverse impact analysis with handwritten notes
e-mail adverse impact analysis and table c om paring em ployee s with handwritten notes; partial redaction of soc ial security num bers

unknown unknown unknown 3 / 1 3 /2 0 0 2

A/C; WP ; AI analysis gathered at request of legal dept
A/C; WP ; AI analysis gathered at request of legal dept
A/C; WP ; AI analysis gathered at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis gathered at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C; W P; AI A nalysis
W o rk C o m m u ni ca ti on P ri vi le g e W P : AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C ; W P; n otes pre pared in anticipation of litigation; prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel

62

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 63 of 76

192913192919

unknown

192920192934

unknown

192935192941

unknown

192970192796

unknown

192977192988

unknown

193168193171

unknown

193172193181

unknown

193182193184

unknown

193185193188

unknown

193189193193

unknown

193194193198

unknown

unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown

adverse impact analysis, handwritte n no tes, notes on ta ble listing employees; partial redaction of soc ial security num bers
spreadsheet and handwritten notes adverse impact an alysis and table com paring em ployee s with handwritten notes; partial redaction of soc ial security num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes
spreadsheet and handwritten notes adverse impact an alysis and table com paring em ployee s with handwritten notes; partial redaction of soc ial security num bers
spreadsheet and handwritten notes adverse impact an alysis and table com paring em ployee s with handwritten notes; partial redaction of soc ial security num bers
spreadsheet and handwritten notes adverse impact an alysis and table com paring em ployee s with handwritten notes; partial redaction of soc ial security num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes; partial redaction of social secu rity num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes; partial redaction of social secu rity num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes; partial redaction of social secu rity num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes; partial redaction of social secu rity num bers
handwritten notes adverse impact analysis and table comparing employees with handwritten notes; partial redaction of social secu rity num bers

unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown unknown

A/C ; W P; A I ana lysis
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of legal counsel
A/C; WP ; AI analysis prepared at request of le gal cou nsel;
A/C; WP ; AI analysis prepared at request of le gal cou nsel;
A/C; WP ; AI analysis prepared at request of le gal cou nsel;
A/C; WP ; AI analysis prepared at request of le gal cou nsel;

63

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 64 of 76

APPENDIX 5 - “LEGAL” DOCUMENTS

Bates
1 0 2 0 5 8 0 -1 0 2 0 5 8 1

To
Kate Fish er

From
Mic hael M achell

1 0 2 1 3 7 1 -1 0 2 1 3 7 1

Kate Fisher

1 0 5 0 8 1 0 -1 0 5 0 8 7 7

Angie Foltz

1 0 6 2 3 5 3 -1 0 6 2 3 5 3 1 0 6 4 2 4 0 -1 0 6 4 2 4 0 1 0 7 0 2 9 8 -1 0 7 0 2 9 9

Shelley Porter Nan cy Fox Sonja A mbur

1 0 7 0 5 1 4 -1 0 7 0 5 1 4

Ma ynard D anny

1 1 3 0 3 9 5 -1 1 3 0 3 9 7

Faith Palmer

Greg Cooper Mic hael B rill
Lisa Lieb Twilla Skelton
De b Godd ard
Unknown
Mic hael B rill Kenn Blurton
Colby Gilson Trinder Betsy
Kip Do wn ey

1 1 4 0 3 6 0 -1 1 4 0 3 6 4

Renee Finks

Ca rrie R othye

1 1 5 6 9 1 0 -1 1 5 6 9 1 1 1 1 5 7 3 5 8 -1 1 5 7 3 5 9

Joan Vanderhelde; Susan Cheney
Mic hael B rill

Rick Mears Mic hael M achell

1 1 5 8 3 8 9 -1 1 5 8 3 8 9 1 1 8 8 9 2 6 -1 1 8 8 9 2 7

Shirley Fox; Suzy Keolling
Linda Picke tt

1 2 0 5 5 0 2 -1 2 0 5 5 0 3

Faith Palmer

Janet Larson
Sonja A mburH a r t le y Kip Downey

1 2 0 5 5 1 1 -1 2 0 5 5 1 2

Faith Palmer

Kip Downey

1 2 1 1 7 2 0 -1 2 1 1 7 2 2

Justin Cro ssw hite

Julie Moylan

1 2 1 1 9 0 0 -1 2 1 1 9 0 0 1 2 1 1 9 0 1 -1 2 1 1 9 0 2 1 2 1 1 9 0 5 -1 2 1 1 9 0 6

Sonja C olbert; Mari Byrne
Eric R ice; Mari Byrne
Sonja C olbert

Eric Rice Sonja C olbert Eric Rice

1 2 1 1 9 0 7 -1 2 1 1 9 0 8 1 2 3 2 8 6 9 -1 2 3 2 8 7 0

Eric R ice; Mari Byrne
Mari Byrne

Sonja C olbert Eric Rice

1 2 3 2 9 2 9 -1 2 3 2 9 3 0

Sheryl Bowlin; Elaine Bishop

Vick ie Sm ith

8/12/2005 Privilege Log
Description
E-mail giving legal advice to HR regarding how to treat e m p lo ye es on LO A E-mail re: advice from legal on separation of employee

Date
1 1 / 7 /2 0 0 1
4 / 1 1 /2 0 0 2

Reason
W P Full Privilege
W P Full Privilege

E-mail containing legal advice on severance information 5/1/2002

A/C Full Privilege

E-m ail re: RIF instruc tions from legal dept E-m ail rega rding legal review update E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n W A R N requirem ents
E-mail re instructions from legal on policy waiver request E-mail regarding savings worksheet for finance and instructions from legal spreadsheet prepared for lega l revie w and e-m ail
E-mail regarding instructions from legal on records c o l le c t io n E-mail regarding legal review changes
E - m ai l r eg a rd in g re s po n se fr om l eg a l o n W A R N

5 / 2 2 /2 0 0 2 0 0 0 0 - 0 0 -0 0 4 / 1 3 /2 0 0 2

A/C Part Privileged
W P Full Privilege
A/C ; W P F ull P r i v il e g e

1 2 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2

A/C ; W P F ull P r i v il e g e
W P Part Privileged

3 / 2 8 /2 0 0 2 1 2 / 2 6 /2 0 0 2

A/C , W P F ull P r i v il e g e
W P Full Privilege

4 / 1 0 /2 0 0 2 9 / 6 /2 0 0 2

W P Full Privilege W P Full Privilege

E-mail regarding legal review on RIFs

2 / 9 /2 0 0 3

W P Full Privilege

E-m ail reg arding bud get cha llenge and note s from lega l E-mail regarding budget and notes from legal E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n W A R N E-m ail reg arding instru ctions from lega l

7 / 1 0 /2 0 0 2 7 / 1 0 /2 0 0 2 1 1 / 1 1 /2 0 0 2 1 0 / 7 /2 0 0 2

W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege

E-m ail reg arding instru ctions from lega l

1 0 / 8 /2 0 0 2

W P Full Privilege

E-mail regarding instructions from legal E-mail regarding instructions from legal

1 0 / 9 /2 0 0 2 1 0 / 9 /2 0 0 2

W P Full Privilege W P Full Privilege

E-mail regarding advice from legal on RIF action
E-mail regarding instructions from legal on process checks

1 0 / 7 /2 0 0 2 1 0 / 3 0 /2 0 0 1

W P Full Privilege W P Full Privilege

64

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 65 of 76

1 2 3 3 0 1 7 -1 2 3 3 0 1 8

Mari Byrne

1 2 3 3 1 3 4 -1 2 3 3 1 3 4

R enee Finks

1 2 3 3 1 3 5 -1 2 3 3 1 3 5

John Shannon

1 2 3 3 2 0 5 -1 2 3 3 2 0 5

June Hastert

1 2 3 6 8 3 9 -1 2 3 6 8 3 9

Vic ki H atfield

1 2 3 7 5 7 6 -1 2 3 7 5 8 0 1 2 3 8 0 6 5 -1 2 3 8 0 6 6 1 2 3 9 5 8 9 -1 2 3 9 5 8 9

Kimberly Klosak; Janet Larson
Ge ne Lam pe; John St. A ngelo
Lynn Simpson

1 2 4 5 9 7 9 -1 2 4 5 9 8 1

Mari Byrne

1 2 4 8 1 8 9 -1 2 4 8 1 9 0

Jan Price

1 2 6 2 7 1 3 -1 2 6 2 7 1 3 1 2 6 3 2 1 0 -1 2 6 3 2 1 0

Da vidM cElligott; Marvin Motley
Janet Larson

1 2 6 3 5 1 1 -1 2 6 3 5 1 1

Janet Larson

1 2 6 3 5 2 4 -1 2 6 3 5 3 1

De b Sprayberry

1 2 6 3 8 8 3 -1 2 6 3 8 8 5

Janet Larson

1 2 6 3 9 9 0 -1 2 6 3 9 9 5

Janet Larson

1 2 6 4 0 3 3 -1 2 6 4 0 3 7

Janet Larson

1 2 6 4 0 3 8 -1 2 6 4 0 4 2

Elaine Bishop

1 2 6 4 0 8 2 -1 2 6 4 0 8 2

Teresa Toal

1 2 6 4 1 2 1 -1 2 6 4 1 2 1

Sharon Hardy

1 2 6 4 1 2 2 -1 2 6 4 1 2 4

Sharon Hardy

1 2 6 5 3 2 6 -1 2 6 5 3 2 8 1 2 9 5 9 4 6 -1 2 9 5 9 4 8

Su zan ne Dris coll; Jan Price
Russ Highflower

1 2 9 6 3 5 8 -1 2 9 6 3 5 8 1 2 9 6 5 3 2 -1 2 9 6 5 3 2

Gh eryl G lidewe ll; Jerry B att
Kimberly Klosak; Carin McFadden

Janet Larson John Shannon Stacey La bou eff Laurie Reed Gene Lampe Zaidi L o r e n zi -M a t te i Michael Motley
Christy Milroy Lynn Simpson Linda Picke tt Janet Larson Scott Jensen Diane Shoemaker Janet Larson Vick ie Sm ith Kathryn Larison Elaine Bishop Janet Larson Amy Oberkrom Ma rissa T hie Ma rissa T hie Ma ry Hu ll Gina Eisler John Shannon Julie Moylan

E- m ai l r egar di ng notes fr om legal on proc es s c hec k s

7 / 3 0 /2 0 0 2

E - m ai l r eg a rd in g ad v ic e f ro m le g al o n PC S disp lace m ents

1 / 9 /2 0 0 3

E - m ai l r eg a rd in g ad v ic e f ro m le g al o n PC S disp lace m ents

1 / 9 /2 0 0 3

E-mail regarding legal restructure reserve

1 / 1 1 /2 0 0 2

E-m ail rega rding legal analysis of AD EA requirem ents

1 0 / 4 /2 0 0 1

E-m ail rega rding instructions from legal on RIF in Pu erto Rico

2 / 1 0 /2 0 0 3

E-mail regarding legal advice on 60-day notice

1 2 / 6 /2 0 0 2

W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege

E-mail regarding legal review of ECO change

6 / 6 /2 0 0 2

E - m ai l r eg a rd in g le g al i ns tr uc ti on s o n W A R N

1 0 / 1 8 /2 0 0 1

E-mail regarding legal review of reduction in force

1 0 / 3 1 /2 0 0 1

E-m ail with ins truction s from legal on summary num bers r e q u e s te d

1 2 / 1 1 /2 0 0 2

E-mail with advice from legal on Broadband Video R e t e n ti o n

1 1 / 1 9 /2 0 0 2

E-mail regarding involving legal on WA RN act paym ents

2 / 1 2 /2 0 0 2

E-mail with advice from legal on new separation code

2 / 2 6 /2 0 0 2

E-mail regarding instructions from legal on separation plan

1 2 / 3 /2 0 0 1

E-mail regarding explanation from legal on termination in C alifornia

1 2 / 5 /2 0 0 2

E-m ail reg arding instru ctions from lega l on re duction in force

1 2 / 1 8 /2 0 0 2

E-m ail reg arding instru ctions from lega l on re duction in force

1 2 / 1 8 /2 0 0 2

E-mail regarding conference call and decision from legal

2 / 3 /2 0 0 3

E-mail regarding action required from legal dept

2 / 5 /2 0 0 3

E-mail regarding action required per legal dept

2 / 1 1 /2 0 0 3

E-mail regarding instructions from legal on records c o l le c t io n

1 2 / 1 9 /2 0 0 2

E-mail regarding realignment with notes from legal

3 / 2 8 /2 0 0 2

E-m ail reg arding lega l revie w of poo ls

3 / 2 9 /2 0 0 2

W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege

E - m ai l r eg a rd in g in s tr uc ti on s f ro m le g al o n C A r e q u ir e m e n t

1 2 / 5 /2 0 0 2

W P Full Privilege

65

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 66 of 76

1 3 1 5 1 8 7 -1 3 1 5 1 8 8

R enee Finks

1 3 3 0 0 4 8 -1 3 3 0 0 4 9 1 3 4 0 1 1 9 -1 3 4 0 1 1 9 1 3 5 1 9 7 2 -1 3 5 1 9 7 4 1 3 5 2 0 4 8 -1 3 5 2 0 4 8
1 3 5 2 0 4 9 -1 3 5 2 0 5 0
1 3 5 2 2 0 9 -1 3 5 2 2 0 9 1 3 5 2 5 3 7 -1 3 5 2 5 3 7 1 3 5 2 5 3 8 -1 3 5 2 5 3 8 1 3 5 2 5 7 2 -1 3 5 2 5 7 3 1 3 5 2 5 7 6 -1 3 5 2 5 7 6 1 3 5 2 5 9 4 -1 3 5 2 5 9 5 1 3 5 2 5 9 7 -1 3 5 2 5 9 8
1 3 5 2 7 6 1 -1 3 5 2 7 6 5
1 3 5 3 2 8 1 -1 3 5 3 2 8 1

Janie Simon
Julie Moylan Cody Krause
Sonja C olbert; Mari Byrne Sonja C olbert; Mari Byrne Janet Larson; Marvin Motley Jen Baughman; Da nnette No rris Jen Baughman; Da nnette No rris Su zan ne Dris coll
Todd Young Deb Aubuchon; Beth Forwald er Tom O`D ea; Jerry B att John Garcia; Jim Kissinger Julie Moylan

1 3 5 3 4 3 4 -1 3 5 3 4 3 5
1 3 5 3 7 4 7 -1 3 5 3 7 4 9 1 3 5 3 7 5 0 -1 3 5 3 7 5 2 1 3 5 6 2 9 8 -1 3 5 6 3 0 0 1 3 5 6 8 4 7 -1 3 5 6 8 4 7 1 3 5 6 8 5 8 -1 3 5 6 8 6 1
1 3 6 5 8 2 5 -1 3 6 5 8 2 5 1 3 6 5 8 9 1 -1 3 6 5 8 9 1
1 4 2 6 8 5 8 -1 4 2 6 8 5 8 1 4 2 8 0 1 5 -1 4 2 8 0 1 5

Sonja A mbur; Janet Larson Janet Larson Mic hael B rill Ch eryl G lidewe ll Su zan ne Dris coll Dick G reen; Gene Lampe Vic ki H atfield Rachel Griebling; Janet Larson De b Sprayberry De b S prayberry

Pin ch ba ck , Ga vin E-mail regarding legal review

Janet Larson Janet Larson Gene Lampe Eric Rice

E-m ail reg arding list of com petitors from lega l E-mail regarding legal instructions on imm igration E-m ail with ins truction s from legal on tem plate letter E-mail regarding instructions from legal on impacts

1 1 / 7 /2 0 0 2 8 / 2 /2 0 0 2 1 1 / 8 /2 0 0 2 1 0 / 1 8 /2 0 0 1 1 0 / 7 /2 0 0 2

W P Full Privilege
W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege

Eric Rice

E-mail regarding instructions from legal on impacts

1 0 / 7 /2 0 0 2

W P Full Privilege

Da vid M cElligott Bar bre Clar k

E-mail regarding summary numbers request from legal dep t
E-mail regarding advice from legal on military leave

11/12/2002 W P Full Privilege

5 / 2 /2 0 0 2

A/C Full Privilege

Barbre C lark

E-mail regarding advice from legal on military leave

5 / 2 /2 0 0 2

A/C Full Privilege

Deborah Goddard De borah Godd ard John Shannon

E-mail regarding legal advice on separation letters E-mail regarding legal advice on RIF E-mail regarding revised timeline for November action

1 1 / 1 4 /2 0 0 1 1 1 / 8 /2 0 0 1 1 0 / 3 1 /2 0 0 2

W P Full Privilege W P Full Privilege W P Full Privilege

John Shannon

E- m ai l r egar di ng r esul ts of l egal r evi ew

1 1 / 5 /2 0 0 2

W P Full Privilege

Ann Rhoads

E-mail regarding advice from legal on PCS Plans

10/22/2001 W P Full Privilege

Janet Larson Mic hael B rill

E-mail regarding advice from legal on immigration i s s u es
E-mail regarding legal advice on W ARN act

Mic hael B rill Janie Simon John Shannon De borah Godd ard Suzanne W illiams Gene Lampe Vick ie Sm ith
Anita Otto Janet Larson

E-m ail rega rding legal advice on W AR N act E-m ail rega rding legal advice on W AR N act E-mail regarding advice from legal on pool reductions E-m ail rega rding legal advice on se paration letters E-mail regarding advice from legal on RIF list
E-m ail rega rding legal analysis of AD EA requirem ents E-mail regarding E-grade package information from legal E-mail regarding advice from legal on realignment E-mail regarding notice period for RIF instructed by leg al

1 1 / 7 /2 0 0 2

Full Privilege

4 / 1 4 /2 0 0 2

W P Full Privilege

4 / 1 5 /2 0 0 2 4 / 1 5 /2 0 0 2 4 / 1 8 /2 0 0 2 1 1 / 1 4 /2 0 0 1 1 0 / 2 6 /2 0 0 1

W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege W P Full Privilege

1 0 / 4 /2 0 0 1 1 0 / 1 5 /2 0 0 1

W P Full Privilege W P Full Privilege

9 / 1 9 /2 0 0 2 1 / 2 1 /2 0 0 2

W P Full Privilege Full Privilege

Bates
1 8 4 6 4 4 - 18 4 6 4 5

From
Barbara Chapman

To
HR personnel

1 8 4 6 4 6 - 18 4 6 4 7

Barbara Chapman Lisa Watson

Lisa Watson , Lisa Reid
Kent Pe tit , Tabitha B ritt

KC Privilege Log
Description
e-mail partial redaction of legal dept comm unication
e-mail partial redaction of legal dept comm unication

Date
2 / 5 /2 0 0 3
1 / 2 4 /2 0 0 3 , 1 / 2 7 /2 0 0 3

Reason
A/C ; W P comm unication from legal dept
A/C; W P

66

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 67 of 76

1 8 4 6 4 8 - 18 4 6 4 9 1 8 4 6 5 0 - 18 4 6 5 1 1 8 4 6 5 2 - 18 4 6 5 3

Jeanne Boughton Barbara Chapman

Lisa Reid Gary Rurup

Am y Pe rri B a r b a r aC h a p m a n

Lisa Reid

Lisa Reid ,
Brian Burlinguette Barbara Chapman

Lisa Reid

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (New Orleans Nov. 2002 RIF)
e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Southwest Nov. 2002 RIF)
e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Califoria Account Executives RIF)

1 / 2 7 /2 0 0 3 , 1 / 2 4 /2 0 0 3

A/C; W P

1 / 2 7 /2 0 0 3 , 1 / 2 4 /2 0 0 3

A/C; W P

1 / 2 4 /2 0 0 3 , 2 / 5 /2 0 0 3 , 2 / 6 /2 0 0 3

AC ; W P:

1 8 4 6 5 5 - 18 4 6 5 7 1 8 4 8 8 6 - 18 4 8 8 7
184908
191263 191264 191265 1 9 1 3 1 3 - 19 1 3 1 8 1 9 1 3 1 9 - 19 1 3 4 0 1 9 1 4 3 5 - 19 1 4 4 2

Lisa Re id , C helli W olford-Goldwater Lisa Watson , B a r b a r aC h a p m a n
Lisa Watson
unknown unknown unknown unknown unknown unknown

Lisa Reid
Kent Petit , Lisa W atson ,Lisa Reid , Tabitha Britt
Craig Ca rroll Elisa Piph er , Kathy Gaylord , Kevin H eater Steve Smetana Richard Cremona Da niel Olm ett i Edward Aaronson Jayna Anderson Phillip Bowman Bill E srey
unknown
unknown
unknown
unknown
unknown
unknown

e-m ail D oc um en t forwa rde d purs ua nt to leg al d ep t's request for documents related to reduction in force decisions (Las Vegas) e-mail July and November 2002 Realignment W orksheets; partial redaction of legal comm unication
e-mail Feb. 2002 RIF; partial redaction of legal comm unication
table with ha ndwritte n no tes from meeting with lega l table with handwritten notes from m eeting with legal table for meeting with legal dept notes from m eeting with legal dept handwritten notes re employee comparison and ratings, from m eeting with legal dept typed S um m ary typed Su m m ary of Un ity II AAR S urvey: partial redaction of legal review

2 / 1 1 /2 0 0 3 , 2 / 1 3 /2 0 0 3 1 / 2 4 /2 0 0 3 , 1 / 2 7 /2 0 0 3
2 / 2 1 /2 0 0 2
unknown unknown unknown unknown 1 0 / 1 7 /2 0 0 2 5 / 8 /2 0 0 2

A/C; W P
A/C; W P
W P: communication from legal dept and/or legal stra tegy, mental impressions or legal advice
A/C ; W P A/C ; W P A/C ; W P A/C; W P A/C ; W P A/C; W P

67

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 68 of 76

1 9 1 5 9 1 - 19 1 5 9 3
191696 1 9 2 6 0 8 - 19 2 6 1 1 1 9 2 6 1 3 - 19 2 6 1 5 192621 1 9 2 6 6 4 - 19 2 6 6 9 192710

Gre g Coop er , Charles W arren, Mic hael M achell
unknown Jan Price
Jan Price
unknown Gre g Coop er unknown

Kim Ma ttingly Jody Brann Mic hael M achell , Greg Cooper Terry Allan Frank DeNap, Re nee Keffer , Charles W arren, Gayle Bayes , John Montross David Flessas Sandy Skeels , Terry Madden James Jennings, James Charlton Richard Berger Kevin G ardiner, Ga ry Fow ler, Mike Hendricks, Jody Luce , Gary Davis, Ed W alke, Joseph Roach W illiam Brid ges Janie Simon , Louise Elrod , Ann Poeh ler, Mic hael B rill
unknown
Sonja A mbur , Jon Bind er, Mic hael B rill , Gre g Coop er , Su zan ne Dris coll, Cathy Johnson, Gene Lampe Sho em aker-Katz Megan Yea rout Marvin Motley Pam Johnson
Sonja A mbur , Jon Bind er, Mic hael B rill , Gre g Coop er , Su zan ne Dris coll, Cathy Johnson Gene Lampe Shoem aker-Katz Megan Yea rout Marvin Motley Pam Johnson
unknown
Paula Zuzich
unknown

e-mails and survey Unity II After Action Review and Survey: Only legal review of survey redacted
handwritten notes re legal review Meeting Notes: legal strategy redacted
Meeting Notes: legal strategy redacted
handwritten notes containing legal advice fax Immigration docum ents from legal dept, with handwritten notes handwritten notes, with question for legal dept redacted

4 / 2 5 /2 0 0 2 , 4 / 2 9 /2 0 0 2
5 / 9 /2 0 0 2 7 / 9 /2 0 0 2
7 / 9 /2 0 0 2
7 / 8 /2 0 0 2 7 / 1 8 /2 0 0 2 unknown

A/C; W P
A/C ; W P A/C; W P A/C; W P A/C ; W P A/C; W P A /C :

68

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 69 of 76

APPENDIX 6 - “TO” OR “FROM” SPRINT ATTORNEYS

Bates
1 0 1 0 5 3 3 -1 0 1 0 5 3 6

To
Kate Fisher

8/12/2005 Privilege Log
From
Janet Larson P atrick H ulla

1 0 2 0 9 9 9 -1 0 2 0 9 9 9 1 1 4 0 6 2 9 -1 1 4 0 6 2 9 1 1 5 8 1 1 2 -1 1 5 8 1 1 3 1 1 5 8 1 1 5 -1 1 5 8 1 1 6

Tami Keasling
Lynn Simpson, Do nna Crossw hite
Sherrie Bowlin; Do nna Crossw hite
De nice Aiss a; Jill Fe rrell

Jan Price Elle n M artin Diane Shoemaker
Vick ie Sm ith
C o rp o ra te E R

1 1 5 8 1 3 1 -1 1 5 8 1 3 2 1 1 5 8 1 3 3 -1 1 5 8 1 3 4 1 1 5 8 1 5 6 -1 1 5 8 1 5 7 1 1 5 8 2 3 2 -1 1 5 8 2 3 3 1 2 3 2 8 6 4 -1 2 3 2 8 6 4 1 2 3 2 9 5 7 -1 2 3 2 9 5 8 1 2 3 3 2 5 5 -1 2 3 3 2 5 5 1 2 3 7 7 2 5 -1 2 3 7 7 2 5 1 2 6 3 7 9 8 -1 2 6 3 7 9 8 1 2 6 3 8 2 1 -1 2 6 3 8 2 1 1 2 6 3 8 2 3 -1 2 6 3 8 2 4 1 2 6 3 8 7 0 -1 2 6 3 8 7 1 1 2 6 3 9 0 4 -1 2 6 3 9 0 5 1 2 6 3 9 9 6 -1 2 6 4 0 0 2 1 2 6 4 0 7 5 -1 2 6 4 0 7 8

Denice Aissa; Do nna Crossw hite
Sherly Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Mic hael B rill; Do nna Crossw hite
Sharri Evenson; Tonya Johnston
Sheryl Bowlin; Do nna Crossw hite
Janet Larson; Do nna Crossw hite
Ro n Focht; Jill Ferrel
Janet Larson; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Sheryl Bowlin; Pa trick Hu lla
Sheryl Bowlin; Do nna Crossw hite
Kathryn Larison; Pa trick Hu lla
Anthony Byergo; Diane S hoe makerKa tz

C o rp o ra te E R Vick ie Sm ith Su zan ne Dris coll Vick ie Sm ith Mel Moyer Vick ie Sm ith Vick ie Sm ith Susan Ott Vick ie Sm ith Vick ie Sm ith Vick ie Sm ith Su zan ne Dris coll Vick ie Sm ith Janet Larson Anita Edwards

69

Description
Ha ndwritte n N ote and E-m ail containing RIF information
E-mail containing updated instructions for the RIF

Date
7 / 2 3 /2 0 0 2
1 0 / 2 4 /2 0 0 1

Reason
A/C Full Privilege
A/C Full Privilege

E-mail regarding revised tem plate
E-mail regarding update on corporate handou ts
E-mail regarding current workforce reduction g u i d e li n e s
E-mail regarding separation g u i d e li n e s
E-mail regarding updated letter tem plate
E-mail regarding additional process checks
E-m ail rega rding tem plate letter overview
E-mail regarding revised t e m p l a te s
E-mail regarding letter tem plate
E-m ail re ga rdin g re vis ed RIF letter
E-mail regarding severance plan changes

1 / 4 /2 0 0 2 1 0 / 2 6 /2 0 0 1 9 / 1 9 /2 0 0 1
1 1 / 2 0 /2 0 0 1 1 0 / 2 4 /2 0 0 1 1 0 / 3 0 /2 0 0 1 1 0 / 1 7 /2 0 0 1 1 2 / 1 8 /2 0 0 2 1 0 / 2 4 /2 0 0 1 1 0 / 3 /2 0 0 1 1 1 / 9 /2 0 0 1

A/C Full Privilege A/C Full Privilege A/C Full Privilege
A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege W P Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege

E-m ail re ga rdin g re vis ed RIF letter

1 0 / 3 /2 0 0 1

E-mail regarding letter template update

1 0 / 2 4 /2 0 0 1

E-mail regarding additional process checks

1 0 / 3 0 /2 0 0 1

E-mail regarding additional process checks

1 0 / 3 0 /2 0 0 1

E-mail regarding letter tem plate

1 0 / 2 4 /2 0 0 1

E-mail regarding terminations in C alifornia

1 2 / 9 /2 0 0 2

E-mail regarding separation issue

2 / 7 /2 0 0 3

A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C; W P A/C Full Privilege

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 70 of 76

1 2 6 4 2 4 1 -1 2 6 4 2 4 1 1 2 6 5 1 1 8 -1 2 6 5 1 1 8 1 3 3 0 0 2 1 -1 3 3 0 0 2 5 1 3 5 1 9 9 3 -1 3 5 1 9 9 4 1 3 5 2 0 0 6 -1 3 5 2 0 0 7 1 3 5 2 0 2 8 -1 3 5 2 0 2 9 1 3 5 2 1 0 3 -1 3 5 2 1 0 4 1 3 5 2 1 0 7 -1 3 5 2 1 0 7 1 3 5 2 1 2 5 -1 3 5 2 1 2 9 1 3 5 2 1 3 3 -1 3 5 2 1 3 5 1 3 5 2 1 6 8 -1 3 5 2 1 6 8 1 3 5 2 5 9 0 -1 3 5 2 5 9 1 1 3 5 2 5 9 6 -1 3 5 2 5 9 6 1 3 6 5 4 3 6 -1 3 6 5 4 3 7 1 3 6 5 4 3 8 -1 3 6 5 4 3 8 1 3 6 5 4 4 7 -1 3 6 5 4 4 7 1 3 6 5 7 4 9 -1 3 6 5 7 4 9

Sheryl Bowlin; Do nna Crossw hite

Vick ie Sm ith

Tami Keasling; Elle n M artin

Sh eryl B ow lin

An ne Kin ney; Pa trick Hu lla
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Pa trick Hu lla
Steven Furgason; Pa trick Hu lla
Steven Furgason; Pa trick Hu lla
Jon Bind er; Tonya Johnston
Shirley Fox; Tonya Johnston
Sharri Evenson; Tonya Johnston
Debra Aubuchon; John Shannon
Renee Finks; Beth Forwalder
Lynn Berding; Tim Hearshman
John St. Angelo; Tim Hearshman
Sonja A mbur; Tim Hearshman
Lavonda Anderson; Beth Forwalder

Diane S hoe maker-Katz Vick ie Sm ith Vick ie Sm ith Vick ie Sm ith Eric Rice Eric Rice Kip Downey Shirley Fox Mel Moyer Beth Forwalder Janet Larson Susan Schen ewe rk Greg Cooper John St. A ngelo Peter Dillon

1 3 6 5 8 3 6 -1 3 6 5 8 3 6 1 3 6 5 8 4 0 -1 3 6 5 8 4 0 1 3 6 5 9 6 1 -1 3 6 5 9 6 2 1 3 6 5 9 8 2 -1 3 6 5 9 8 2 1 4 2 4 1 7 0 -1 4 2 4 1 7 1
1 4 2 6 7 8 4 -1 4 2 6 7 8 5 1 4 2 8 2 2 1 -1 4 2 8 2 2 1

Da vid M cElligott; Do nna Crossw hite
Cody Krause; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
Sheryl Bowlin; Do nna Crossw hite
J e n n i fe r Ba ughm an; To nya J o h n s to n
Steve Debusk; Beth Forwald er
Jen Baughman; Tonya Johnston

Vick ie Sm ith Gene Lampe Vick ie Sm ith Vick ie Sm ith Da nette N orris
Ann Rhoads Danette Norris

E-mail regarding RIF impact on immigration issues

1 0 / 2 4 /2 0 0 1

E-mail regarding employees identified at selection meeting

1 0 / 2 8 /2 0 0 1

E-mail regarding separation plan
E-mail regarding RIF

7 / 1 9 /2 0 0 2 1 0 / 2 6 /2 0 0 1

A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege

E-mail regarding RIF

10/26/2001 A/C Full Privilege

E-mail regarding additional process checks
E-m ail re ga rdin g R IF c l a ri fi c a ti o n
E-mail regarding down grade j u s ti fi c a ti o n
E-mail regarding RIF process

1 0 / 3 0 /2 0 0 1 1 2 / 1 0 /2 0 0 2 1 2 / 1 0 /2 0 0 2 6 / 2 6 /2 0 0 2

A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege

E-mail regarding center c l o s in g
E-mail regarding revised templates
E-mail regarding revised timeline for November action
E-mail regarding RIF

1 2 / 1 9 /2 0 0 2 1 2 / 1 8 /2 0 0 2 1 0 / 2 6 /2 0 0 2 1 1 / 5 /2 0 0 2

A/C Full Privilege A/C Full Privilege A/C Full Privilege A/C Full Privilege

E-m ail reg arding RIF in network engineering
E-m ail reg arding RIF in Network Engineering
E-m ail reg arding RIF in network engineering
E-mail regarding instructions from hum an resources on selection process
E-mail regarding letter t e m p l a te s
E-mail regarding letter t e m p l a te s
E-mail regarding letter tem plate
E-mail regarding letter tem plate
E-mail regarding selection process

5 / 2 0 /2 0 0 2

W P Full Privilege

5 / 1 7 /2 0 0 2 5 / 2 0 /2 0 0 2

W P Full Privilege W P Full Privilege

1 / 1 6 /2 0 0 3

A/C Full Privilege

10/11/2001 W P Full Privilege

10/11/2001 W P Full Privilege

10/24/2001 A/C Full Privilege

10/24/2001 A/C Full Privilege

8 / 1 /2 0 0 2

A/C Full Privilege

E-mail regarding position e l im i n a t io n
E-m ail re ga rdin g R IF g u i d e l in e s

4 / 1 7 /2 0 0 2 8 / 1 /2 0 0 2

A/C Full Privilege A/C Full Privilege

70

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 71 of 76

Bates
1 8 5 0 0 2 - 18 5 0 0 3 1 8 5 2 4 6 - 18 5 2 4 7 185459
185521 185522 185523 1 8 6 4 7 2 - 18 6 4 7 3
191206 191222

KC Privilege Log

From

To

Description

Roger Parkinson ( A VP )

Kip D own ey (HR ), Ton ya Joh nston(SL), Maggie Beaton (Adm. Asst.),Bill Brougham (Mgr), Denise Fleming (Dir), Deborah Keating(Dir), Roger Parkinson (AVP),Nancy Sh aeffer (F in A nal)

e-mail Budget Challenge HR Calculation

Jan Price (HR )

Elaine B ishop (HR), T am mie Ca lys(HR ), Sharon Hardy (HR), Karen Kackley (legal analyst), Margie Linck (Dir), Kelly Mortenson (Mgr),Alan Nelis (HR), Elaine Tang (legal analyst), Sheryl D. Bowlin (HR),Kate Fisher (HR ), Mary H ull (HR ),Kathi Ke rste (H R), J a ne t L a rs o n( H R ), K a re n W i nd e s ( H R)

e-m ail RIF T erm Data Process

Lynn Simpson (HR), Vicki Smith

Ma rni B yrne, LaQ uita Co llier, K elly C arlisle (HR), Suzanne Driscoll(HR), Kate Fisher (HR ), Nan cy Fox(HR ), Kim Ganote (HR ), Scott Jensen (HR), Tamm i Keasling (HR ),Vick i Kolb (HR ), Cod y Krau se(H R), Ge ne Lam pe (H R), M ichael Ma chell (HR ), Mich ael M arino (HR ),David M cElligott (HR ), Jan Price(HR), Elaine Bishop (HR), James Hayes (HR), Patrick Hulla (SL), Jo Renda (HR), Debra Simpson (HR),Sarah Urich (HR ), Lisa Jam eson, Jan et Larson (HR ), Margie Linck(Dir), Mitzi Miller (HR), Janice Schon wette r (HR ), Tere sa S warts (HR ), K a re n W i nd e s ( H R)

e-mail Additional Process Checks

Karin Miller (P CS )

Elaine Tang (legal analyst), Karen Kackley (legal analyst)

e-mail PCS R IF List

Karin Miller (P CS )

Elaine Tang (legal analyst), Karen Kackley (legal analyst)

e-mail PCS R IF List

Karin Miller (P CS )

Elaine Tang (legal analyst), Karen Kackley (legal analyst)

e-mail PCS R IF List

Ge ne Lam pe (H R), Vicki Smith

Co dy K rause (HR ), Leon Lan g(H R), Da vid McElligott (HR ),Suzann e Mc Vey (HR ), Debra Simpson (HR), Heather Thorndike(HR), Marcia Valenzeno (HR ),Burke W alke r (HR ), Sco tt W inkler(Employee Relations Sp ecialist),Sh eryl B ow lin (H R), Ke lly Ca rlisle(HR), S uzan ne D riscoll (H R), K ate Fisher (HR), N ancy Fox (H R), K im Ganote (HR), Scott Jensen (HR),Tami Keasling (HR ), Vick i Kolb(HR ), Gene Lam pe (H R), Michael Machell (HR), Michael Marino (HR ),Jan Price (HR ), Jo R end a (HR),D ebra Simpson (HR), Lynn Simpson (HR), Sarah Urich (HR),Elaine Bishop (HR), James Hayes(HR), Patrick Hulla (SL), Lisa Jameson, Janet Larson (HR), Mitzi Miller (HR), Margie Linck (Dir),Janice Schonwetter (HR), Teresa Swarts (HR), Karen W indes

Addi ti onal Pr oc es s C hec k s

unknown

unknown

han dwritten notes re 7/22/2002 m eeting with Tim Hearshman (SL)

unknown

unknown

handwritten notes either written by Tim Hearshman (SL),or taken from m eeting with Tim Hearshman(SL)

Date
7 / 1 0 /2 0 0 2

Reason
A/C Part Privilege

7 / 1 9 /2 0 0 2

A/C; W P

1 0 / 3 0 /2 0 0 1 1 0 / 3 1 /2 0 0 1

A/C Full Privilege

1 / 6 /2 0 0 3

A/C Full Privilege

1 / 6 /2 0 0 3

A/C Full Privilege

1 / 6 /2 0 0 3

A/C Full Privilege

10/30/2001 A/C Full Privilege

unknown

A/C ; W P

7 / 2 2 /2 0 0 1

A/C ; W P

71

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 72 of 76

1 9 1 2 5 7 - 19 1 2 6 0

unknown

191262

unknown

1 9 1 4 1 4 - 19 1 4 1 6

unknown

191722

unknown

unknown unknown unknown unknown

handwritten notes handwritten notes prepared for m eeting with Tim Hearshman (SL)
handwritten notes handwritten notes prepared for m eeting with Tim Hearshman (SL)
employee job data printout and handwritten notes from conversation with Elaine Tang (SL)
handwritten notes from conversation with T im Hearshman (SL)

10/17/2002 A/C ; W P

unknown

A/C ; W P

4 / 1 6 /2 0 0 2

A/C ; W P

unknown

A/C; W P

72

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 73 of 76

APPENDIX 7 - REMAINING DOCUMENTS

Bates 1 0 0 0 0 7 5 -1 0 0 0 1 2 1 1 0 0 0 1 9 4 -1 0 0 0 2 0 3 1 0 0 0 3 1 6 -1 0 0 0 9 6 3 1 0 0 1 1 2 1 -1 0 0 1 1 2 5 1 0 0 9 9 1 2 -1 0 0 9 9 1 2

To Kenna Osburn None Peter Dillon Da ve Iery Ric W alter

1 0 0 9 9 1 4 -1 0 0 9 9 1 5 1 0 0 9 9 1 6 -1 0 0 9 9 1 6

Jerry Usry Jerry Usrey

1 0 0 9 9 2 0 -1 0 0 9 9 2 0

Mic hael B ril

1 0 0 9 9 2 1 -1 0 0 9 9 2 1 1009922 1 0 0 9 9 2 4 -1 0 0 9 9 2 4 1 0 0 9 9 6 1 -1 0 0 9 9 6 3 1 0 0 9 9 7 6 -1 0 0 9 9 7 8 1 0 0 9 9 9 5 -1 0 1 0 0 1 9 1 0 1 0 0 2 0 -1 0 1 0 0 3 0 1 0 1 0 1 0 3 -1 0 1 0 1 0 3 1 0 1 0 1 0 4 -1 0 1 0 1 0 5 1 0 1 0 2 5 0 -1 0 1 0 2 5 4

Jerry Usrey Jerry Usrey Jerry Usrey Jerry Usrey Kathleen McBee None None Jerry Usrey Jerry Usrey Melannie Schultz

1 0 1 3 0 3 5 -1 0 1 3 3 0 6 1 0 2 0 3 8 0 -1 0 2 0 4 2 3 1 0 2 0 5 0 4 -1 0 2 0 5 0 4

John Shannon Chris Thompson Debra Aubuchon

1 0 2 1 1 0 9 -1 0 2 1 1 0 9 1 0 2 1 1 6 8 -1 0 2 1 1 7 0 1 0 2 1 2 3 3 -1 0 2 1 2 3 3 1 0 5 2 7 9 4 -1 0 5 2 7 9 6

Deonna Sharp Denice Aissa Mic hael B rill Gre g Coop er

1 0 6 4 2 5 2 -1 0 6 4 2 5 3 1 0 6 4 2 5 6 -1 0 6 4 2 5 6

De irdre Moore Ann Rhoads

From Peter Dillon Unknown Eric Rice Janet Ca shwe ll Gre g Coop er, Kim Ma ttingly Gre gory P lante Kevin Wilson
Gre g Coop er, Kate Fisher Ric W alter Bill Benner Gre gory P lante Gregory Plante Lynn Simpson Unknown Unknown Frank Hickey Frank Hickey Kip Downey Faith Palmer Allison Reed Ron Gier John Shannon Ron Gier Vic ki K olb C o rp o ra te E R Ken Blurton Frederick Ha rris Paula Zuzich Ann Rhoads Jim Kissinger Ron Gier

8/12/2005 Privilege Log
D e s c r i p ti o n E-mail & spreadsheets re: network director Spreadsheet: Network Dept demographics E-mail spreadsheet re: finance selection pool E-mail with attached separation information E-m ail re: total # e mployee separation s in O ct.

Da te 1 2 / 2 7 /0 2 0 0 - 0 0 -0 0 1 1 / 1 4 /0 3 1 / 3 0 /0 3 1 0 / 3 1 /0 2

Reason AI Part Privileged AI Full Privilege AI Part Privileged AI Part Privileged A/C Part Privileged

E-mail re: downsizing of employees in region E-mail transmitting word document from m gr staffing meeting for the engineering dept. E-m ail re: timeline for restructuring of C PE Field O p e r a t io n s E-mail regarding CPE reductions E-mail re: downsizing in Pacific region E-mail re: employee reductions in each market E-m ail re: reco mmend ations for Atlantic reo rg E-mail containing info related to the RIF Spreadsheet: Headcount Reduction Spreadsheet: Voluntary Headcount Reduction E-mail re: workforce reduction E-mail re: workforce reduction E-mail with updates on how the RIF is being conducted

6 / 1 4 /0 2 9 / 2 4 /0 2
9 / 2 6 /0 2
7 / 3 /0 2 6 / 1 4 /0 2 6 / 1 0 /0 2 5 / 1 4 /0 2 1 / 5 /0 2 0 0 - 0 0 -0 0 0 0 - 0 0 -0 0 6 / 1 0 /0 2 6 / 1 1 /0 2 6 / 4 /2 0 0 2

A/C Part Privileged A/C Part Privileged
A/C Part Privileged
A/C Part Privileged A/C Part Privileged A/C Part Privileged A/C Part Privileged W P Part Privileged AI Full Privilege AI Full Privilege A/C Part Privileged A/C Part Privileged A/C Part Privileged

E-mail transmitting a list of employees for redeployment E-m ail transm itting transition team materials E-mail re revised timeline for November action

4 / 2 /2 0 0 2 1 2 / 2 3 /2 0 0 2 1 0 / 2 6 /2 0 0 2

A/C Full Privilege W P Full Privilege W P Full Privilege

E-m ail rega rding releas e agreem ents E-mail explaining the separation plan E-mail containing follow up information on RIFs E-mail with attached RIF list

1 / 2 3 /2 0 0 1 1 1 / 2 0 /2 0 0 1 5 / 2 4 /2 0 0 2 7 / 1 9 /2 0 0 2

W P Full Privilege W P Full Privilege W P Full Privilege AI Part Privileged

E-mail regarding marketing organization E-mail regarding selection decisions

1 1 / 5 /2 0 0 2 1 1 / 1 /2 0 0 2

W P Full Privilege A/C; WP Full Privilege

73

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 74 of 76

1 0 7 0 1 4 3 -1 0 7 0 1 4 3 1 0 7 0 4 5 4 -1 0 7 0 4 5 4

Karin Miller Chris Thompson

1 1 0 9 2 5 3 -1 1 0 9 2 5 3 1 1 4 1 3 2 1 -1 1 4 1 3 2 2

Sh eryl B ow lin Gene Lampe

Kelly Mortensen Julie Moyla Ron Gier Jan Price Scott W inkler

E-m ail rega rding instructions o n RIF lists E-mail regarding RIF process documentation
E-mail with instructions on visa and patent reports E-mail regarding draft release language

1 2 6 2 7 0 6 -1 2 6 2 7 0 7 1 2 6 2 7 0 8 -1 2 6 2 7 0 9 1 2 6 2 7 1 0 -1 2 6 2 7 1 1 1 2 6 4 3 9 8 -1 2 6 4 3 9 9 1 2 8 1 5 3 2 -1 2 8 1 5 3 3

Da vid M cElligott; Marvin Motley
Vonya McCann; Ma rvin Mo tley
Vonya McCann; Ma rvin Mo tley
Vonya McCann; Marvin Motley
Jed Dodd

Vonya McCann

E-mail regarding summary numbers requested

Da vid M cElligott

E-mail regarding summary numbers requested

Da vid M cElligott

E-mail regarding summary numbers requested

Bill W hite

E-m ail rega rding separation sum mary by state

Randy Bryson

E-mail regarding business stack ranking

1 2 8 1 5 4 3 -1 2 8 1 5 4 3

Jerry U sry

Gre gory P iante

E-mail regarding downsizing information

1 2 8 1 5 5 1 -1 2 8 1 5 5 1

Jerry U sry

Ga ry Ga rcia

CPE Managers E-mail regarding RIF list

1 2 8 1 5 5 8 -1 2 8 1 5 5 9

Jerry U sry

Ga ry Ga rcia

E-m ail rega rding staffing work sheet

1 2 8 1 5 6 4 -1 2 8 1 5 6 4

Jerry Usry

Ga ry Ga rcia

1 2 9 5 6 4 8 -1 2 9 5 6 4 8 1 2 9 5 6 4 9 -1 2 9 5 6 4 9

Gre g Coop er; Kim berly Ma ttingly
Jerry U sry

Frank Hickey Ric W alter

CPE Ma na ge rs E -m ail re ga rdin g C en tral Re gio n R IF d o c u m e n t a ti o n E-mail regarding downgrades
E-mail regarding field operations down-sizing

1 2 9 5 6 5 0 -1 2 9 5 6 5 0

Jerry U sry

Gre gory P lante

E-mail regarding headcount

1 2 9 5 6 5 1 -1 2 9 5 6 5 1 1 2 9 5 6 5 3 -1 2 9 5 6 5 3 1 2 9 5 6 5 4 -1 2 9 5 6 5 5

Frank Hic ke y; Jerry U sry
Ric W alter; Kim berly Ma ttingly
Jerry U sry

Greg Cooper Greg Cooper Gre gory P lante

E-mail regarding RIF timing issues E-mail regarding CPE reductions E-mail regarding downsizing

1 2 9 5 6 5 6 -1 2 9 5 6 5 6

Jerry U sry

James Bergner

E-mail regarding downsizing

1 2 9 5 6 5 7 -1 2 9 5 6 5 7

Kim berly Ma ttingly

Frank Hickey

E-mail regarding RIF packages

1 2 9 5 6 5 8 -1 2 9 5 6 5 9

Jerry U sry

Ga ry Ga rcia

E-mail regarding additional RIF list

1 2 9 5 7 2 9 -1 2 9 5 7 3 0

Chris Thompson

John Shannon

E-mail regarding pool reductions

1 2 9 5 7 6 7 -1 2 9 5 7 6 7

Chris Thompson

Ron Gier

E-mail regarding activity status sheet

1 2 9 5 8 8 3 -1 2 9 5 8 8 3 1 2 9 5 9 2 1 -1 2 9 5 9 2 3

Chris Sharp; De onn a Sharp
Chris Thompson

Cindy Dove Peter Dillon

E-mail regarding process outlines E-m ail rega rding realign ment works hee ts

1 / 3 0 /2 0 0 3 1 / 2 9 /2 0 0 3

A/C; WP Full Privilege A/C Full Privilege

1 1 / 7 /2 0 0 1 1 0 / 3 1 /2 0 0 1 1 2 / 1 1 /2 0 0 2

W P Full Privilege A/C Full Privilege A/C Full Privilege

1 2 / 1 1 /2 0 0 2

A/C Full Privilege

1 2 / 1 1 /2 0 0 2

A/C Full Privilege

1 2 / 1 2 /2 0 0 2

A/C Full Privilege

8 / 1 6 /2 0 0 2 1 0 / 1 4 /2 0 0 2 1 0 / 1 1 /2 0 0 2 1 0 / 2 /2 0 0 2 9 / 2 7 /2 0 0 2

A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged.

1 0 / 1 0 /2 0 0 2

A/C Part privileged.

6 / 1 1 /2 0 0 2 7 / 3 /2 0 0 2 1 0 / 9 /2 0 0 2

A/C Part privileged. A/C Part privileged. A/C Part privileged.

1 0 / 3 1 /2 0 0 2

A/C Part privileged.

6 / 1 4 /2 0 0 2 6 / 1 3 /2 0 0 2 1 0 / 2 4 /2 0 0 2 6 / 1 4 /2 0 0 2 1 1 / 4 /2 0 0 2 1 2 / 1 1 /2 0 0 2 1 / 2 8 /2 0 0 3

A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Part privileged. A/C Full Privilege A/C Full Privilege A/C Part privileged.

1 1 / 8 /2 0 0 2

A/C Part privileged.

74

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 75 of 76

1 2 9 5 9 4 0 -1 2 9 5 9 4 0 1 2 9 5 9 4 1 -1 2 9 5 9 4 2

Randy Bryson; Margie Paxson
Margie Paxson

Steve Mueller Randy Bryson

1 2 9 5 9 7 2 -1 2 9 5 9 7 4 1 2 9 7 0 7 6 -1 2 9 7 0 7 6 1 3 2 9 5 1 6 -1 3 2 9 5 3 6
1 3 3 0 2 2 5 -1 3 3 0 2 2 9 1 3 6 5 8 9 2 -1 3 6 5 8 9 2 1 4 1 2 9 4 5 -1 4 1 2 9 4 8

Jackie Ashworth; Jerry U sry
Ric W alter; Tim Dinsiage
Peter Dillon; Chris Thompson

Frank Hickey
Linda Mccoy
Lavonda Anderson

Chris Thompson
Rachel Griebling; Janet Larson
Joe Vida l; Joan VonderHeide

Peter Dillon Vick ie Sm ith
De b Sprayberry

E-mail regarding Stack Ranking
E-m ail rega rding HQ Business S ales & S upp ort E-mail regarding HR contacts for separation meetings
E-mail regarding 2003 budget
E-mail regarding access management organizational charts E-m ail rega rding RIF list E-mail regarding E-grade packages E-mail regarding director separations

8 / 1 4 /2 0 0 2

A/C Part privileged.

1 1 / 1 /2 0 0 2 1 0 / 2 4 /2 0 0 2

A/C Part privileged. A/C Part privileged.

9 / 1 9 /2 0 0 2

A/C Part privileged.

3 / 1 0 /2 0 0 3

A/C Full Privilege

2 / 1 9 /2 0 0 3 1 0 / 1 5 /2 0 0 1

A/C Full Privilege W P Full Privilege

2 / 4 /2 0 0 2

AI Full Privilege

Bates 184552

From Tina Peek (HR )

To T a sh a R ee d (H R )

KC Privilege Log
D e s c r i p ti o n e-mail ISSC RIF Preparation-East

Da te 1 / 6 /2 0 0 3

184555184556

Tina Peek (HR )

T a sh a R ee d (H R )

e-mail ISSC RIF Preparation-East

1 / 6 /2 0 0 3

184557184559

T a sh a R ee d (H R )

Mari Burg er (HR)

e-mail ISSC RIF Preparation-East

37628 [sic]

184567 184591

Scott Jen sen (HR ) S c ot t J en s en (H R )

Keith W oods (Enterprise Sa les)
Kip D own ey (HR )

e-m ail Analysis S um mary

1 / 2 8 /2 0 0 2

e-mail Analysis Per Our Discussion 4/5/2002

184592184593
184619184620
184642184643
185194
185210

Erica Oliver (SM ES ), Barb ara Ch apm an (H R), L is a W a ts o n ( H R)
Rebecca Holiday (Bus. Sa les -P CS ), Barbara Chapman (HR), Lisa Watson (HR)
Lisa W atson (HR), B a r b a r aC h a p m a n (HR), Erica O l iv e r( S ME S )
John St. A ngelo (HR )
T in a Pe e k ( H R)

Kent Petit (HR), Lisa W atson (HR), Lisa Reid (HR), Tabitha B r it t ( H R)
Ke vin K appler (Regional D ir Sa les),De nise Ba rrett, T im Du sek (Regional Dir S ales), Kent Petit(HR), Lisa W atson (HR), Lisa Reid(HR), Tabitha B r it t ( H R)
Kent Petit (HR), Lisa W atson (HR),Lisa Reid (HR), Tabitha B r it t ( H R)
Don Hallacy (Tech), Len Lauer (Exec), Marvin Motley (HR ), Ric W alter (H R), M e ga n Ye a ro u t ( H R)
Tasha Reed (HR: employee relation ship coordinator)

e-mail Central-July 2002 & N o v em b e r 2 0 02 , B S S R
e-m ail D oc um en ts re late d to RIF d e c i si o n s
e-mail July and November 2002 Re alignm ent works hee ts
e-m ail Summary List
e-mail ISSC RIF Preparation-East

1 / 3 1 /2 0 0 3
1 / 2 4 /2 0 0 3 1 / 2 7 /2 0 0 3
1 / 3 1 /2 0 0 3 , 1 / 2 7 /2 0 0 3 , 1 / 2 4 /2 0 0 3 1 0 / 1 2 /2 0 0 1
1 / 6 /2 0 0 3

Reason
W P; transmits legal advice from legal dept to those responsible for im plem enting it
W P; transmits legal advice from legal dept to those responsible for im plem enting it
W P; transmits legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; AI analysis prepared at request of legal dept
A/C ; W P; do cum ents prepared at request of legal; comm unication from legal counsel
A/C; WP ; documents collected at request of legal dept; comm unication from legal counsel
A/C; WP ; documents prepared at request of legal dept, comm unication from legal dept
A/C :partial redaction of comm unication to legal counsel
A/C : legal advice from legal dept to those resp onsible for im plem enting it

75

Case 2:03-cv-02200-JWL-DJW Document 4591 Filed 03/19/2007 Page 76 of 76

185547

Scott W inkler

G e n e L a m pe (H R )

Denton Roberts List

1 0 / 1 /2 0 0 1

185548 185716185718 187246 188306
188307
188309
188324
188326
191385

Ge ne Lam pe (H R), Scott W inkler

Ge ne Lam pe (H R), S cott W inkler(Employee Relations S p e ci al is t) ,E r ic R ic e ( H R

Denton Roberts List Revisions

1 0 / 8 /2 0 0 1

S c o tt J e ns e n ( H R)

Jon Bind er (HR), S harri Evenson(HR), Suzanne D r is c ol l ( H R)

Sprint E-Solutions Impacted List for ER Review and Comm ents; partial r e d a c ti o n

7 / 2 0 /2 0 0 2

Anita Edwards (HR)

Justin Cro ssw hite (H R), D e n na B ow le s ( H R )

M o rr is S T D

1 2 / 1 7 /2 0 0 2

Ge ne Lam pe (H R), Sc ott W inkler(Employee R e l a ti o n s Sp ecia list)

Eric R ice (H R), S cott W inkler(Employee Relations S p e ci al is t) ,G e n e L a m pe (H R )

De nton Roberts Lists

1 0 / 1 /2 0 0 1 , 1 0 / 7 /2 0 0 1

Ge ne Lam pe (H R), Sc ott W inkler(Employee R e l a ti o n s Sp ecia list)

Eric R ice (H R), S cott W inkler(Employee Relations S p e ci al is t) ,G e n e L a m pe (H R )

De nton Roberts Lists

1 0 / 1 /2 0 0 1 , 1 0 / 7 /2 0 0 1

Ge ne Lam pe (H R), Sc ott W inkler(Employee R e l a ti o n s Sp ecia list)

Eric R ice (H R), S cott W inkler(Employee Relations S p e ci al is t) ,G e n e L a m pe (H R )

De nton Roberts Lists

1 0 / 1 /2 0 0 1 1 0 / 7 /2 0 0 1

Ge ne Lam pe (H R), Sc ott W inkler(Employee R e l a ti o n s Sp ecia list)

Eric R ice (H R), S cott W inkler(Employee Relations S p e ci al is t) ,G e n e L a m pe (H R )

De nton Roberts Lists

1 0 / 1 /2 0 0 1 , 1 0 / 7 /2 0 0 1

Ge ne Lam pe (H R), Sc ott W inkler(Employee R e l a ti o n s Sp ecia list)

Eric R ice (H R), S cott W inkler(Employee Relations S p e ci al is t) ,G e n e L a m pe (H R )

De nton Roberts Lists

1 0 / 1 /2 0 0 1 , 1 0 / 7 /2 0 0 1

unknown

unknown

handwritten notes handwritten notes re O sam a Ata

6 / 6 /2 0 0 2

A/C; WP ; AI analysis prepared at request of legal dept
A/C; WP ; communication to legal counsel; legal strategy and mental i m p r e s s io n s
A/C; WP ; agenda for legal meeting and com munication to be m ade to legal counsel
A/C; WP ; communication from legal counsel
A/C; WP ; partial redaction of legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; partial redaction of legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; partial redaction of legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; partial redaction of legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; partial redaction of legal advice from legal dept to those responsible for im plem enting it
A/C; WP ; communication to or from legal co unsel and /or notes pre pared in anticipation of litigation

76

 
 Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

SHIRLEY WILLIAMS, et al.,

Plaintiffs,
v.
SPRINT/UNITED MANAGEMENT COMPANY,

CIVIL ACTION No. 03-2200-JWL-DJW

Defendant.

MEMORANDUM AND ORDER Plaintiff Shirley Williams filed this suit on behalf of herself and others similarly situated, asserting that her age was a determining factor in Defendant's decision to terminate her employment during a reduction-in-force (RIF). This case has been provisionally certified as a collective action pursuant to 29 U.S.C. § 216(b) and the parties are presently engaged in discovery concerning the merits of Plaintiffs’ pattern and practice allegations. This matter is presently before the Court on Plaintiffs’ Motion to Compel Responses to Plaintiffs’ Tenth Interrogatories and Eleventh Requests for Production of Documents (doc. 4300). For the reasons set forth below, the motion is denied without prejudice for failure to confer prior to filing the motion. I. Efforts to Confer Prior to Filing Motion Plaintiffs served their Tenth Interrogatories and Eleventh Requests for Production of Documents on March 28, 2006. Defendant served its Response to Plaintiffs’ Eleventh Request for

-1-

Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 2 of 6
Production of Documents on May 22, 2006.1 The parties held a “meet and confer” session on June 22, 2006. Because Defendant had not yet answered Plaintiffs’ Tenth Interrogatories and counsel for Defendant had to leave the “meet and confer” session early, counsel agreed to postpone discussions until the following week On June 28, counsel for the parties spoke by telephone regarding Plaintiffs’ Eleventh Request for Production of Documents. Counsel again agreed to postpone any further discussion relating to the Tenth Interrogatories, and the first numbered request of the Eleventh Request for Production of Documents. Some other matters relating to the Eleventh Request for Production of Documents were discussed on June 28. Following that telephone conversation, Plaintiffs’ counsel sent a letter to Defendant’s counsel confirming the conversation. Defendant’s counsel responded with an e-mail dated July 1, which confirmed that there were unresolved issues.
Defendant served its Answers and Objections to Plaintiffs’ Tenth Interrogatories on July 13, 2006.2 After receiving Defendant’s answers and objections, Plaintiffs’ counsel sent a letter dated August 10, 2006, which summarized the discovery requests and Defendant’s objections to them. The next day, August 11, 2006, Plaintiffs’ counsel sent an e-mail to Defendant’s counsel, inviting a further “meet and confer” session, and suggesting a suspension of the motion to compel deadlines. After a series of e-mail exchanges that day, defense counsel made it clear that Defendant opposed Plaintiffs’ suggested suspension and request for an extension of time. The next business day, Plaintiffs requested an extension of time to file their Motion to Compel. The Court granted their motion and Plaintiffs filed their Motion to Compel on August 31, 2006.
1See Certificate of Service (doc. 4136). 2See Certificate of Service (doc. 4229).
-2-

Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 3 of 6
II. Whether Plaintiffs Satisfied Their Duty to Confer Federal Rule of Civil Procedure 37 requires the movant to make a good faith attempt to
resolve the discovery dispute before filing a motion to compel discovery responses. The motion to compel must include a certification of the effort to resolve the dispute.3
In conjunction with Fed. R. Civ. P. 37, District of Kansas Rule 37.2 provides: The court will not entertain any motion to resolve a discovery dispute pursuant to Fed. R. Civ. P. 26 through 37 . . . unless counsel for the moving party has conferred or made reasonable efforts to confer with opposing counsel concerning the matter in dispute prior to the filing of the motion. A “reasonable effort to confer” . . . requires that the parties in good faith converse, confer, compare views, consult and deliberate, or in good faith attempt to do so.4 The purpose of the local rule is to encourage the parties to satisfactorily resolve their discovery disputes prior to resorting to judicial intervention.5 Meet and confer requirements are not satisfied “by requesting or demanding compliance with the requests for discovery.”6 The parties must determine precisely what the requesting party is actually seeking; what responsive documents or information the discovering party is reasonably capable of producing; and what specific, genuine objections or other issues, if any, cannot be resolved without judicial intervention.7 Plaintiffs’ Certificate of Consultation in Compliance with Local Rule (doc. 4302) filed contemporaneously with their motion states that Plaintiffs’ counsel communicated at various times
3Id. 4D. Kan. Rule 37.2. 5VNA Plus, Inc. v. Apria Healthcare Group, Inc., No. Civ. A. 98-2138-KHV, 1999 WL 386949, at *1 (D. Kan. June 8, 1999). 6Cotracom Commodity Trading Co. v. Seaboard Corp., 189 F.R.D. 456, 459 (D. Kan. 1999). 7Id.
-3-

Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 4 of 6
with Defendant’s counsel in this case, with respect to the Defendant’s responses to Plaintiffs’ Tenth Interrogatories and Eleventh Requests for Production of Documents. It further states that upon receipt of Defendant’s responses to the discovery requests, counsel for Plaintiffs communicated with counsel for Defendant regarding Defendant’s refusal to provide complete responses to many of Plaintiffs’ discovery requests and the parties exchanged correspondence, discussed the issues at various “meet and confer” sessions and in telephone conferences, and via e-mail.
Defendant argues that because it has not been afforded the opportunity to complete the “meet and confer” process, it would be unfair for the Court to consider Plaintiffs’ present motion. Defendant points out that on August 17, 2006, the parties had specifically scheduled a follow-up “meet and confer” session for August 28, 2006 so that they could resume discussion of Plaintiffs’ written discovery after the two conferences to be held with Judge Lungstrum. Defendant insists that it specifically invited further discussion regarding the discovery based on the content of the August 17, 2006 session and the hearings with Judge Lungstrum. Plaintiffs, however, chose unilaterally to cancel the “meet and confer” scheduled for August 28, 2006, and, to instead proceed directly to filing their motion to compel. According to Defendant, Plaintiffs’ refusal to complete the discussion commenced on August 17, 2006 deprived the parties and the Court of the opportunity to resolve these matters without the need for a motion. This is directly contrary to the purpose of D. Kan. Rule 37.2, and Plaintiffs’ motion should be denied on that ground alone.
The Court has reviewed Plaintiffs’ Certificate of Compliance, as well as correspondence exchanged between the parties with regard to Plaintiffs’ Tenth Interrogatories and Eleventh Requests. Based on this review, the Court finds that Plaintiffs have failed to satisfy their meet and confer obligations required by D. Kan. Rule 37.2 and Federal Rule of Civil Procedure 37. The Court
-4-

Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 5 of 6
notes that the June and early July 2006 efforts cited by Plaintiffs in support of satisfying their duty to confer were held before Defendant had even served its Answers and Objections to Plaintiffs’ Tenth Interrogatories. Apparently recognizing this, counsel agreed to postpone discussions relating to the discovery requests at the June 22, 2006 “meet and confer” session and June 28 telephone conference. Plaintiffs’ counsel did send Defendant a letter on August 10, 2006 that reiterated their requests and their understanding of Defendant’s objections. This letter was followed up by a series of e-mail exchanges the next day that primarily discussed whether Defendant would agree to suspend the thirty-day deadline for filing motions to compel. After Defendant replied that it would oppose any extension motion, Plaintiffs ceased their efforts to confer and proceeded with filing a motion for extension of time. Based on these circumstances, the Court finds that Plaintiffs have failed to make a reasonable effort to confer before filing their motion to compel. The Court will therefore deny Plaintiffs’ Motion and will direct the parties to arrange and participate in a “meet and confer” session with the Special Master. The parties are specifically ordered to review the Court’s previous orders, some of which have been entered since this motion was filed, that relate to similar issues and attempt to resolve the current issues based on the Court’s previous orders. If the parties are unable to resolve all of their discovery dispute with the assistance of the Special Master, Plaintiffs may file an Amended Motion to Compel Responses to Plaintiffs’ Tenth Interrogatories and Eleventh Requests for Production of Documents on those issues that remain unresolved.
IT IS THEREFORE ORDERED that Plaintiffs’ Motion to Compel Responses to Plaintiffs’ Tenth Interrogatories and Eleventh Requests for Production of Documents (doc. 4300) is denied without prejudice subject to the parties’ participation in a “meet and confer” session with the Special Master on the issues set forth in the motion.
-5-

Case 2:03-cv-02200-JWL-DJW Document 4627 Filed 04/30/2007 Page 6 of 6
IT IS FURTHER ORDERED each party is to bear their own expenses in relation to this motion.
IT IS SO ORDERED. Dated in Kansas City, Kansas on this 30th day of April, 2007.

cc: All counsel

s/ David J. Waxse David J. Waxse United States Magistrate Judge

-6-

 
 IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Shirley Williams et al.,

Plaintiffs,

v.

Case No. 03-2200-JWL

Sprint/United Management Company,

Defendant.

MEMORANDUM & ORDER On September 10, 2007, the court held a hearing to consider final approval of the parties’ settlement of this collective action. Opt-in plaintiff Ruby Harvey-Burgin appeared pro se at the settlement hearing and objected to the settlement based on her asserted belief that her portion of the settlement proceeds was not calculated appropriately. On the following day, the court entered its Order of Final Approval of Settlement and, in doing so, overruled Ms. HarveyBurgin’s objection with the exception that the court ordered plaintiffs’ counsel to reimburse Ms. Harvey-Burgin’s demonstrable, out-of-pocket travel and lodging expenses associated with her deposition. Ms. Harvey-Burgin has now filed an appeal relating to the court’s September 11, 2007 Order of Final Approval of Settlement and, more specifically, her claim that her portion of the settlement proceeds should be increased. In connection with that appeal, and as directed by the Clerk of the Tenth Circuit Court of Appeals, the clerk of this court recently transmitted to the Tenth Circuit a certified copy of the transcript of the September 10, 2007 settlement hearing.

Ms. Harvey-Burgin now moves the court, pursuant to Federal Rule of Appellate Procedure 10(e), to correct the transcript of the settlement hearing (doc. 4701) on the grounds that it is “incomplete, inaccurate and omissive.” As will be explained, the motion is granted in part and denied in part.
In her motion, Ms. Harvey-Burgin contends that one comment allegedly made by the court was omitted from the transcript of the settlement hearing; that one comment allegedly made by plaintiffs’ counsel was omitted from the transcript; and that certain physical movements made by Ms. Harvey-Burgin at a specific point in the hearing are not reflected in the transcript (namely, looking “backwards toward plaintiff’s attorney’s table, then forward toward the judge”). She further contends that the transcript erroneously reflects that she qualified one of her statements with the phrase “I believe” when, according to Ms. Harvey-Burgin, she did not so qualify her statement. She also complains that the transcript contains a typographical error (i.e., that line 15 on page 8 reflects that the word “should” was uttered when it was not). Finally, Ms. Harvey-Burgin asserts that she simply cannot recall certain comments made by the court as reflected at lines 16 through 25 on page 85 of the transcript.
A certified transcript is entitled to a statutory presumption of accuracy. See 28 U.S.C. § 753(b) (The “transcript in any case certified by the reporter . . . shall be deemed prima facie a correct statement of the testimony taken and proceedings had.”). Mere assertions that the record is wrong are not sufficient to overcome this presumption. Veillon v. Exploration Servs., Inc., 876 F.2d 1197 (5th Cir. 1989). In analyzing the merits of Ms. Harvey-Burgin’s objections to the certified transcript of the settlement hearing, the court has carefully reviewed the transcript itself
2

and has relied on its own memory of what transpired at the settlement hearing. The court’s review of the transcript reveals that only one of Ms. Harvey-Burgin’s objections to the transcript has merit–her contention that the word “should” at line 15 on page 8 is a transcription error and should be deleted. With respect to her remaining objections, Ms. Harvey-Burgin has not overcome the statutory presumption of accuracy to which the transcript is entitled. Her contention concerning the omission of comments allegedly made by the court and plaintiffs’ counsel are entirely inconsistent with the court’s memory of what transpired at the hearing and, moreover, make little contextual sense. The transcript’s failure to reflect certain physical movements made by Ms. Harvey-Burgin is not surprising as such intangibles are typically not captured in a transcript. Her failure to recall the comments made by the court at lines 16 through 25 on page 85 of the transcript is also not surprising given that the comments were made more than one year ago. Nonetheless, they are consistent with the court’s recollection of what transpired.
The court has also asked the court reporter to review independently the transcript of the hearing as well as the stenographic notes of the hearing. As a result of her independent review, the court reporter has filed an amended certified transcript. This certified transcript, consistent with the court’s analysis of Ms. Harvey-Burgin’s objections, reflects only one change from the previous transcript–the deletion of the word “should” from line 15 on page 8. The fact that the amended certified transcript does not reflect any other changes suggested by Ms. Harvey-Burgin assures the court that the court reporter found no evidence supporting those changes in her stenographic notes. See 28 U.S.C. § 753(b).
3

IT IS THEREFORE ORDERED BY THE COURT THAT Ms. Harvey-Burgin’s motion to correct the transcript of the final approval hearing (doc. 4701) is granted in part and denied in part. It is granted to the extent that line 15 on page 8 of the transcript erroneously contains the word “should” (an error that has been corrected in the amended certified transcript) and is otherwise denied.
IT IS SO ORDERED. Dated this 19th day of December, 2008, at Kansas City, Kansas.
s/ John W. Lungstrum___________ John W. Lungstrum United States District Judge
4

 
 U.S. District Court DISTRICT OF KANSAS (Kansas City) CIVIL DOCKET FOR CASE #: 2:03−cv−02200−JWL−DJW

Williams v. Sprint/United Management Company Assigned to: District Judge John W. Lungstrum Referred to: Magistrate Judge David J. Waxse Demand: $1,000,000 Case in other court: 10CCA, 08−03103
10CCA, 08−03196 Cause: 29:621 Job Discrimination (Age)
Special Master

Date Filed: 04/23/2003 Date Terminated: 09/11/2007 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question

John R. Phillips

represented by John R. Phillips Husch Blackwell LLP − 4801 Main 4801 Main Street, Suite 1000 Kansas City, MO 64112 816−983−8119 Fax: 816−983−8080 Email: john.phillips@huschblackwell.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jeffrey Moore

represented by Bert S. Braud The Popham Law Firm, PC 712 Broadway, Suite 100 Kansas City, MO 64105 816−221−2288 Fax: 816−221−3999 Email: bbraud@pophamlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian D. DeFrain D&L Transport 10540 Marty Street, Suite 160 Overland Park, KS 66212 913−40777−7481 Fax: 877−884−9590 Email: brian@dandltrans.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Deborah J. Blakely White Graham Buckley & Carr 19049 E. Valley View Parkway, Suite C Independence, MO 64055 816−373−9080 ext 110 Fax: 816−373−9319 Email: dblakely@wagblaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Dennis E. Egan The Popham Law Firm, PC 712 Broadway, Suite 100 Kansas City, MO 64105 816−221−2288 ext 628 Fax: 816−221−3999 Email: degan@pophamlaw.com LEAD ATTORNEY

ATTORNEY TO BE NOTICED
Dirk L. Hubbard Walters Bender Strohbehn & Vaughan, PC 2500 City Center Square 1100 Main Street Kansas City, MO 64105 816−421−6620 Fax: 816−421−4747 Email: dhubbard@wbsvlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. White Graham Buckley & Carr 19049 E. Valley View Parkway, Suite C Independence, MO 64055 816−373−9080 ext 114 Fax: 816−373−9319 Email: ggraham@wagblaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith Jennifer Martin Smith, Attorney at Law 3836 SE 32nd Street Topeka, KS 66605 785−817−5902 Email: JMSLaw@live.com TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann The Klamann Law Firm 4435 Main Street, Suite 150 Kansas City, MO 64111 816−421−2626 Fax: 816−421−8686 Email: jklamann@klamannlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain Humphrey, Farrington & McClain 221 West Lexington, Suite 400 Independence, MO 64050 816−836−5050 ext 424 Fax: 816−836−8966 Email: kbm@hfmlegal.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers The Meyers Law Firm, LC 503 One Main Plaza 4435 Main Street Kansas City, MO 64111 816−444−8500 Fax: 816−444−8508 Email: mmeyers@meyerslaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis PSUSBSID−NOMAIL

Plaintiff Joe Norton
Plaintiff Robert O. Smith

913−558−6595 Fax: 816−221−3999 LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Teresa Warnick

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Anita Reeves

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Bert R. Allen

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Jesse W. Ballard

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Patricia Barbe

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Michael E. Bauman

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Judy Ann Budihas
Plaintiff William Craig Cezar

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Steven K. Constance

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mark A. Cragin

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Alecia M. Cripps

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Tammy A. Darling

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff James Dawson

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Albert M. Frankovich

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Stephen J. Gallup
Plaintiff Thomas M. Gerrity

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Les Goodwin

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael J. Grahovac

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Bruce Hertzfield

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff William Hicks
Plaintiff Thomas J. Hollingsworth

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Andrew Justesen

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff James A. Loetel

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Sam Matier TERMINATED: 05/18/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Michael McVicker
Plaintiff Joseph A. Morse

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James A. Noah

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff William E. Pitts

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Patricia C. Plantenberg

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Edward O. Rawlings

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Bruce F. Salisbury

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Tony D. Schroeder

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Neil Sieber
Plaintiff Clarence Albert Wildes, Jr.

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Dawne M. Adams

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Constance J. Bonovich

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Agus R. Budiardjo TERMINATED: 04/03/2007

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Jo Belle Crain

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Clifford Deal

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Dan Dietz

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff John L. Eller
Plaintiff Jim Fagan

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Harold Fesmire

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff John Gartin

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Eleanor Jane Gorton

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Rex Hull

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Cheryl L. Hurst

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sally A. Juhn TERMINATED: 11/29/2005
Plaintiff

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Roger Lippold TERMINATED: 03/29/2005
Plaintiff Cathy McNally

Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Kenneth Meinhardt

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Kathy J. Nicol

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert Oakes

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Gary Owens

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Delores Packer

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Barry Pascal
Plaintiff Roy Poe TERMINATED: 06/23/2005

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Melanie Richards

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Norman R. Rutkowski

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Linda Kay Wissman

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Joel R. Blumenthal

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Cheryl Bolton

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alan Boyer
Plaintiff Sharon A. Brown

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Mindy Ann Cleary

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Darrell D. Denton

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Thomas M. Digirlamo

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Pamela A. Emler

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Jeff D. Garland

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff
Juanette Helms−Yates TERMINATED: 06/23/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jerry L. Hipp
Plaintiff Robert D. James

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Eugene R. Laessig

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lawrence M. Matt

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Douglas D. Meng

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Lenore Meng

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Georgia L. Milliren

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Rosemary Milton

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert Nicol TERMINATED: 06/23/2005
Plaintiff Sandra Lynn Norwood−Brown

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Janet Lynn Poletis

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Joseph A. Ritt

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Katherine L. Roe

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Roger L. Rucker

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Nancy Tweedy

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Donald C. Wright
Plaintiff Karen S. Staley

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kenneth Lloyd Ballew

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Edward S. Blinco

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Robert M. Boehm

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Larry L. Brice

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff
Mary Pat Cavanaugh TERMINATED: 05/18/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kenneth E. Donnelly
Plaintiff Barbara R. Frans

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Travis L. French

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jon D. Gallion

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Rebecca Haaven

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Ronald Haefner

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David H. Haksins

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Julia A. Hicks

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bonnie L. Hoopes
Plaintiff John Eldon Hoopes

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Rochelle D. Hughes−Walker

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Wayne Kuzmich

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Ralph J. Kwapiszeski

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff William R. Merchant

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Suzanne C. North

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Gerald F. Portillo

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kenneth Mark Prohoniak
Plaintiff Sharon K. Russo

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Jeri Ann Swafford

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Harold C. Taylor

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Peggy Sturgess

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Mary Jane Jackson

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert D. McManus

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Linda Gayle Westbrook

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gerold L. Blake
Plaintiff Barbara J. Combs

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Brenda H. Coverdale

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kenneth R. Darling

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Patricia A. Meunier−Muenks

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Judith V. Shaw

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Billy Shiplet

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Kim M. Siewert

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Paula M. Barree
Plaintiff Nancy L. Dalton TERMINATED: 06/22/2005

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Carol Lynn Farrow

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jon Marc George

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Linda G. Havens

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Sherri B. Herren

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Werner R. Kalytka

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Carol L. Kippes
Plaintiff Theresa A. Larson TERMINATED: 05/18/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David C. Molz

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address)

Plaintiff Lisa A. Morehart

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bobbie D. Perry

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005

Plaintiff Monica R. Pfister

LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Robin R. Smith

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jeffrey L. Starbuck
Plaintiff Roosevelt J. Draine

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Daniel R. Honeycutt

Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Shirley J. Myers

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Gregory W. Alewel

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Catherine F. Bartholow

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Gordon Dean Brown

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David A. Carmel

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Dale Aaron Dupuis
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Linda Ford TERMINATED: 05/18/2005
Plaintiff Susan Lin

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Brenda M. Long

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Alan D. Rock

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gerry Scott

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Denisa Smith

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Steven R. Smith

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff John A. Stinehour
Plaintiff Ralph James Sweatte

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Benjamin F. Tate

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Aiguel Arredondo, Jr.

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Michael A. Broccoli

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Peggy Virginia Broughton

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Margret L. Bruckner

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John W. Curry

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Arnita Davis−Colter
Plaintiff Eldon J. Elliott

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alvin Enoch

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Edward B. Flournoy

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Joseph Domenic Gallo

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Theresa Leona Goodson

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Sonia A. Graddick

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Hillard Hart

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Maxine E. Jordon
Plaintiff Delbert H. Kelley

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Thomas Lauro

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Jack E. McElroy

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Brenda Joyce Miller

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Marsha Lynn Moody

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Linda B. Newcomer

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alan Otto

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Carol L. Rollins
Plaintiff Stephen C. Rood

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kathleen R. Ruis

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Willie G. Small

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Robert J. Stine

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert A. Valentine

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Patricia A. Whitaker

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Cinda Marie Wittman

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Yvonne Arlene Wood−Olson
Plaintiff Leonard C. Zody

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rodney Abel

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Michael D. Albers

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Lois Eileen Anderson

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sharon Lee Asciutto

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Cortez C. Aylor, III

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bobby Joe Bailey

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Beverly Banks
Plaintiff Michael R. Barbour

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Joesph E. Baughman

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Fred Benjamin

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Gloria Jean Britt

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard Brumbaugh

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Peter Inglis Buchan

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bobby N. Burch

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Loring Bush
Plaintiff Valerie Jean Byrd

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kimberly Yvonne Carlson

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Jerry B. Carnes

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Rafael Carrizales−Yerena

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Rebecca V. Castro TERMINATED: 05/18/2005

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Mary F. Christiansen

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Don Cobb
Plaintiff Miguel Codina

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Evelyn Conner

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Elois Brooks Cotton

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff David Otto Daugherty

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Cheryl Davis

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Leroy Davis

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Charlie Dominguez

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mike Dougherty
Plaintiff Josie L. Doyle

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Willie L. Ellison

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jerald D. Epstein

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Kevin W. Flanagan

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Carolyn J. Gates

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Gary L. Graber

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff
James E. Hamilton TERMINATED: 05/18/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Charles O. Hammond
Plaintiff Theodore Thomas Herring

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Deborah J. Hingston

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Raymond C. Holk

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Linda Hosack

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff
J. Roger Hunt TERMINATED: 04/03/2007

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard A. Izzo

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Kalyan Jana

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David W. Johnson
Plaintiff Stanley N. Jones

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Willie U. Jones

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Stanley Kim

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Mary Kimbrough

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Wallen Ugene Klann

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David R. Klingler

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Nolan R. Krueger

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Philip Leanza
Plaintiff Michael F. Lense

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Lee R. Lewis

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John Littler

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Charles I. Mandrell

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Dianne Maxwell Lambert

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jerry C. McKee

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Rasendra G. Mehta
Plaintiff Dwala K. Miles

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sharon S. Miller

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff William H. Morris

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lana L. Nevils

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Jerald Vernon Nevonen

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Mike John O'Brien

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff William M. O'Loughlin
Plaintiff Mary A. Parks

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Joyce E. Parsons

Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Erik D. Pedersen

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff John Wesley Persaud

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Antoinette M. Phillips

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Gil Pierson

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Roberta S. Pietrzak

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Suzanne T. Reed
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kenneth L. Rhudy
Plaintiff Jean Robinson

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Walter Edward Robinson

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Luis Angel Roman

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff William A. Rosenberg

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Thomas MacRae Ryan

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sandra S. Scott

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Kim Marie Soeder
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert G. Spann
Plaintiff Linda M. Spencer

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Thadeusz Stachow

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Fernando Viera

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Laurie A. Viles

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff William C. Wakerman

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ralph W. Wasko

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Charles Watson
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Darrell R. Webster
Plaintiff Janice Sue Wheeler

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Brenda J. Wilson

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff George K.B. Winful

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sheila Badu Winful

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Joe Lewis Wright

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael G. Wursta

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Andrzej H. Zurniewicz
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Keith R. Allen
Plaintiff Charles E. Appleby

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Christi Sue Austin

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Maury Bimberg

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Leonard Birney

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Thomas Carmalt Blow, II

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gwendolyn Bridges

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Maurice William Castellon
Plaintiff Toni Chang

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lana Sue Coleman

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Edgar L. Cox

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Kathe Leann Cronin

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James P. De La Roche

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Jesse R. Diaz

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David K. Dober

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Carole L. Enyings
Plaintiff Elizabeth Evans

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rebecca G. Ferrell

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Edmund Brian Fick

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Everlee J. Flanigan

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John James Fleming

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Paula L. Fonzo

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert Fowler

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Donald D. Franklin
Plaintiff Nancy Fretwell

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kathleen S. Fulton

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Mary L. Gaston−Davis

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Deborah Gibson

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Earlene Gillespie

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Glenn Golden

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Russell D.T. Gorrell, Jr.

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Walter C. Gross, Jr.
Plaintiff Richard Guth

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ronald J. Guzell

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Richard D. Harper

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Jane Pleasants Hathaway

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Gloria D. Hevener

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Garry Wayne Hicks

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Stephen Homan TERMINATED: 03/27/2006
Plaintiff Ralph F. Horne

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Linda J. Horton

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gene R. Huffman

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Inez E. Jenkins

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Veletta Johnson

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Virginia L. Johnson

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Roger S. Kelly

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Suzanne C. Kilpatrick
Plaintiff Rosemary Kocher

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Barbara Ann Kuklenski

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Christina Y. Lane

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Adrienne E. Lanigan

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Paul J. LeMay

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Norman Londot

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Aaron Lott, Jr.

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ronald Matz
Plaintiff Diana L. McNabney

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Denise Ann Moles

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rafael A. Molina

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Deborah P. Morton

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Terri Murray

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Adrian J. O'Boyle

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Rose F. Parker

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mark Daniel Provost
Plaintiff Thomas H. Rasco

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address)

Plaintiff Steven M. Rich

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Robert S. Robinson TERMINATED: 06/23/2005

Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Robert Louis Rumel

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Betty E. Ryder

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gary W. Schafer

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Gary L. Scott
Plaintiff Gladys J. Searcy

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Colleen Shockey

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Douglas Wayne Simerly

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James L. Smith

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Julie Louise Smith

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Walter Stanton

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jeffrey Strogin
Plaintiff Michael S. Swaim

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff William F. Tarr

Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff John J. Thomas, IV

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Terry R. Thomas

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Vella M. Thomasson

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Judith D. Tinnell

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard Jeffrey Vogel

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Michael E. Votypka
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Rex Allen Webb
Plaintiff Robert L. Westphal

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Julius Williams

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Colleen J. Wirt

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rocio Wright

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Mark R. Yengle

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kathleen T. Young

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Gloria Adamson
Plaintiff Robert Hunter Anderson

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Russell Asato

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Marsha Baldwin

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Bonnie B. Balliet

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff William J. Beaver

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Dinah L. Blackmon

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Diane K. Bland

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff David H. Boyer
Plaintiff Robert Bruce Brower

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert Earl Brown

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Sheila Bruce

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Steven Dale Colton

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Debra Ann Cook

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Cynthia Gail Crews

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lennox K. Danielson

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Donald Richard Darden
Plaintiff James G. Davidson

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Anthony V. Dilluvio

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Susan C. Doherty

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Sandra J. Eastin

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Brenda Edoukoun

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Sandra Fay Tompkins Edwards

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James Elder, III

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Mary F. Gilbert
Plaintiff Marijo Goetz

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Glenda O. Hayes

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Paul Hefley

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Diane R. Helton

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kevin L. Henry

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff William Bradley Herring, III

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Dawn Johnson

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Marlene A. Karbula
Plaintiff Thomas L. Kulka

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Anne W. Logue

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Bradley C. Mayeux

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Susan A. Melton

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Carla Merlotti

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Carol Morahan

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael Stephen Nabi

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Richard Nelli
Plaintiff Randolph H. Phillips

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John M. Schafer

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff John C. Scheele

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Donald M. Shook

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sharon L. Shults

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Reginald Simmons

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Leslie Slow−Goldfine

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Mark R. Smith
Plaintiff Michael David Tate

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Howard L. Tiffany

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Sandra L. Wardell

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Wendell D. Wilson

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Larry W. Allen

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Mamadou Badiane

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sherrie Bartlett

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Edward Russell Birch
Plaintiff Julie Bowden

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Roy Bradford

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Marion Branch

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Belinda A. Brown

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Daniel R. Byrne TERMINATED: 04/03/2007

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Patricia A. Cahoon

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Joseph F. Carroll

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff LaVerne Clark
Plaintiff Gregory S. Collins

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael Conradi

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Francis J. Correll

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Kenneth P. Cromley

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Carl Fallik

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff David Hunter Fitzgerald

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael J. Frost

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Deborah Ann Gant
Plaintiff Robert Goodman

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Clel A. Hall

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Emma J. Hancock

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Gary R. Hanson

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff M. Diane Hostetter

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff Kent Thomas Humphry

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bertie Lynette Justice

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY

Plaintiff Inder Kainth
Plaintiff Dennis C. Klemp

ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Barbara J. Lamar

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY

Plaintiff Debra A. Leeds

ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard

Plaintiff Kathy J. Lockaby

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kevin Marshall

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address)

Plaintiff
Kathleen C. Martin TERMINATED: 05/18/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Yolanda Mathews
Plaintiff Gerard W. Mercuri

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Connie M. Miller

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Henry B. Miller

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Karen J. Miller

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Paul W. Myers

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Gail N. Nishida

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Michael J. Read

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Cecile Grimwood Richardson
Plaintiff Yvonne R. Richardson

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Myron J. Rittenhouse

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jacob Rodriguez

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff William Rose

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Elizabeth L. Roy

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Steve Rubin

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Regina D. Shadle

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David Sharp
Plaintiff Paul Solomon

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Mark S. Stone

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Patrick H. Stritch

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY

Plaintiff Donald A. Summers

ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr.

Plaintiff Michelle L. Palmer Washington

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY

Plaintiff Patricia Ann Webster

John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Lisa Marie White−Turney

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Philip G. Williamson
Plaintiff Cheryl Elliott Wilson

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address)

Plaintiff Dennis Wilson

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Yanwen Xia TERMINATED: 11/29/2005

Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY

Plaintiff Richard Zabic

ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith

Plaintiff Jerry Zolman

(See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael E. Brief

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address)

Plaintiff Karen Anita Byrd

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gwendolyn J. Frison TERMINATED: 05/18/2005
Plaintiff Delaino L. Jones

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Debra Susan Kramer

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael E. Potter

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Aaron N. Shaddox

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Lang H. Tran

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sandra M. Washington

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Chris Willoughby
Plaintiff Diana J. Anderson

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Larry D. Auxier

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Henry Ayer, Jr.

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Renee M. Balcom

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY

Plaintiff Patricia A. Bicknell

ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann

Plaintiff Sandra Lynn Brown

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Judith A. Buckner

Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address)

Plaintiff Betty P. Cabello
Plaintiff Sharon T. Carmody

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Carmen M. Chandler

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address)

Plaintiff Rostine Coleman

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
Carlotta C. Craft TERMINATED: 05/18/2005

Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005

Plaintiff Charles David Curtis

LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Margaret DeGennaro

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert D. Eicher
Plaintiff Charles W. Fisher

Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Delbert Harrison Flint

Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Marcus A. Fortier, Jr.

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Diane Geier

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Charles B. George

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Sharon J. Hindenach

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Wendell A. Hines

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Robert C. Huffer
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cheryl R. Jackson
Plaintiff Sheryl Yvonne Jones

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff John Karcher

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Carol A. Kirk

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Leslie H. Kreger

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Frank J. Kulikowski

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kathleen D. McBride

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Francis J. McDonough
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Janelle D. McMechan
Plaintiff Brian K. McNiff, Sr.

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Marvin Mizrahi

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Louis Isiah Moorman

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alberta M. Nichols

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Teresa Lynn Nichols

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Clara Perkins

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Clifton Odell Pryor
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sandra K. Ridings
Plaintiff Kevin S. Rowan

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Leonard J. Schiffer

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Roger Allen Sherburne

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael B. Smith

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Valerie Smith

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Susan Ann Snider

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Michael J. Sumner
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Denise M. Svacina
Plaintiff Thomas A. Taylor

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Malcolm Tears

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Veretta B. Thomas

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Danny R. Van Voorhis

Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address)

Plaintiff Kelvin Lynn Vineyard

TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff J. Steven Whayne

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY

Plaintiff Jeffrey Richard Whiteside
Plaintiff

ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Joseph F. Williams
Plaintiff Thomas V. Woodall

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Robert L. Yarmo

ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan

Plaintiff Lisa J. Zolman

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael A. Affolder
Plaintiff Edward J. Anstead
Plaintiff Janice L. Biehls
Plaintiff John H. Boldrey

Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen J. Dennis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Douglas Bolton TERMINATED: 05/18/2005 Plaintiff Joe Chan
Plaintiff Worth Joe Clark
Plaintiff Judith P. Cobb
Plaintiff Debra R. Davis
Plaintiff Phyllis A. Drake

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Jeffrey L. Dunbar
Plaintiff Matthew S. Dunn
Plaintiff Deborah A. Ehr
Plaintiff Thomas W. Falls
Plaintiff Peter B. Flum

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jakov Gavrushenko
Plaintiff David Golan
Plaintiff Marvin J. Gomez
Plaintiff Sheree L. Goodhart
Plaintiff Robert J. Harris
Plaintiff Ruby J. Harvey−Burgin

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Ruby J. Harvey−Burgin 807 N. Adele, Unit A Orange, CA 92867 PRO SE

Plaintiff John Fred Hopson
Plaintiff Carolyn J. Horner
Plaintiff Earl Hughes
Plaintiff Larry G. James
Plaintiff Joseph Jerrick

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Bonnie Lee Kennon
Plaintiff John F. Kenny
Plaintiff Kermie Carroll Lackey
Plaintiff Sally Leon−Guerrero
Plaintiff Judith R. Limbach
Plaintiff Lorraine M. Martin

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Sharon E. McCarty
Plaintiff Jacquie K. Mitchell
Plaintiff Phyllis Marie Moore
Plaintiff Ralph Moore
Plaintiff Robert E. Moore

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rebecca Neff
Plaintiff Jose R. Nieves
Plaintiff Donna B. Noble
Plaintiff Brian J. O'Connor
Plaintiff Linda E. Palacios−Ramirez
Plaintiff Rebecca Ann Perry

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Arnie Phillips
Plaintiff Chaitram Raghu
Plaintiff Pamela J. Raines
Plaintiff Louis G. Rocha
Plaintiff Randall C. Schulenberg
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Joseph Sciulli
Plaintiff Shirley Sebeniecher
Plaintiff David T. Settles
Plaintiff Shiverla K. Shannon
Plaintiff Jane O'Neal Smith
Plaintiff Patricia Szekely

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Jennifer Lee Titus
Plaintiff Curtis M. Tostie
Plaintiff Nikimi D. Ward
Plaintiff Jimmy Williams
Plaintiff Joan M. Boro
Plaintiff Janise L. Collins

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff William Anthony Dandridge
Plaintiff Mary L. DeVore
Plaintiff Scott Farley
Plaintiff Jonathan L. Fry
Plaintiff Robert R. Harris

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Arline B. Hodges TERMINATED: 03/29/2005 Plaintiff Pamela S. Huffman
Plaintiff Harry G. Kavalary
Plaintiff Gerald P. Keith
Plaintiff Connie G. Krenning
Plaintiff Sharon Mendoza

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Linda S. Parker
Plaintiff Rebecca S. Perkins
Plaintiff Michelle Stone
Plaintiff Ronald T. Stoner
Plaintiff Maggie E. Thomason
Plaintiff Wade H. Toubassi

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Valerie D. Vann
Plaintiff Peggy Eileen Watkins−Case
Plaintiff Esteban S. Yepez
Plaintiff Sharon Kay Adams
Plaintiff Steven L. Brown
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Douglas L. Curts
Plaintiff Mary Beth Harford
Plaintiff Donna R. Kofsky
Plaintiff Bobbie J. Mitchell
Plaintiff Scott T. Rowe
Plaintiff Warren Snitzer

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Kevin Daryl Brown
Plaintiff Mitchel Robert Carlson
Plaintiff Walter V. Emery
Plaintiff Cindy Engelbrecht TERMINATED: 06/22/2005 Plaintiff Earl L. Fowler TERMINATED: 06/23/2005 Plaintiff Barbara J. Gibbs TERMINATED: 06/23/2005 Plaintiff Linda S. Hague

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Evelyn J. Hildebrand
Plaintiff Martha M. Lally TERMINATED: 05/18/2005 Plaintiff Kenneth A. Machamer TERMINATED: 06/23/2005 Plaintiff Kathryn J. McCourt
Plaintiff William A. McSpadden TERMINATED: 06/23/2005 Plaintiff Glenda R. Mixer
Plaintiff Julio M. Morales

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Tom Rohlfing TERMINATED: 06/23/2005 Plaintiff David L. Schaecher
Plaintiff Ronald Wayne Schutte
Plaintiff Jeffrey C. Shipley
Plaintiff Gregory L. Simmons TERMINATED: 03/29/2005 Plaintiff Wesley Lee Tyree

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Timothy Marshall Boyd
Plaintiff Chuck Diaz TERMINATED: 06/22/2005 Plaintiff David L. Jungert
Plaintiff Katherine A. Ritchie TERMINATED: 06/23/2005 Plaintiff Gladys M. Sanderson
Plaintiff David G. Weerts TERMINATED: 06/23/2005 Plaintiff Samuel E. Bagwell

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David C. Brage TERMINATED: 03/29/2005
Plaintiff Susan Eriksen
Plaintiff Edward A. Espinosa TERMINATED: 03/29/2005
Plaintiff Regina Gail Meeks TERMINATED: 03/29/2005
Plaintiff Leonard E. Fus TERMINATED: 03/29/2005
Plaintiff James D. Gideon TERMINATED: 06/23/2005
Plaintiff Cheryl J. Johnson
Plaintiff Vera M. Kipper

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Roger D. Leimkuehler
Plaintiff Richard S. Mason
Plaintiff Rita Miller
Plaintiff Mark Oglesby TERMINATED: 06/23/2005 Plaintiff James W. Parsons
Plaintiff Duane Porter

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Robert Lee Rogers
Plaintiff Karen Shertz
Plaintiff Mary Catherine Swett TERMINATED: 03/29/2005
Plaintiff Sherry Lee VanNoy TERMINATED: 06/23/2005
Plaintiff John A. Wansing TERMINATED: 03/29/2005
Plaintiff Kenneth A. Cronk
Plaintiff David L. Evans TERMINATED: 03/29/2005

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff JoAnn Hughes TERMINATED: 06/23/2005 Plaintiff Bradley F. Rogers TERMINATED: 06/23/2005 Plaintiff Paul Rowland
Plaintiff Anthony F. Seelza
Plaintiff Morris Edward Smith
Plaintiff Mariellen Bell Wiemann
Plaintiff Albert M. Atkinson

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Stephen J. Bek TERMINATED: 06/22/2005 Plaintiff Bernard W. Mayse
Plaintiff Earl H. Boyd TERMINATED: 06/22/2005 Plaintiff Anthony F. Scelza TERMINATED: 06/27/2005
Plaintiff Douglas H. Freeman

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sarah A. Brown Brown & Curry, LLC 406 W. 34th Street, Suite 810 Kansas City, MO 64111 816−756−5458 Fax: 816−666−9596 Email: sarah@brownandcurry.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Reta M. Juiliano
Plaintiff Charles H. Kroll TERMINATED: 06/23/2005 Plaintiff David L. Lanter
Plaintiff Pyotr Lipavsky
Plaintiff Paul James McAllister
Plaintiff Ronald M. Mears

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael Meyer TERMINATED: 06/23/2005 Plaintiff Virginia J. Nooner TERMINATED: 03/29/2005 Plaintiff Kathleen M. Parks
Plaintiff Sherry Peterson TERMINATED: 03/29/2005 Plaintiff Catherine Prazenica
Plaintiff Craig T. Price
Plaintiff Cathy R. Sanders

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Clifford W. Schick TERMINATED: 06/23/2005
Plaintiff Eddie T. Settles TERMINATED: 03/29/2005
Plaintiff Syed Sa Shah TERMINATED: 03/29/2005
Plaintiff Megan M. Spohrer TERMINATED: 03/29/2005
Plaintiff Richard Allen Starling
Plaintiff Mavis L. Tuttle
Plaintiff Ida M. Walker TERMINATED: 03/29/2005
Plaintiff William R. White

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Thomas A. Armstrong
Plaintiff Bruce J. Beard TERMINATED: 06/22/2005
Plaintiff Lorraine M. Hatz TERMINATED: 05/18/2005
Plaintiff Patricia Ann Jackson TERMINATED: 05/18/2005
Plaintiff Betty Minard TERMINATED: 03/29/2005
Plaintiff Edith M. Nelson TERMINATED: 06/23/2005
Plaintiff Michael Rhodes TERMINATED: 06/23/2005
Plaintiff Karen F. Rook TERMINATED: 03/29/2005
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Michelle T. Shaw
Plaintiff Teri S. Shelton TERMINATED: 06/23/2005 Plaintiff Ivan Blue
Plaintiff Sue B. Britt
Plaintiff David McNeill
Plaintiff Dominic V. Orlando
Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Terresa E. Rodriguez
Plaintiff Mary Frances Williams
Plaintiff Lauden T. Adams
Plaintiff Christopher Allen TERMINATED: 06/22/2005 Plaintiff Steve L. Bidwell
Plaintiff James K. Blake TERMINATED: 03/29/2005 Plaintiff David C. Bryant

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff William Eddy TERMINATED: 03/29/2005
Plaintiff Priscilla Yvonne Ferden TERMINATED: 06/22/2005
Plaintiff Robert Kolterman
Plaintiff Giray H. Koprucu
Plaintiff Debbie Jo Krsa Pellegrino
Plaintiff Lynn Anne Lee TERMINATED: 06/23/2005
Plaintiff Howell D. McClain TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Walter Franklin McKinley, Jr.
Plaintiff Kathleen M. Miles TERMINATED: 03/29/2005
Plaintiff Carrie L. Moore TERMINATED: 06/23/2005
Plaintiff Stephen Petty
Plaintiff David V. Poggi TERMINATED: 03/29/2005
Plaintiff Daniel L. Robbins TERMINATED: 06/23/2005
Plaintiff Margaret S. Roberts
Plaintiff Joyce E. Swarn

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Steve S. Voultepsis
Plaintiff Linda L. Altman
Plaintiff John Wesley Atkins TERMINATED: 06/22/2005 Plaintiff Katalin Buffington TERMINATED: 06/22/2005 Plaintiff Cynthia Muse Christopher
Plaintiff Teresa M. Commons−Moore

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mari Dauphine TERMINATED: 06/22/2005 Plaintiff Myra Jan De Vall
Plaintiff Carol Irene Faucher
Plaintiff Rebecca S. George TERMINATED: 06/23/2005 Plaintiff Harold E. Gray, III
Plaintiff Joy L. Gregg

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ronald E. Hebert
Plaintiff Dale W. Husbands
Plaintiff Lynn B. Iffland TERMINATED: 03/29/2005 Plaintiff Susan K. Jacobson
Plaintiff Sandra E. Janini TERMINATED: 06/23/2005 Plaintiff Daniel Wayne Knodle
Plaintiff Donna L. Krug TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Elizabeth Ann Mahoney TERMINATED: 03/29/2005 Plaintiff Lloyd M. Mallory
Plaintiff Nanci Myer
Plaintiff Jeanette Norwood TERMINATED: 03/29/2005 Plaintiff Henry D. Pohl
Plaintiff Dennis Potwora TERMINATED: 06/23/2005 Plaintiff Jesse S. Sanders

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Ronald C. Stein
Plaintiff Ian Stong
Plaintiff Linda S. Turner
Plaintiff Peter J. Volante
Plaintiff Robert L. Wittenberg TERMINATED: 06/23/2005 Plaintiff Hugh T. Womer TERMINATED: 03/29/2005 Plaintiff Jeffery D. Baker TERMINATED: 06/22/2005

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Raymond Joseph Ballan TERMINATED: 03/29/2005 Plaintiff Ann Marie Bohlander
Plaintiff Karen S. Breshears
Plaintiff Cynthia L. Brewer−Bulk
Plaintiff James R. Canter TERMINATED: 03/27/2006
Plaintiff Samir S. Demian

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Elizabeth A. Floyd TERMINATED: 06/23/2005
Plaintiff Robert G. Hannaway, Jr.
Plaintiff David E. Fraser TERMINATED: 06/23/2005
Plaintiff Janice C. Guidry TERMINATED: 06/23/2005
Plaintiff James Michael Harper TERMINATED: 06/23/2005
Plaintiff Buddy Edward Jedd TERMINATED: 06/23/2005
Plaintiff Ruth Kagan
Plaintiff Amr Khalifa TERMINATED: 06/23/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lynda M. Kidwell TERMINATED: 06/23/2005
Plaintiff Michael A. LaMontia
Plaintiff Karen D. McCarty TERMINATED: 06/23/2005
Plaintiff Hugh M. Menking TERMINATED: 03/29/2005
Plaintiff Vera Ortega TERMINATED: 06/23/2005
Plaintiff Debra Morales Perry
Plaintiff Linda A. Peterson
Plaintiff

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Michael C. Petronella TERMINATED: 06/23/2005 Plaintiff Karl Paul Pettigrew
Plaintiff Ruth Ann Richardson
Plaintiff Debra Joyce Sherrod
Plaintiff Robert H. Steinmetz
Plaintiff Jo Ellen Strahle TERMINATED: 06/23/2005 Plaintiff Fulvia Hoffmann TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Kelly Koop TERMINATED: 06/23/2005 Plaintiff Randall R. Warren TERMINATED: 03/29/2005 Plaintiff Curtis R. White
Plaintiff Jon Zeiger
Plaintiff Heyun Zheng TERMINATED: 06/23/2005 Plaintiff Robert E. LaGrand, Jr.
Plaintiff Soledad Marie Leath

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Anita M. Lock
Plaintiff Donna E. Allman TERMINATED: 06/22/2005 Plaintiff Shandy McCollough
Plaintiff Joe Kevin McGowan
Plaintiff Martha J. Alley
Plaintiff Walter Roy Copeland TERMINATED: 05/18/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John Eckholm
Plaintiff Mark W. Lundy
Plaintiff James McCance
Plaintiff Robert L. McIlrath
Plaintiff David S. Nichols
Plaintiff Gary Douglas Urton

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Thomas David Waddell
Plaintiff Khaled Al−Zouhbi
Plaintiff Tamara Arlene Ansaldo
Plaintiff Marilyn J. Balderson
Plaintiff Robyn M. Barrett TERMINATED: 06/22/2005 Plaintiff Terri Bogina

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michelle Brauer TERMINATED: 06/22/2005 Plaintiff Terry Bridges
Plaintiff Kathy Marie Britton
Plaintiff Mark S. Capell
Plaintiff Leslie Joe Coker TERMINATED: 06/22/2005 Plaintiff Patricia A. Coker

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James R. Colyer TERMINATED: 06/22/2005 Plaintiff Augustine Alvin Cotten
Plaintiff Donald K. Cowick
Plaintiff James Pat Beard
Plaintiff Jill E. Michaels TERMINATED: 06/23/2005 Plaintiff Willie Mack Palmer TERMINATED: 06/23/2005 Plaintiff Phil Bodine

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Charles F. Breinninger TERMINATED: 03/29/2005 Plaintiff Lynda Day
Plaintiff Vicki Dickinson
Plaintiff Bobbie J. Dunn
Plaintiff John F. Dunne
Plaintiff

Mark V. Bodine Bennett Bodine & Waters 11125 Johnson Drive Shawnee, KS 66203 913−948−7900 Fax: 913−948−7901 Email: mbodine@bbw−law.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cynthia R. Erwert
Plaintiff Karry W. Foster TERMINATED: 06/23/2005
Plaintiff James H. Franklin TERMINATED: 06/23/2005
Plaintiff Jeffrey L. Gaughan TERMINATED: 06/23/2005
Plaintiff Glenn T. Gillihan
Plaintiff Merrie M. Glenn
Plaintiff Sharon K. Goldring TERMINATED: 03/29/2005
Plaintiff Martha Harry

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Paul J. Hartl
Plaintiff Myra Penny Hobley
Plaintiff Sherry Lynn Hudson TERMINATED: 06/23/2005 Plaintiff Chaim Ivry TERMINATED: 06/23/2005 Plaintiff Kumkum A. Jain
Plaintiff Ricky A. Jordan

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rufus J. Kemp
Plaintiff Patricia A. Ricketts TERMINATED: 06/23/2005 Plaintiff Dennis C. Wike
Plaintiff Debra Fields−Williams
Plaintiff Benjamin Woodrow Fincher TERMINATED: 03/29/2005 Plaintiff Timothy L. Armintrout
Plaintiff Joanne K. Foster

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Virender Kumar
Plaintiff Donald Eugene Freeman
Plaintiff Michael J. Hayde
Plaintiff Jeanne D. Logan
Plaintiff Shirley Hodge TERMINATED: 06/23/2005 Plaintiff John Barry Kite

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Justine E. Bowen Koch TERMINATED: 06/23/2005
Plaintiff Harrell Wayne Lewis TERMINATED: 06/23/2005
Plaintiff Jean Lofflin TERMINATED: 06/23/2005
Plaintiff Bruce Logsdon
Plaintiff Patricia Dill McAdam TERMINATED: 06/23/2005
Plaintiff Deborah McDonald
Plaintiff Sara E. Nelson TERMINATED: 03/29/2005
Plaintiff

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Stephen Curtis Newton
Plaintiff Christian U. Nwabara TERMINATED: 06/23/2005 Plaintiff Larry L. O'Neil
Plaintiff Richard G. Parks TERMINATED: 06/23/2005 Plaintiff Charles N. Parrish
Plaintiff Warren P. Pierson, III TERMINATED: 03/29/2005 Plaintiff Michael B. Renner

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Tracy Rickett TERMINATED: 03/29/2005 Plaintiff Phillip Rosenfeld
Plaintiff Kenneth J. Sawyer TERMINATED: 06/23/2005 Plaintiff Julie F. Schuman
Plaintiff Gary Nolte TERMINATED: 04/03/2007
Plaintiff Deborah Lynn Phillips
Plaintiff Mary L. Secrest

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Wendy Shaeffer
Plaintiff Preston Stauffer
Plaintiff Ann G. Stephens TERMINATED: 04/01/2005 Plaintiff Daniel L. Strader
Plaintiff Michael K. Stubbs TERMINATED: 06/23/2005 Plaintiff Bruce C. Voiles

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Albert Wood, Jr.
Plaintiff David Janiga
Plaintiff Cortez H. Liggins
Plaintiff Peggy Sue McRedmond TERMINATED: 06/23/2005 Plaintiff Cheryle Moore TERMINATED: 05/18/2005 Plaintiff Bonnie B. Watts TERMINATED: 03/29/2005 Plaintiff Kenneth R. Murry

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Carole A. Young
Plaintiff Brian R. Orner
Plaintiff Annette Boldridge
Plaintiff Scott D. Graham
Plaintiff Ronald E. Hammond TERMINATED: 05/18/2005 Plaintiff Charles M. Miner

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Loreatha E. Nicholson TERMINATED: 05/18/2005 Plaintiff Steven T. Spackeen
Plaintiff Jack A. Vielleux
Plaintiff Stacy L. Villines
Plaintiff Christine Vose
Plaintiff Josephine Zloty

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff John Buglino
Plaintiff Lynn M. Abud TERMINATED: 06/22/2005 Plaintiff Dave Compton
Plaintiff Robert S. Davis
Plaintiff Rich Reindel
Plaintiff Sally Genise Nelson

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Donna Lee A. Andrews
Plaintiff Godfrey I. Archibong
Plaintiff Derek R. Bailey TERMINATED: 06/22/2005 Plaintiff Betsy Berens
Plaintiff Thomas E. Bleckley TERMINATED: 06/22/2005 Plaintiff Lois R. Boldt
Plaintiff James Eldon Boynton

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff David S. Bresnahan
Plaintiff Christine Carnahan
Plaintiff Bertha W. Carter TERMINATED: 06/22/2005 Plaintiff Ginger Chase
Plaintiff Denise Criddle−Jenkins
Plaintiff Susan M. D'Alessandro

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff John Kelly Dannelley
Plaintiff Janet S. Deckard
Plaintiff John D. Toole TERMINATED: 06/23/2005 Plaintiff Michael E. Tekampe
Plaintiff Nancy M. Demorest
Plaintiff Timothy E. Demorest

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Janette M. Diehl
Plaintiff Timothy Dillon TERMINATED: 03/29/2005
Plaintiff Melvyn Dunkerley TERMINATED: 11/29/2005
Plaintiff Diane Eberhart TERMINATED: 06/22/2005
Plaintiff Catherine Evans
Plaintiff Bruce H. Fields TERMINATED: 06/23/2005
Plaintiff Patricia Eileen Fierst

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Thomas C. Foerster TERMINATED: 06/23/2005
Plaintiff Alan M. Freemire
Plaintiff Kathryn C. Gardner
Plaintiff Byron Gudmestad TERMINATED: 06/23/2005
Plaintiff Connie L. Gutierrez TERMINATED: 06/23/2005
Plaintiff Clarence R. Hanson
Plaintiff Jack Michael Harry TERMINATED: 03/29/2005

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ronald Dean Havens
Plaintiff Joseph E. Hernandez TERMINATED: 06/23/2005 Plaintiff Drema H. Hill
Plaintiff Charline Whipper TERMINATED: 05/18/2005 Plaintiff Karen Flores−Pell TERMINATED: 06/23/2005 Plaintiff Michael Johnson
Plaintiff Robert E. Johnson

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Everton W. Knight TERMINATED: 06/23/2005 Plaintiff Robert Williams Kunkle
Plaintiff Dena Janetta Lee TERMINATED: 05/18/2005 Plaintiff William Thomas Lightfoot
Plaintiff James A. Mitchell TERMINATED: 06/23/2005 Plaintiff Douglas L. Neudeck
Plaintiff Kevin Leo Neuer

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Kalayla O'Connor
Plaintiff Donald W. Payne
Plaintiff Thomas Portee TERMINATED: 06/23/2005 Plaintiff Charles Wyane Ratliff
Plaintiff Wayne Snyder TERMINATED: 06/23/2005 Plaintiff Rose Wollfrey TERMINATED: 04/01/2005 Plaintiff James J. Aragon

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Andre A. Begin TERMINATED: 06/22/2005 Plaintiff Linda Bernskoetter
Plaintiff Brenda J. Caldwell
Plaintiff John W. Dedovesh TERMINATED: 03/29/2005 Plaintiff Rhonda L. Dents
Plaintiff Ralph E. Evans
Plaintiff

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Ronald F. Frampton
Plaintiff Robert E. Groeger TERMINATED: 03/29/2005 Plaintiff Aryan Heydari
Plaintiff Kenneth E. Horner
Plaintiff Margaret A. Kennedy
Plaintiff Marla S. Lowe
Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert James Nielsen
Plaintiff Nicholas M. Romanich
Plaintiff Judith A. Shafer
Plaintiff Laura M. Sumner TERMINATED: 03/29/2005 Plaintiff Pearl M. Walker TERMINATED: 06/23/2005 Plaintiff Glenda Wilson−Brown
Plaintiff John Wesley Wright

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gary J. App
Plaintiff Don Broome
Plaintiff Ken Chevasin
Plaintiff Judy E. Coughlin
Plaintiff Robert D. Ferguson
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

E. Blair Ford TERMINATED: 06/23/2005
Plaintiff Julia W. Frei
Plaintiff Oneeda W. Gerald TERMINATED: 06/23/2005
Plaintiff Lee G. Haglund TERMINATED: 06/23/2005
Plaintiff Husain A. Hasham
Plaintiff Fairlyon E. Hill
Plaintiff Mickey Mae Hobbs TERMINATED: 06/23/2005
Plaintiff Gary D. Jackson

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Cyrus Matin−Nia
Plaintiff Ann Miller
Plaintiff Jimmie L. Norfleet
Plaintiff Robert M. Schaffer
Plaintiff Thomas A. Strickland TERMINATED: 06/23/2005 Plaintiff Katherine A. Trummer TERMINATED: 03/29/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Anne Welty TERMINATED: 03/29/2005 Plaintiff Gary L. Bailey
Plaintiff Thomas L. Ginnick TERMINATED: 06/23/2005 Plaintiff Richard Leon Harris TERMINATED: 06/23/2005 Plaintiff Iza Pyatt
Plaintiff Thaddeus R. Sobon
Plaintiff Karen R. Abolt

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Jean Ann Forester TERMINATED: 06/23/2005
Plaintiff Roy J. Gregerson TERMINATED: 05/18/2005
Plaintiff Teresa Ann Hemingway
Plaintiff Michael Hinson TERMINATED: 03/29/2005
Plaintiff David C. Hinton
Plaintiff Lilllian Hodges TERMINATED: 05/18/2005
Plaintiff Craig D. Jones TERMINATED: 06/23/2005
Plaintiff Howard Owen Holbrook

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gerry Hollingshead
Plaintiff Lemuel B. Ivie TERMINATED: 06/23/2005
Plaintiff Thomas Michael Jackson TERMINATED: 03/29/2005
Plaintiff Jeffrey O.C. Johnson TERMINATED: 06/23/2005
Plaintiff Willie James Johnson, Jr. TERMINATED: 03/29/2005
Plaintiff Larry M. Jurak
Plaintiff Carole L. Kann

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Elizabeth D. Kaufman TERMINATED: 06/23/2005 Plaintiff Leslie U. Kimiecik
Plaintiff Burma Knowles
Plaintiff Steven D. Koch
Plaintiff David E. Koerner
Plaintiff William Russell Kumpe TERMINATED: 06/23/2005 Plaintiff John T. Kurpinski, Sr. TERMINATED: 03/29/2005

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Carol Laundy
Plaintiff Bernice Lewis TERMINATED: 03/29/2005 Plaintiff David L. Lingardo
Plaintiff Amy Lutz TERMINATED: 03/29/2005 Plaintiff Anthony M. Martucci
Plaintiff Jeanne M. Miller
Plaintiff Nelda J. Monroe TERMINATED: 06/23/2005

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Edward Anthony Mosczynski
Plaintiff Michael F. Nicosia TERMINATED: 05/18/2005
Plaintiff Jeong Oh
Plaintiff Donna S. Oltmann TERMINATED: 03/29/2005
Plaintiff Farifteh Parniani−Eatman
Plaintiff Vincent Perlongo TERMINATED: 06/23/2005
Plaintiff Anthony Pierce TERMINATED: 06/23/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Diana Pinkins TERMINATED: 06/23/2005 Plaintiff Carlos J. Poteet, Jr.
Plaintiff Susan T. Pringle TERMINATED: 06/23/2005 Plaintiff Michael Edwin Ragan
Plaintiff David A. Ray
Plaintiff Daniel J. Roberts TERMINATED: 06/23/2005 Plaintiff John Garland Roberts

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alissa Karen Ross
Plaintiff Joyce A. Savage
Plaintiff Ralph B. Schneider TERMINATED: 06/23/2005 Plaintiff Toni Selman TERMINATED: 06/23/2005 Plaintiff Russell C. Simmons TERMINATED: 04/01/2005 Plaintiff Victoria Rose Simone
Plaintiff Jeffrey B. Anderson

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Veronica C. Armstrong
Plaintiff Loyal Charles Auman TERMINATED: 03/29/2005 Plaintiff Karen L. Barquist
Plaintiff Jeanette M. Bass
Plaintiff Elmer Leroy Benson
Plaintiff Sharon Berlint TERMINATED: 06/22/2005 Plaintiff Robert Harry Biniek

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Bobby Harold Boggs
Plaintiff James R. Bollinger
Plaintiff Thomas A. Bradley TERMINATED: 05/18/2005 Plaintiff Richard M. Breitenbach
Plaintiff Joan K. Burton TERMINATED: 03/29/2005 Plaintiff John J. Carter

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Lucy Chapa
Plaintiff Janiece Ann Cline
Plaintiff Richard J. Clisso TERMINATED: 03/29/2005 Plaintiff Robert E. Cody TERMINATED: 05/18/2005 Plaintiff Lonnie Aaron Daniels
Plaintiff Richard F. Danjou TERMINATED: 03/29/2005 Plaintiff Susan L. Davidson

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Beatrice M. Dewing
Plaintiff Dennis Eugene Edney
Plaintiff Gladys Marie English TERMINATED: 06/22/2005 Plaintiff A. Ron Evangelista
Plaintiff James S. Fish
Plaintiff Lisa R. Franceschini

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff James E. Friendly TERMINATED: 06/23/2005 Plaintiff Judy K. Gaffney
Plaintiff Michael D. Gaffney
Plaintiff Fred Giuntini TERMINATED: 05/18/2005 Plaintiff Robert Graham
Plaintiff Walter D. Grba
Plaintiff

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert W. Greenhut TERMINATED: 06/23/2005 Plaintiff Greg Harper
Plaintiff Ronald Keith Harper
Plaintiff Patricia M. Harrelson TERMINATED: 06/23/2005 Plaintiff Teresa L. Harris
Plaintiff Angela Haynes
Plaintiff Joan M. Heacker

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John Hendrix
Plaintiff Dixie L. Heyl TERMINATED: 06/23/2005
Plaintiff Sheldon G. Hootner
Plaintiff Joe A. Jamison TERMINATED: 06/23/2005
Plaintiff Linda C. Johns TERMINATED: 03/29/2005
Plaintiff Linda L. Johnston
Plaintiff Robert L. Jones TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff James Robert Jorrie
Plaintiff Daniel Bruce Kennedy
Plaintiff David Keyes TERMINATED: 06/23/2005
Plaintiff Kevin W. Dacy
Plaintiff Tae H. Kim TERMINATED: 06/23/2005
Plaintiff Gary Walter Kloss TERMINATED: 06/23/2005
Plaintiff William Kwan TERMINATED: 06/23/2005
Plaintiff Annie Ray

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Billy F. Smith
Plaintiff Terri Tansey
Plaintiff Michael West TERMINATED: 06/23/2005 Plaintiff Dan J. Chavez TERMINATED: 05/18/2005 Plaintiff Karen D. Cordier
Plaintiff Eve M. Crane

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Janet Edmonds TERMINATED: 06/22/2005 Plaintiff James Frame
Plaintiff Barbara B. Grill
Plaintiff Susan Grissom TERMINATED: 06/23/2005 Plaintiff David G. Clark
Plaintiff Ann E. Hanlon

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Coletta L. Straggers
Plaintiff Patricia A. Holmes
Plaintiff Denise Paula Yeager
Plaintiff Charles A. Johnson
Plaintiff Joseph Lederhos TERMINATED: 03/29/2005 Plaintiff Vanessa Boyd Napper

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sunny Cyprian Onwuzuruike
Plaintiff Augustine Onyejiaka TERMINATED: 06/23/2005
Plaintiff Mazie M. Ratliffe−Newton
Plaintiff Christine Schmidt TERMINATED: 06/23/2005
Plaintiff Kevin Walton Seydler
Plaintiff Cynthia A. Shafer TERMINATED: 06/23/2005
Plaintiff Delores Soria TERMINATED: 03/29/2005
Plaintiff Kelly Wood TERMINATED: 06/23/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Andrew Burkhart
Plaintiff Sherri Lynn Chavora
Plaintiff John Conklin
Plaintiff Marcell Jeanne Estes TERMINATED: 06/22/2005 Plaintiff Michael J. Fairlie TERMINATED: 03/29/2005 Plaintiff Dean Goodwin
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Wendy Ann Hamilton TERMINATED: 06/23/2005 Plaintiff Carolyn Adams Hawkins
Plaintiff Sandra Hernandez TERMINATED: 06/23/2005 Plaintiff Wintino B. Jones
Plaintiff Jeffrey C.. Martin
Plaintiff Victor Merrekous Mitchell
Plaintiff LaVonn L. Montgomery TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Frederick William Parkin TERMINATED: 03/29/2005 Plaintiff Rosalyn Carol Reese TERMINATED: 03/29/2005 Plaintiff Kent Paul Smith
Plaintiff Marca E. Snook
Plaintiff Edna Ashley Williams TERMINATED: 06/23/2005 Plaintiff Merrill Wittmer
Plaintiff Trudi L. Krugh

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Terry L. Leber TERMINATED: 06/23/2005
Plaintiff Deborah H. Lee TERMINATED: 03/29/2005
Plaintiff Jacqueline Lisby
Plaintiff Carol L. Little TERMINATED: 06/23/2005
Plaintiff Linda H. Lowery TERMINATED: 06/23/2005
Plaintiff Max M. Lagauer
Plaintiff Douglas Lundstrom TERMINATED: 06/23/2005
Plaintiff Linda L. Lyman TERMINATED: 06/23/2005
Plaintiff

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Steve Macy TERMINATED: 06/23/2005 Plaintiff Carolyn Mahn
Plaintiff Tamara J. Maichel
Plaintiff Linda S. Mancino
Plaintiff Dennis J. Mays
Plaintiff Beverly McCoy
Plaintiff

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Terry R. Mollett
Plaintiff Roxie L. Moreland TERMINATED: 06/23/2005 Plaintiff Kevin Keith Nartker TERMINATED: 03/29/2005 Plaintiff Kevin Olmstead TERMINATED: 03/29/2005 Plaintiff Rob Roy Benson, Jr.
Plaintiff James P. Carroll
Plaintiff Christopher J. Dauten

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Debra Ann Ferguson
Plaintiff Fannye Johnson−Forester
Plaintiff David A. Harrington
Plaintiff Donald A. Hayes
Plaintiff Nancy B. Johnson
Plaintiff Charmaine L. Keller

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael Kochevar
Plaintiff Steven A. Matalone, II
Plaintiff Steven Edward McDonough
Plaintiff Michael S. Orenberg
Plaintiff Arjovik Ray
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Richard A. Olson TERMINATED: 06/23/2005
Plaintiff W. Wayne Parsons TERMINATED: 06/23/2005
Plaintiff Peter A. Pasquale
Plaintiff Donna J. Patrick
Plaintiff Barbara J. Radtke
Plaintiff Joan M. Rambo TERMINATED: 06/23/2005
Plaintiff Vinnie Roberts TERMINATED: 06/23/2005
Plaintiff Harold Grant Robinson TERMINATED: 06/23/2005

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael A. Rogers
Plaintiff Irene Ruler TERMINATED: 03/29/2005 Plaintiff Joan Elizabeth Rupp TERMINATED: 06/23/2005 Plaintiff Joseph P. Rutten
Plaintiff Charles Edward Salters TERMINATED: 06/23/2005 Plaintiff Larry A. Sharpe
Plaintiff Samuel Edward Shelton

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Donna Sweet TERMINATED: 06/23/2005 Plaintiff Stanley R. Thompson
Plaintiff Debra Louise Tolbert TERMINATED: 03/29/2005 Plaintiff Deborah L. Viebrock
Plaintiff James B. Wagner TERMINATED: 03/29/2005 Plaintiff Alvenia W. Warren
Plaintiff Jane P. Watts

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Katheryn Louise Webster
Plaintiff Hyla B. Weeks
Plaintiff Frank B. Wigfall, Sr. TERMINATED: 06/23/2005 Plaintiff Gerald Williams
Plaintiff Elaine Wilson
Plaintiff Joy C. Adorante

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Deborah F. Alt TERMINATED: 06/22/2005
Plaintiff Quirino C. Amore, Jr. TERMINATED: 06/22/2005
Plaintiff David E. Andrews TERMINATED: 06/22/2005
Plaintiff Virginia Z. Ansell
Plaintiff Tery M. Ayers
Plaintiff Donna M. Baer TERMINATED: 06/22/2005
Plaintiff Marjorie A. Bailey

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Patricia C. Ballard
Plaintiff Judy Barnett TERMINATED: 03/29/2005
Plaintiff Nolan B. Beatty
Plaintiff Rita A. Roberts
Plaintiff R. Allen Schindler TERMINATED: 05/18/2005
Plaintiff Debra H. Seidel TERMINATED: 03/29/2005
Plaintiff Davis Shikles TERMINATED: 02/03/2006
Plaintiff Noel Strong

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Carol A. Sturm TERMINATED: 05/18/2005 Plaintiff John Scott Turik
Plaintiff Maria C. Walker−Magdaleno
Plaintiff Lowell Hal Wallace
Plaintiff Edward G. Wemlinger
Plaintiff Anthony Orin Young

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Elizabeth Boggs TERMINATED: 06/22/2005 Plaintiff Marsha A. Burch TERMINATED: 06/22/2005 Plaintiff Christie B. Carrico
Plaintiff Renee J. Daniels
Plaintiff Al Krygeris
Plaintiff David Paul Markham

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Debra Markham
Plaintiff Sue Anne McDonald TERMINATED: 06/23/2005
Plaintiff Brenda Blackshear TERMINATED: 06/22/2005
Plaintiff Louis Blum
Plaintiff Timothy N. Bowser TERMINATED: 06/22/2005
Plaintiff Gerry M. Osterberg
Plaintiff Diana Lyn Bland TERMINATED: 06/22/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Maurice Lee Brown
Plaintiff Stephen R. Brown
Plaintiff George O. Bryce
Plaintiff Jeanne Butcher
Plaintiff Alcee Butler, Jr. TERMINATED: 06/22/2005 Plaintiff Richard W. Cahoon TERMINATED: 06/22/2005 Plaintiff Dennis William Campbell TERMINATED: 06/22/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Karen L. Carpenter
Plaintiff Mildred Carter−Grueninger TERMINATED: 06/22/2005 Plaintiff H. Marie Church
Plaintiff Ernestine Cole
Plaintiff Rhonda Comer
Plaintiff Thomas D. Conrow

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jay D. Cox
Plaintiff Phillip E. Norman TERMINATED: 06/23/2005 Plaintiff Everline Primm
Plaintiff Charles Douglas Smith
Plaintiff Vicki S. Van Engen TERMINATED: 06/23/2005 Plaintiff Thomas P. Armstrong TERMINATED: 06/22/2005 Plaintiff Abigail Louise Davis

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Robert Kent Hodgson
Plaintiff Carolyn De Ann Majd
Plaintiff Beulah Elaine Shields
Plaintiff E Maria Strahan Wheaton
Plaintiff Michael S. Ambre TERMINATED: 04/01/2005 Plaintiff Alan Cepeda TERMINATED: 06/22/2005 Plaintiff William W. Crockett

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Barbara Dean TERMINATED: 06/22/2005 Plaintiff Cecil L. Dickson
Plaintiff Meredith Francis
Plaintiff LaDonna Kay Gazaway TERMINATED: 06/23/2005 Plaintiff Jack E. McConnell TERMINATED: 06/23/2005 Plaintiff David L. Norton
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

William C. Phillips TERMINATED: 06/23/2005
Plaintiff Michael C. Royal TERMINATED: 06/23/2005
Plaintiff Jacqueline J. Webster TERMINATED: 06/23/2005
Plaintiff Vera Theresa Sledge
Plaintiff Dominic V. Orlando
Plaintiff Ronald Cook TERMINATED: 06/22/2005
Plaintiff Matthew J. Borkowski

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Shirley Williams
Plaintiff Michael P. Buxkemper TERMINATED: 06/22/2005

represented by Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Claudio E. Molteni Morrow Willnauer Church, LLC − KC 8330 Ward Parkway, Suite 300 Kansas City, MO 64114 816−382−1382 Fax: 816−382−1383 Email: cmolteni@mwcattorneys.com TERMINATED: 03/06/2008 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Martin Smith (See above for address) TERMINATED: 06/09/2005 LEAD ATTORNEY
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Matthew C. Billips Miller, Billips & Ates, PC 730 Peachtree St. − Ste. 750 Atlanta, GA 30328 404−969−4101 Fax: 404−969−4141 Email: mbillips@mbalawfirm.com TERMINATED: 07/23/2008 LEAD ATTORNEY PRO HAC VICE
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Debra E. Cohen
Plaintiff Frances Cooper TERMINATED: 06/22/2005 Plaintiff Cedric B. DeBolt, Jr.
Plaintiff Melanie Denis
Plaintiff Eric Scott Erhard TERMINATED: 03/29/2005 Plaintiff Jackie Flannery
Plaintiff Patricia A. Garber TERMINATED: 06/23/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Donald D. Hullinger
Plaintiff Denise M. Kotel
Plaintiff Diane R. Krizek TERMINATED: 03/29/2005 Plaintiff John David Mais TERMINATED: 06/23/2005 Plaintiff Michael A. Mierchuk
Plaintiff Ricky Morrison
Plaintiff Anita Y. Moxley

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Theresa Muscat−Reynaud
Plaintiff Sandra Price
Plaintiff Abdul N. Rahim
Plaintiff Gary Scheib
Plaintiff Hhilda Ashanti Turnage

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard White
Plaintiff Lorraine H. Woodard
Plaintiff Mary Jane Crotzer TERMINATED: 05/18/2005
Plaintiff Sharon K. Valasek
Plaintiff Joyce M. Hutchings TERMINATED: 05/18/2005
Plaintiff Michael J. Bumpers TERMINATED: 06/22/2005
Plaintiff Rosa Lee Darby TERMINATED: 06/22/2005
Plaintiff Kevin T. Farley

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Sheila M. Farris TERMINATED: 03/29/2005
Plaintiff Nathan E. Feimster TERMINATED: 06/22/2005
Plaintiff Regina A. Ferguson TERMINATED: 06/23/2005
Plaintiff Duane F. Filsinger TERMINATED: 03/29/2005
Plaintiff Arvie Fisher TERMINATED: 06/23/2005
Plaintiff Gregory P. Flotard TERMINATED: 06/23/2005
Plaintiff Barbara J. Garcia
Plaintiff Thomas Garza TERMINATED: 06/23/2005

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Bette Getz
Plaintiff Hilda Sutton Gibson
Plaintiff LaVerne E. Gildner, Jr. TERMINATED: 06/23/2005 Plaintiff Thomas M. Goff
Plaintiff Flora L. Grayson
Plaintiff Pablo B. Gausch

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Wayne Wesley Hartman
Plaintiff David Hopkins
Plaintiff David B. Jackson
Plaintiff Julie Jaillet
Plaintiff Keith Jamour TERMINATED: 11/29/2005 Plaintiff Leava Jones

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Kimberlea P. Joyner−Wortman TERMINATED: 06/23/2005
Plaintiff Michael L. Kaufhold, Sr.
Plaintiff Paul R. Lamoree TERMINATED: 06/23/2005
Plaintiff Beverly P. Lane TERMINATED: 06/23/2005
Plaintiff Paul A. Lero TERMINATED: 06/23/2005
Plaintiff Brian Long
Plaintiff Michael H. Lovett

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Teresa L. Major TERMINATED: 06/23/2005
Plaintiff Robert L. Marion TERMINATED: 06/23/2005
Plaintiff Anne C. McAuley TERMINATED: 03/29/2005
Plaintiff Arnie Byron McKinnis, III TERMINATED: 06/23/2005
Plaintiff Carl N. Morgan
Plaintiff Kathy S. Morgan
Plaintiff Susan Lynn Neill
Plaintiff Ronald Wayne Nuhring TERMINATED: 03/29/2005

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Darrell L. Parks
Plaintiff Rebecca Patton TERMINATED: 06/23/2005
Plaintiff John R. Paul, Jr. TERMINATED: 06/23/2005
Plaintiff Kenneth R. Peterson TERMINATED: 06/23/2005
Plaintiff Khiem Phan
Plaintiff Jani Pryne
Plaintiff Vincent L. Rohloff, II TERMINATED: 06/23/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Donna M. Salinas TERMINATED: 06/23/2005 Plaintiff Gary A. Schauperl
Plaintiff Phyllis Jean Schierioth
Plaintiff Christine L. Sheppard TERMINATED: 06/23/2005 Plaintiff Sandra Cox Snead TERMINATED: 06/23/2005 Plaintiff Alexander A. Smircich
Plaintiff Billy J. Smith

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Stephan F. Spooner
Plaintiff Margaret E. Spriggs TERMINATED: 06/23/2005 Plaintiff Michael Ray Steele TERMINATED: 06/23/2005 Plaintiff Sandra Sturgeon
Plaintiff Maria Surrell
Plaintiff Brenda Jean Tanner
Plaintiff Bruce E. Taylor

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Karen Shepherd Tenison
Plaintiff Ronald Eugene Thompson
Plaintiff Eric S. Thomsen
Plaintiff Colleen M. Thornbrugh
Plaintiff Graceann E. Tompkins

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Diane B. Townes
Plaintiff Steve T. Tran TERMINATED: 06/23/2005 Plaintiff Carol Lee Truitt
Plaintiff Diane Turecheck
Plaintiff Camilla S. Walton
Plaintiff Shelia Denise Webb

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Elizabeth Terri Weber
Plaintiff Peggy J. Wilson
Plaintiff Susan G. Wunder TERMINATED: 06/23/2005 Plaintiff John A. Young TERMINATED: 06/23/2005 Plaintiff Aleksandra Zinoryeva
Plaintiff A. Doreen Snyder TERMINATED: 06/23/2005 Plaintiff David B. Snypes

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Edith L. Splain
Plaintiff Paul D. Sprout, Jr.
Plaintiff Sharon Uyvonne Steele
Plaintiff David T. Stevens TERMINATED: 06/23/2005 Plaintiff Edwin F. Stewart TERMINATED: 03/29/2005 Plaintiff Alonzo Street TERMINATED: 06/23/2005 Plaintiff Diane K. Strefling

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Phyllis A. Taylor
Plaintiff Sheila Thomas−Peterson
Plaintiff Sammy Thompson
Plaintiff Patrick Trainor
Plaintiff Kenneth A. Turner TERMINATED: 06/23/2005 Plaintiff Mary Wagner

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Diane A. Weege
Plaintiff Deborah Denise Whalen TERMINATED: 06/23/2005
Plaintiff Stephen Wibbenmeyer TERMINATED: 06/23/2005
Plaintiff Joseph Wilcox TERMINATED: 06/23/2005
Plaintiff Arthur L. Williams
Plaintiff DiAnna Lynn Williams
Plaintiff Kuo−Kong Woo TERMINATED: 06/23/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Joy M. Acree
Plaintiff Debra L. Arck
Plaintiff Scott Barger TERMINATED: 03/29/2005 Plaintiff Dale M. Deal
Plaintiff Bernadine Ann Goens
Plaintiff Tiha Harris TERMINATED: 03/29/2005 Plaintiff Lucy M. Harrison TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Debra A. Kehn TERMINATED: 05/18/2005
Plaintiff JoAnn Kelly TERMINATED: 06/23/2005
Plaintiff Steven J. Koester
Plaintiff Diane Licavoli
Plaintiff Bruce Allen Lipson TERMINATED: 03/29/2005
Plaintiff Michael Morris Poindexter TERMINATED: 06/23/2005
Plaintiff Carmen Ramirez TERMINATED: 03/29/2005
Plaintiff Elton L. Reynolds TERMINATED: 03/29/2005
Plaintiff

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David A. Richards
Plaintiff Kelly Ann Schneider
Plaintiff Donna K. Smith
Plaintiff Ronald L. Steinour
Plaintiff Glenda B. Sumner TERMINATED: 05/18/2005 Plaintiff Geraldine Richard Turner
Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Clifford Joel Waugh
Plaintiff Brenda O. Weatherford
Plaintiff Donald Wingard
Plaintiff Cheryl J. Alexander
Plaintiff Dennis Dean Ayers TERMINATED: 03/29/2005 Plaintiff DeLece Renae Barker TERMINATED: 06/22/2005 Plaintiff Mark R. Brennaman

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Beverly S. Brown TERMINATED: 03/29/2005 Plaintiff Gerald M. Caswell
Plaintiff Reynold J. Chen
Plaintiff William Chen TERMINATED: 06/22/2005 Plaintiff Glinda Currin−Adams
Plaintiff Troy G. Green

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Christopher F. Guarino TERMINATED: 06/23/2005 Plaintiff Serena James TERMINATED: 06/23/2005 Plaintiff Jan McDaniel
Plaintiff Debbie L. McElvain−Thompson
Plaintiff Russell D. Mehl
Plaintiff Rodney A. Miller
Plaintiff James W. Murch

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robin S. Nelson
Plaintiff Jeffrey L. Nichols
Plaintiff Steven P. Reutter
Plaintiff Mary R. Scott
Plaintiff Kevin A. Shannon TERMINATED: 04/03/2007
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Ginger W. Sullivan
Plaintiff Jacquline L. Vickery
Plaintiff Joseph B. Ziegler
Plaintiff Charles Morris Adams TERMINATED: 06/22/2005 Plaintiff James Charlie Benedict TERMINATED: 06/22/2005 Plaintiff Bernard L. Bland, III
Plaintiff George Laurence Carter TERMINATED: 06/22/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Keith W. Cecil, III TERMINATED: 03/29/2005
Plaintiff Ronald L. Davis TERMINATED: 06/22/2005
Plaintiff Cherry L. Jackson TERMINATED: 05/18/2005
Plaintiff Lillian June Johnson
Plaintiff Donald L. Kentopp
Plaintiff Cheryl V. List TERMINATED: 06/23/2005
Plaintiff Cathy J. Mark TERMINATED: 06/23/2005
Plaintiff Lydon Capra McCallon

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Jefferey Trent McGill TERMINATED: 03/29/2005
Plaintiff Michael L. Mennuti TERMINATED: 06/23/2005
Plaintiff Gerry B. Miller TERMINATED: 06/23/2005
Plaintiff ChloeAnn Petty TERMINATED: 03/29/2005
Plaintiff Robin Posey−Blue
Plaintiff Sylvan R. Rossi TERMINATED: 03/29/2005
Plaintiff Richard A. Sage TERMINATED: 06/23/2005
Plaintiff Sherree D. Sammons

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gary Dean Shappell
Plaintiff Michael Spoon TERMINATED: 06/23/2005 Plaintiff Rex A. Steyskal
Plaintiff Carolyn J. Winston
Plaintiff Phil Yan
Plaintiff Tommie Lee Arnick, Jr. TERMINATED: 06/22/2005 Plaintiff Dale Michael Aston

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Steven R. Castro
Plaintiff Robert B. Cullinan TERMINATED: 03/29/2005 Plaintiff Karen Duraney
Plaintiff Pamela Fellows
Plaintiff Willie E. Ford, Jr.
Plaintiff David W. Garbush TERMINATED: 06/23/2005

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Stuart R. Goble
Plaintiff Jeanette M. Gonzales
Plaintiff Mary C. Heritage TERMINATED: 06/23/2005 Plaintiff Thomas Mennona
Plaintiff Michael M. Murchison
Plaintiff Catharine M. Murphy TERMINATED: 06/23/2005 Plaintiff Laima Narubin TERMINATED: 06/23/2005

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Leslie D. Perry TERMINATED: 06/23/2005
Plaintiff Marlene Waltmon Ponce
Plaintiff Shirley A. Ragins TERMINATED: 03/29/2005
Plaintiff David R. Satterfield
Plaintiff Gloria Ann Armour Sawyer TERMINATED: 05/18/2005
Plaintiff Herbert E. Skidmore TERMINATED: 03/29/2005
Plaintiff Linda J. Tufano

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Albert W. Vogel, Jr.
Plaintiff Helena E. Young
Plaintiff Joanne Elaine Zubal
Plaintiff Catherine Arline Brauner
Plaintiff David Mark Brown
Plaintiff Robyn Butler

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Charles Caton
Plaintiff Mary Ann Crisp
Plaintiff Linda DeMatteis
Plaintiff Donna Jane Diehm
Plaintiff Kent Gooden
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Randall E. Graham TERMINATED: 03/29/2005
Plaintiff Susan E. Guthrie
Plaintiff Robin M. Hobbs TERMINATED: 06/23/2005
Plaintiff Phyllis R. Janes TERMINATED: 06/23/2005
Plaintiff Denise Karen Dunn King
Plaintiff Lewis A. Levy TERMINATED: 06/23/2005
Plaintiff Larrie Loehr
Plaintiff Douglas Edward Marlowe TERMINATED: 06/23/2005

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Aderele Teddy Mason
Plaintiff Michael E. Mulvaney
Plaintiff Hoyt Eldean Neal, Jr.
Plaintiff Ehi Parker TERMINATED: 05/18/2005 Plaintiff Earl Simmons
Plaintiff Madelyn Velasquez−Almansa

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Debra Walker
Plaintiff Patrick H. Walsh
Plaintiff Jacquet Wishropp TERMINATED: 06/23/2005
Plaintiff Clark Abrahamson TERMINATED: 06/22/2005
Plaintiff Larry E. Bell TERMINATED: 03/29/2005
Plaintiff Daniel James Blevins TERMINATED: 06/22/2005
Plaintiff Joyce D. Brodberg
Plaintiff Sandra S. Conrad

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Catherine M. Gilbert
Plaintiff Judith C. Hadar
Plaintiff Linda C. Hardy
Plaintiff Jillian James
Plaintiff Edwin C. Kisiel, Jr. TERMINATED: 06/23/2005 Plaintiff

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sue M. Mange
Plaintiff Deborah A. Mitchell
Plaintiff Charlotte Wright Parker
Plaintiff Lisa Y. Perez
Plaintiff Russell W. Rackley
Plaintiff Bradley J. Roth

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Louis Ruiz TERMINATED: 03/29/2005
Plaintiff Althea W. Smith TERMINATED: 06/23/2005
Plaintiff Angileen Noreen Stewart
Plaintiff P.J. Turner TERMINATED: 06/23/2005
Plaintiff Judy Vodas TERMINATED: 06/23/2005
Plaintiff Brian Warrick
Plaintiff Gary L. Willis

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Theresa M. Wilson
Plaintiff Jeffrey David Zak
Plaintiff Gerard B. Arena
Plaintiff Janette H. Darmer Blackmon
Plaintiff Mary Alice Brinson
Plaintiff M. Dale Carter

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gary L. Daehnke TERMINATED: 06/22/2005
Plaintiff Joel R. Darden
Plaintiff Nathaniel J. Dobin TERMINATED: 06/22/2005
Plaintiff Brenda R. Eversole TERMINATED: 04/03/2007
Plaintiff John Finley
Plaintiff Linda Gail Goss TERMINATED: 06/23/2005
Plaintiff Richard James Grady TERMINATED: 03/29/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gwendolen M. Guthrie−Rudacille
Plaintiff Randal P. Hammond
Plaintiff Robbie Jo Hernandez
Plaintiff Marvita L. Johnson
Plaintiff Michael D. Lawson TERMINATED: 06/23/2005 Plaintiff Thomas C. Lindzy

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Thomas J. Prescott TERMINATED: 05/18/2005
Plaintiff L. Renee Routzong TERMINATED: 06/23/2005
Plaintiff Harold F. Simon
Plaintiff Martin A. Smith TERMINATED: 06/23/2005
Plaintiff Juliette A. Stevens
Plaintiff Janice F. Thompson TERMINATED: 05/18/2005
Plaintiff Brenda L. Weber
Plaintiff Timothy A. Wonder

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Joe Ann Adams
Plaintiff Betty R. Allen TERMINATED: 03/29/2005 Plaintiff Elvy Paulette Andis
Plaintiff William J. Brown TERMINATED: 06/22/2005 Plaintiff Richard James Courtice
Plaintiff Michael D. Dadisman TERMINATED: 03/29/2005

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Rosemary Delpino
Plaintiff Gary W. Fry TERMINATED: 06/23/2005 Plaintiff Robert J. Haley
Plaintiff Alice Whitaker Harris
Plaintiff Joyce M. Hecht TERMINATED: 06/23/2005 Plaintiff Sharon Gentry Jones TERMINATED: 06/23/2005 Plaintiff Timothy Allen Lee

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Robert A. Moritz
Plaintiff Donald M. Osborn TERMINATED: 03/29/2005
Plaintiff Nancy L. Patton TERMINATED: 06/23/2005
Plaintiff Rick Rawlings TERMINATED: 03/29/2005
Plaintiff Tina Richter TERMINATED: 03/29/2005
Plaintiff Karen M. Rider TERMINATED: 03/29/2005
Plaintiff Sally Thompson Rosine
Plaintiff Peggy Schniegenberg TERMINATED: 06/23/2005
Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Susan Sites TERMINATED: 06/23/2005
Plaintiff Darrel Smith TERMINATED: 06/23/2005
Plaintiff Christeen Vergith TERMINATED: 06/23/2005
Plaintiff Alfonso Zamorano TERMINATED: 06/23/2005
Plaintiff David Emmett Brown
Plaintiff John L. Butler
Plaintiff Sandra J. Crow
Plaintiff Tracy j. Delnegro

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mark Gaff
Plaintiff Ronald L. Hetrick
Plaintiff Helen Hill TERMINATED: 06/23/2005 Plaintiff Jerome F. Kacheroski
Plaintiff Suzan Malady TERMINATED: 06/23/2005 Plaintiff Annette N. McCabe TERMINATED: 06/23/2005 Plaintiff Cynthia S. McCandless

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Pamela E. Mullen
Plaintiff Patricia Murzyn
Plaintiff LaWanda F. Roche
Plaintiff Anne M. Stern TERMINATED: 06/23/2005 Plaintiff Reggie Thompson
Plaintiff Helen VanNess

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Angela Walker
Plaintiff Michael B. Wynter
Plaintiff Susan Yaw
Plaintiff Nancy Sue Cabray TERMINATED: 06/22/2005 Plaintiff Michael A. Canty
Plaintiff Candy M. Colwell TERMINATED: 03/29/2005

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Barbara Motes Coon TERMINATED: 03/29/2005 Plaintiff Eileen T. Darrah
Plaintiff Leslie Ann Douglas
Plaintiff Ted A. Harris
Plaintiff Donna K. Hubert
Plaintiff Denise M. Johnson

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Shelly R. Johnson TERMINATED: 03/29/2005 Plaintiff Wanda King
Plaintiff Mary Louise Mackey
Plaintiff Shirley Randle Parks
Plaintiff Kandy D. Planco TERMINATED: 06/23/2005 Plaintiff Kimberly Prock TERMINATED: 05/18/2005 Plaintiff Rosemary J. Stombaugh

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Louise Vandercar TERMINATED: 06/23/2005 Plaintiff Robert N. Wilson TERMINATED: 06/23/2005 Plaintiff Eddie C. Wu
Plaintiff Toby Young
Plaintiff Judith S. Ballesteros TERMINATED: 06/22/2005 Plaintiff Raymond Lydale Campbell
Plaintiff Noemi Caraballo

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Allen H. Dandeneau
Plaintiff Mark Dowell
Plaintiff Gloria Mae Hughes TERMINATED: 05/18/2005 Plaintiff Thomas J. Lipari
Plaintiff Douglas S. MacLean TERMINATED: 03/29/2005 Plaintiff David L. McLaughlin
Plaintiff

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Joan A. Molek TERMINATED: 03/29/2005
Plaintiff Christopher R. Nichols TERMINATED: 03/29/2005
Plaintiff William J. Overley TERMINATED: 06/23/2005
Plaintiff Timothy Parker−Price TERMINATED: 06/23/2005
Plaintiff William Raaf
Plaintiff Mark J. Saxton TERMINATED: 06/23/2005
Plaintiff Cheryl Ann Hall Stillwell
Plaintiff Jacqueline Taylor TERMINATED: 06/23/2005
Plaintiff Sherri L. Tubbs TERMINATED: 06/23/2005

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Johnnie Mae Walker TERMINATED: 05/18/2005 Plaintiff Jane Ann Zolotor
Plaintiff Patricia A. Barrett
Plaintiff Dennis Christy
Plaintiff Willie F. Cosby
Plaintiff LaNeishae V. Edison

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Marie Edwards
Plaintiff Jacklynn D. Goforth
Plaintiff Carldene Green
Plaintiff Ellen S. Hare TERMINATED: 03/29/2005 Plaintiff John Anthony Kaye
Plaintiff David G. Kern TERMINATED: 06/23/2005 Plaintiff Steve Lacey

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Jeanette Kathryn Saunders
Plaintiff Barbara Schoenberger
Plaintiff Manuel A. Torrez
Plaintiff Ethel Turner TERMINATED: 06/23/2005 Plaintiff Carla Raye Waddy TERMINATED: 06/23/2005 Plaintiff Nancy L. Wallace

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff J. C. Weathersby
Plaintiff Brenda Williams TERMINATED: 06/23/2005 Plaintiff Candis Yarsulik
Plaintiff Catherine Ann Anzick
Plaintiff Charles A. Bell
Plaintiff Evelyn Faye Berry

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Larry A. Capps TERMINATED: 03/29/2005 Plaintiff Sandra Kay Charles
Plaintiff Barbara Anne Davis
Plaintiff Julio J. Di Palma TERMINATED: 03/29/2005 Plaintiff Suzanne Fee
Plaintiff Betty K. Fletcher

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Curtis Ann Herbert TERMINATED: 06/23/2005
Plaintiff Theodore P. Hoagland TERMINATED: 05/18/2005
Plaintiff Ronald L. Hons TERMINATED: 06/23/2005
Plaintiff Jackie R. Johnson TERMINATED: 06/23/2005
Plaintiff Karen Nelson
Plaintiff Timothy C. Newcomb
Plaintiff Betty J. Snowden
Plaintiff Thomas C. Stanfield

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Richard L. Thomas
Plaintiff Mark Allen Triplett
Plaintiff Steven A. Young
Plaintiff Joyce Ann Bixler TERMINATED: 11/29/2005 Plaintiff Dayna Bozile TERMINATED: 04/03/2007
Plaintiff Randall D. Crabtree TERMINATED: 06/22/2005

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Heidi H. Dupre
Plaintiff Debbie Evans−Guillen
Plaintiff Bruce J. Freitas TERMINATED: 03/29/2005 Plaintiff John L. Hale TERMINATED: 03/29/2005 Plaintiff Charles Richard Keene TERMINATED: 06/23/2005 Plaintiff Berrie B. Lawson
Plaintiff Robert Delano Lerch

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Richard E. Pendleton TERMINATED: 06/23/2005 Plaintiff Mike Stephen Perkins
Plaintiff Mary Jeanne Ratway TERMINATED: 06/23/2005 Plaintiff Mary Anne Read
Plaintiff Carl E. Robinson
Plaintiff Janet Seamon
Plaintiff

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Carol Waggener
Plaintiff Jeffrey Wagner TERMINATED: 06/23/2005 Plaintiff Janet Lynn Weller
Plaintiff Leslie Westland
Plaintiff Michael Battin TERMINATED: 03/29/2005 Plaintiff Janice Bishop
Plaintiff Joseph L. Browne TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Terri G. Christian
Plaintiff Kenneth Corniello TERMINATED: 03/29/2005 Plaintiff James Lee Fisk
Plaintiff James E. Hinds
Plaintiff Maynard M. Kealiher
Plaintiff Willie Maudeen Miles TERMINATED: 03/29/2005 Plaintiff Brenda B. Miller

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff John R. Mueller
Plaintiff Brenda Lynette Newman
Plaintiff Eugene Rainville
Plaintiff Betty F. Richards
Plaintiff Richard L. Roberson
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Janet M. Roberts
Plaintiff Michael F. Santillo
Plaintiff Peggy Crenshaw Talbott
Plaintiff Leonard Weinberg
Plaintiff Suzanne Woods TERMINATED: 03/29/2005 Plaintiff Ronald J. Aitken, Sr.
Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cynthia L. Beatty
Plaintiff Steven M. Bohlander TERMINATED: 06/22/2005 Plaintiff Diana Duncan TERMINATED: 03/29/2005 Plaintiff Ernest Boyd Erlbeck, Jr.
Plaintiff DiAnna Thomas Etheridge
Plaintiff Byron J. Folse
Plaintiff Cathe Frantz

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sue Anne Fulton
Plaintiff Monique Guadalupe
Plaintiff John K. Hickman
Plaintiff Ann K. Hicks TERMINATED: 06/23/2005 Plaintiff Randall L. Lasiter
Plaintiff J. Kevan Norris

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mark Schaefer
Plaintiff David Senator TERMINATED: 03/29/2005 Plaintiff Alexandra Szykowny
Plaintiff Ed Troop TERMINATED: 03/29/2005 Plaintiff Jerry Lee Winchell
Plaintiff Mitchell J. Adams

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard C. Anglada
Plaintiff Walter D. Bennett TERMINATED: 04/01/2005 Plaintiff Paulette D. Bowen
Plaintiff Michael G. Butts
Plaintiff Pamela S. Byers
Plaintiff Marybeth Chris TERMINATED: 03/29/2005 Plaintiff Richard L. Eaton

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Antonio Flaquer
Plaintiff Paul A. Juarez TERMINATED: 05/18/2005 Plaintiff Evelyn Marie Lee TERMINATED: 03/29/2005 Plaintiff Patty Jo Lynch
Plaintiff Edward P. Megrant TERMINATED: 06/23/2005 Plaintiff Patricia S. O'Donnell
Plaintiff Brenda Oliver

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Denise Rodriguez TERMINATED: 03/29/2005 Plaintiff Debra L. Sharts TERMINATED: 06/23/2005 Plaintiff Carole Ann Spiller
Plaintiff Jay C. Swisher, Jr.
Plaintiff Audry Marie Wise
Plaintiff Irma Ames

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff JoAnne Bloxham TERMINATED: 06/22/2005 Plaintiff Robert Diaz TERMINATED: 06/22/2005 Plaintiff Candis Kay Dolan
Plaintiff Pamela W. Forehand
Plaintiff Susan Marie Forget
Plaintiff Dennis L. Gill
Plaintiff Brenda P. Graves TERMINATED: 06/23/2005

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Sally Ann Grossi TERMINATED: 06/23/2005 Plaintiff Dianne Vines Hamdan
Plaintiff Brenda D. Head TERMINATED: 05/18/2005 Plaintiff Judith I. Howard
Plaintiff Gerald Robert Mersing
Plaintiff Paula Nourse
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Maria E. Oliva TERMINATED: 06/23/2005
Plaintiff Steve W. Petty TERMINATED: 06/23/2005
Plaintiff Victor Preddie
Plaintiff Sally D. Preston
Plaintiff Vernita Preston TERMINATED: 06/23/2005
Plaintiff Charles J. Sandberg TERMINATED: 06/23/2005
Plaintiff Kathleen E. Alloune TERMINATED: 06/22/2005
Plaintiff Carol Alvarez

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Lynwood C. Bowen, Jr.
Plaintiff Margaret R. Capone
Plaintiff Martha R. Custer TERMINATED: 06/22/2005 Plaintiff Edward F. Hassman
Plaintiff Judith M. Hickman
Plaintiff Jeffery E. Huffman

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Alimamy G. Kargbo TERMINATED: 06/23/2005 Plaintiff Mark J. Linde TERMINATED: 03/29/2005 Plaintiff Grace Diane Marott
Plaintiff Dianne Martin
Plaintiff Susan Q. Mason
Plaintiff Laurie M. Ortiz
Plaintiff Kathy M. Pine

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Julia J. Reitzes
Plaintiff Norman M. Snow TERMINATED: 06/23/2005
Plaintiff Barbara A. Snowden TERMINATED: 03/29/2005
Plaintiff Diana M. Strickland TERMINATED: 06/23/2005
Plaintiff Mickey Thomas
Plaintiff Juanita F. Ambristee
Plaintiff Martin B. Bishop TERMINATED: 06/22/2005

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Hal Boggess TERMINATED: 03/29/2005 Plaintiff Dennis P. Callahan
Plaintiff Larry W. Davis
Plaintiff Faye Ellen Dornan TERMINATED: 03/29/2005 Plaintiff Charles E. Ebner
Plaintiff Sherri Fassee
Plaintiff Carl L. Grady

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Kimberly Hartzell TERMINATED: 03/29/2005 Plaintiff Linda Henderson
Plaintiff Jack Hyndman
Plaintiff Doreen M. Ledig
Plaintiff Donna S. Mackey
Plaintiff

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Richard G. McPheeters
Plaintiff Jacqueline M. Minne
Plaintiff Nettie Rosner Schait
Plaintiff Marilynn Y. Smallwood TERMINATED: 06/23/2005 Plaintiff Tammy L. Turner
Plaintiff Debbie S. Vital TERMINATED: 06/23/2005 Plaintiff Karen J. Andre

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Yvonne Adele Bennett
Plaintiff Barbara Brown
Plaintiff Herbert Campbell TERMINATED: 06/22/2005
Plaintiff Susan L. Cunningham TERMINATED: 06/22/2005
Plaintiff Betty H. Dorrity TERMINATED: 06/22/2005
Plaintiff Christine Evelyn Monticue

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Arya Vir Pathria TERMINATED: 06/23/2005 Plaintiff Carlton Lewis Payne
Plaintiff William Robert Payne
Plaintiff Cheryl Rollwagen
Plaintiff Dong Jean Schin TERMINATED: 06/23/2005 Plaintiff Katherine E. Sellers TERMINATED: 03/29/2005 Plaintiff Ann Miles Shelly

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Natalie Slade
Plaintiff Cathy Thurston−Seignious
Plaintiff E. Jean Wright
Plaintiff Rosalyn F. Wright
Plaintiff Debra G. Zissis
Plaintiff Susan Allen

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard N. Barraco
Plaintiff Felix Berenguer TERMINATED: 03/29/2005 Plaintiff Eugene Michael Gaughan TERMINATED: 06/23/2005 Plaintiff Richard L. Green TERMINATED: 06/23/2005 Plaintiff Mary O. Hodge
Plaintiff Gwen C. Johnson
Plaintiff Daniel J. Kohlrieser

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff David S. MacNamara
Plaintiff Richard G. Maronay TERMINATED: 06/23/2005 Plaintiff Thomas B. McCulloch, Jr.
Plaintiff David Lee Molinaro TERMINATED: 05/18/2005 Plaintiff Delores Ellen Neis
Plaintiff Joaquin Porras TERMINATED: 06/23/2005 Plaintiff David A. Pressell

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Luis Rodriguez
Plaintiff Susan Marie Schwartz
Plaintiff Brenda Tatum
Plaintiff Sharon Faye Vogelsong TERMINATED: 06/23/2005 Plaintiff Angela Byrd Wilson
Plaintiff Harold Bradshaw TERMINATED: 06/22/2005

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Brenda Sue Bryan
Plaintiff Arnie L. Dales TERMINATED: 06/22/2005 Plaintiff Adrianne Elizabeth Ford TERMINATED: 06/23/2005 Plaintiff Clinton L. Heintzelman
Plaintiff Chris Lewis
Plaintiff Beth A. Mann
Plaintiff Alan L. Matthews, Jr. TERMINATED: 03/29/2005

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address)

Plaintiff Donna S. McCoy TERMINATED: 03/29/2005 Plaintiff Michael R. Mears TERMINATED: 06/23/2005 Plaintiff Gale Meyer
Plaintiff Theresa A. Moore
Plaintiff Jill Ann Newman
Plaintiff Wayne Obidowicz
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Timothy John O'Brien TERMINATED: 06/23/2005 Plaintiff Molly R. Parker
Plaintiff Richard Dean Piercy TERMINATED: 03/29/2005 Plaintiff Gerald E. Purinton
Plaintiff Yuk−Wa Suen
Plaintiff Loretta E. Tyre
Plaintiff Susan Odette Acevedo TERMINATED: 06/22/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sonja M. Allen
Plaintiff Kathy L. Bell
Plaintiff Brent Branley
Plaintiff Gordon F. Clark TERMINATED: 03/29/2005 Plaintiff Jerald Alan Bethke
Plaintiff Shirley W. Francis

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Johnny W. Giles
Plaintiff Fred R. Boughton
Plaintiff Roger H. Hempeck
Plaintiff Henry J. Holst, Jr.
Plaintiff Clifford E. McGeehon
Plaintiff Elvis Lloyd Morehead, Jr.

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael C. Notarianni TERMINATED: 03/29/2005 Plaintiff Debora G. Padgett
Plaintiff Lee Poindexter
Plaintiff Juliann Radford TERMINATED: 03/29/2005 Plaintiff Francis Xavier Saucedo
Plaintiff Michael Schlobohm

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ronald J. Schmidt
Plaintiff Richard E. Scott, Jr.
Plaintiff Robert Todd Cohen
Plaintiff Barbara B. Davis
Plaintiff Linda W. Shields TERMINATED: 03/29/2005 Plaintiff Merrill G. Detweiler

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Gale Lee Dorman
Plaintiff Judy M. Stephens
Plaintiff Michael L.J. Downer
Plaintiff Javier Fernandez
Plaintiff Kenneth Lee Gregory TERMINATED: 06/23/2005 Plaintiff Richard S. Hill

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bruce H. Hogan
Plaintiff Nancy Horton
Plaintiff Purushottam V. Kamat
Plaintiff Raymond J. Lewis TERMINATED: 03/29/2005 Plaintiff Markus E. Merrill
Plaintiff Leon H. Simpkins TERMINATED: 03/29/2005 Plaintiff Lynette D. Tolar TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Judy J. Watson
Plaintiff Yoshikazu Yamada TERMINATED: 06/23/2005
Plaintiff Anne L. Aalderink TERMINATED: 03/29/2005
Plaintiff Ronnie Graham Cashwell
Plaintiff Diane D. Franklin TERMINATED: 06/23/2005
Plaintiff Carolyn Hardin
Plaintiff Belinda J. Jackson−Lee TERMINATED: 05/18/2005
Plaintiff Barbara L. Johnson

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Plaintiff Leonard D. Klamm
Plaintiff Paul Nicholas Mastel
Plaintiff Lourdes A. Perez
Plaintiff Thomas Anthony Albanese
Plaintiff James E. Prime

Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Charolette B. Reeder TERMINATED: 06/23/2005
Plaintiff Dean Axford
Plaintiff Ellen Carter Reeves TERMINATED: 03/29/2005
Plaintiff Brent Conte TERMINATED: 03/29/2005
Plaintiff Carole Karron Rynston TERMINATED: 06/23/2005
Plaintiff Cheyenne Thomas
Plaintiff Kimberly DeCamp

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Pelagio Del Mar, Jr. TERMINATED: 06/22/2005 Plaintiff Pamela Turner
Plaintiff Dorothy Joan Duncan
Plaintiff Ronald S. Beaton TERMINATED: 06/22/2005 Plaintiff Thomas Lee Fenton
Plaintiff Theresa L. Cassity
Plaintiff Patricia A. Decker

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Paul Joseph Flake TERMINATED: 03/29/2005 Plaintiff Marcia Dorothy Dominguez
Plaintiff Tim D. Elliott
Plaintiff Stephen C. Gilbert
Plaintiff Zoe Ann Freeland
Plaintiff Steven Hanoski

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Calaine Griggs TERMINATED: 06/23/2005 Plaintiff Rona Sozanne Hartwick
Plaintiff Margaret H. Hay
Plaintiff Marjorie A. Hattrup
Plaintiff Robert Eugene Hudson, Jr.
Plaintiff Kirk T. Johnson TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Sandra F. Jolly TERMINATED: 06/23/2005 Plaintiff Marilyn S. Lankard
Plaintiff Dare W. Little
Plaintiff Roxanne Miles
Plaintiff Steven Ray McWilliams
Plaintiff Robert C. Miller

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Evelyn G. Miller
Plaintiff Patricia L. Pauscher TERMINATED: 04/01/2005 Plaintiff Arik Pollack
Plaintiff Deborah S. Scott
Plaintiff Joseph Robbins, Jr. TERMINATED: 06/23/2005 Plaintiff James L. Siders
Plaintiff Caren J. Smith TERMINATED: 06/23/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Sylvia A. Trevino TERMINATED: 06/23/2005
Plaintiff Charles Whitman Stephens, Jr.
Plaintiff Peggy Sue Timms TERMINATED: 06/23/2005
Plaintiff Ahmed Omar Adaweh TERMINATED: 06/22/2005
Plaintiff Denise Vanausdoll
Plaintiff Terri−Lynn Bartolome TERMINATED: 06/22/2005
Plaintiff Connie Woody Blackburn
Plaintiff

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

James W. White
Plaintiff Agnes C. Boyd
Plaintiff Teryl E. Casey
Plaintiff Randy W. Eaton
Plaintiff Gloria J. Elix TERMINATED: 06/22/2005 Plaintiff Richard P. Freni TERMINATED: 04/01/2005 Plaintiff Gerard R. Gagnier

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Maria V. Graffeo
Plaintiff LaMarl Harris TERMINATED: 06/23/2005 Plaintiff Frank Ikpeze TERMINATED: 06/23/2005 Plaintiff Robert Kestner
Plaintiff William R. Lerand
Plaintiff Rafael Lorie TERMINATED: 06/23/2005 Plaintiff Linda McGann

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Roger Newton TERMINATED: 06/23/2005 Plaintiff Karen (Rosenzweig) Pence
Plaintiff Floyd B. Summa
Plaintiff Catherine Mary Wood
Plaintiff David L. Borreson
Plaintiff Russell H. Brown

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mark Browne
Plaintiff Lydia Ann Burton
Plaintiff James Frank Gandy, Jr.
Plaintiff Eduardo S. Garrido
Plaintiff Albert L. Goodwin TERMINATED: 05/18/2005 Plaintiff Clifford M. Hallock

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael R. Hart TERMINATED: 06/23/2005
Plaintiff John R. Hegstrom
Plaintiff Mary Ellen Jaeger
Plaintiff Diane L. Johnson TERMINATED: 04/01/2005
Plaintiff Susan E. Lejserowits
Plaintiff Robert Loughbom, Jr. TERMINATED: 06/23/2005
Plaintiff Trudy L. Newton TERMINATED: 06/23/2005

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Judy K. Novosel TERMINATED: 03/29/2005
Plaintiff Mercy Porter
Plaintiff Ysabel Sanchez, Jr. TERMINATED: 06/23/2005
Plaintiff Ruth M. Stepien TERMINATED: 05/18/2005
Plaintiff Gradietta Woods
Plaintiff Gregory Lee Chapman
Plaintiff Ronald Ciampolillo TERMINATED: 06/22/2005
Plaintiff

ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Emily H. Fong
Plaintiff Katherine S. Fowler
Plaintiff Terry M. Gunnell
Plaintiff Therese Ann Hearl
Plaintiff Karen L. Henderson
Plaintiff Cynthia Ann Lackner

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Debra A. Marsh
Plaintiff Michael L. Marshall
Plaintiff Kelly S. Murphy
Plaintiff Treston R. Perkins
Plaintiff Richard A. Ritari
Plaintiff Steven Victor Roland

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Nancy B. Sherrill TERMINATED: 06/23/2005
Plaintiff Anna L. Sipe TERMINATED: 03/29/2005
Plaintiff Michael Smolen TERMINATED: 06/23/2005
Plaintiff Mark G. vonHausen
Plaintiff Berniece Branch Williams TERMINATED: 06/23/2005
Plaintiff Ferna P. Williams TERMINATED: 03/29/2005
Plaintiff Ernest Alvarez TERMINATED: 06/22/2005
Plaintiff Patricia Ona Barnett

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Arnetta R. Conley
Plaintiff Peter H. Duspiva
Plaintiff Tracy Ann Dykes
Plaintiff Ruth Fair
Plaintiff Tunja Jewel Gardner
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

John A. Hultquist, Jr.
Plaintiff Raymond C. Kirkland
Plaintiff Kristine Marie Lehane
Plaintiff Frederick R. Merz
Plaintiff Shirley Morris
Plaintiff Colleen L. Neill TERMINATED: 06/23/2005 Plaintiff

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Therese Rigano TERMINATED: 06/23/2005 Plaintiff Ricque L. Robinson TERMINATED: 06/23/2005 Plaintiff Dianne E. Sams
Plaintiff Gregory J. Scott
Plaintiff Patricia J. Sheets
Plaintiff James A. Williams
Plaintiff Clifford P. Wright, Jr.

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Christopher D. Blalock
Plaintiff Nancy A. Budd
Plaintiff Karen E. Campbell
Plaintiff Garrett Kent Carpenter TERMINATED: 06/22/2005 Plaintiff William A. Chance
Plaintiff James G. DiDio

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Barry Ferrell
Plaintiff Fellman George, Jr.
Plaintiff Philip J. Gooselaw
Plaintiff Rochelle Hawkins
Plaintiff Deborah M. Hufnagel TERMINATED: 04/03/2007

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Curtis L. Humphries
Plaintiff Robin Lee Karres
Plaintiff Deborah S, Kistner
Plaintiff Richard J. McCune
Plaintiff Carol S. Povolish
Plaintiff James Curtis Proctor, Jr.

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Christina Siemens
Plaintiff Edwin J. Terry
Plaintiff Linda S. Wilkerson TERMINATED: 06/23/2005 Plaintiff Randal Blough TERMINATED: 06/22/2005 Plaintiff Eva Carter TERMINATED: 03/29/2005 Plaintiff Gloria M. Fisher
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Latifah N. Hisham TERMINATED: 05/18/2005 Plaintiff Deborah Lynn Klundt
Plaintiff Toni Marie Lewis
Plaintiff William D. Lewis TERMINATED: 03/29/2005 Plaintiff James R. Lord TERMINATED: 03/29/2005 Plaintiff Frank F. Luppens
Plaintiff Diane A. Marciel

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Laura F. Mixon
Plaintiff Jeffrey A. Nispel
Plaintiff Mitchell L. Nutterfield
Plaintiff Steven Pepper TERMINATED: 06/23/2005 Plaintiff Douglas B. Roberson
Plaintiff Lloyd E. Sanders

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Joy L. Saxton
Plaintiff Cynthia J. Shaffer
Plaintiff Anthony R. Sosa
Plaintiff Ruben J. Zaragoza
Plaintiff Laurie A. Aguilar
Plaintiff Shirley A. Bassett

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Catherine A. Berzinski TERMINATED: 06/22/2005 Plaintiff Annie M. Burton TERMINATED: 06/22/2005 Plaintiff Catherine Cuevas
Plaintiff Edna H. Davis
Plaintiff Donald A. Fedge
Plaintiff Marcie A. Kenley

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Mary Elizabeth Lacy
Plaintiff Frank J. Matranga
Plaintiff Georgia McCormack
Plaintiff Darryl A. Miller
Plaintiff Debra Lynn Mitcham TERMINATED: 06/23/2005 Plaintiff Ellen M. Perkett TERMINATED: 06/23/2005 Plaintiff Alan F. Steinbrecher

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Jerry Lynn Tomlinson
Plaintiff Deborah L. Vaughan
Plaintiff Pamela Janice Vicchio−Cabral TERMINATED: 06/23/2005 Plaintiff Charlotte Weissman
Plaintiff Randy H. Yates
Plaintiff Linda S. Bardot

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Carolyn Jo Bednarz
Plaintiff Gregory M. Bolinski
Plaintiff Donald E. Contreras
Plaintiff Frederic G. Fischer
Plaintiff Kenneth T. Fu
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Hulbert
Plaintiff Rasiah Alfred Jey
Plaintiff Isaac W. Lamm
Plaintiff Thomas Lewis Long TERMINATED: 03/27/2006
Plaintiff Charles Agee
Plaintiff Harold G. Baumhardt

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Linda N. McElroy TERMINATED: 06/23/2005 Plaintiff Robert George Bibbings, II
Plaintiff Nancy B. Newlin
Plaintiff Thomas Bilvin
Plaintiff Debra Sharlene Olson TERMINATED: 06/23/2005 Plaintiff Vivian S. Carter TERMINATED: 06/22/2005 Plaintiff Pamela Sanchez

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Sherry Drury
Plaintiff Bruce Sidener
Plaintiff Deborah A. Theno
Plaintiff Larry Fultz
Plaintiff Jacqueline Ann Tyre TERMINATED: 05/18/2005 Plaintiff Carol A. Gabriel

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain

Plaintiff Jessica A. Vinzant TERMINATED: 06/23/2005
Plaintiff Roger Geimer TERMINATED: 06/23/2005
Plaintiff Carol Ann Zumbrunn TERMINATED: 06/23/2005
Plaintiff Evelyn P. Harris TERMINATED: 05/18/2005
Plaintiff Gene M. Haskins
Plaintiff Nina Hollowell
Plaintiff Ada Carol Keene

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Bruce Krueger TERMINATED: 05/18/2005 Plaintiff Russell A. Payton, Sr.
Plaintiff Wilfredo Aleman TERMINATED: 11/29/2005 Plaintiff Dori M. Porche
Plaintiff Andre P. Rack TERMINATED: 06/23/2005 Plaintiff John Adamson Beall
Plaintiff Mark W. Simmons

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff Karen Turner
Plaintiff Charles Curtis Blake
Plaintiff Rosemary E. Weidler
Plaintiff Nichole Bledsoe−Wise
Plaintiff Teresa J. Blevins
Plaintiff Christopher O. Dougherty

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff Stephen L. Eastridge
Plaintiff Peter Ellsworth TERMINATED: 03/29/2005 Plaintiff Kathy M. Hill TERMINATED: 03/29/2005 Plaintiff Kenneth Hoeflich
Plaintiff Duane S. Koziel
Plaintiff Frances A. Lindholm

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY

Plaintiff James R. McVicker
Plaintiff Cheryl Lynn Messenger TERMINATED: 05/18/2005 Plaintiff Sherryl Ann Nealy TERMINATED: 06/23/2005 Plaintiff Kenneth Roy Newell
Plaintiff Dianne M. Nunez
Plaintiff Frederick D. Raby
Plaintiff Richard A. Wright, Sr.

ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Ann Marie Carney Adams TERMINATED: 06/22/2005 Plaintiff Carl Trent Alexander
Plaintiff Joyce E. Anderson
Plaintiff Mark H. Cohen TERMINATED: 03/29/2005 Plaintiff Barbara L. Cook
Plaintiff Larry L. Coyle

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Barbara Ann DeMarie TERMINATED: 03/29/2005 Plaintiff Lee G. Hampshire
Plaintiff Betsy B. Krueger
Plaintiff Jo McCuaig Lillig
Plaintiff Joan Macewich
Plaintiff Michael P. Murphy

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Terry A. Phillips
Plaintiff Linda Ann Pilgreen
Plaintiff Esperanza Riojas
Plaintiff Ronald E. Sieve
Plaintiff Joyce B. Simmons
Plaintiff Leah Velasquez

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Plaintiff Joanna Welch TERMINATED: 03/29/2005 Plaintiff Marsha A. Willyard
Plaintiff Julia Atkeisson TERMINATED: 06/22/2005 Plaintiff Pamela Barbieri TERMINATED: 06/22/2005 Plaintiff Daniel J. Chapman
Plaintiff Rachel D. Coleman
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Mary Susan Cook TERMINATED: 06/22/2005
Plaintiff Patricia S. Cash TERMINATED: 06/22/2005
Plaintiff Daniel Burton Gilliam
Plaintiff Timothy Markham Goff
Plaintiff Leticia C. Gonzalez TERMINATED: 06/23/2005
Plaintiff Patricia A. Hammon
Plaintiff Abraham M. Harding TERMINATED: 06/23/2005
Plaintiff Janet C. Hawkins

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Richard M. Daniel
Plaintiff Cynthia S. Ellis
Plaintiff Alice Marie Helt
Plaintiff Robert Cecil Horne, Jr. TERMINATED: 03/29/2005 Plaintiff Teresa C. Espinoza
Plaintiff Michael J. Frymyer

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Ruth A. Jobe
Plaintiff Min Liu TERMINATED: 06/23/2005 Plaintiff Jacqueline Luczak
Plaintiff Cynthia Gordon TERMINATED: 06/23/2005 Plaintiff Kristina Wood Lunde
Plaintiff Mark D. Hagen TERMINATED: 06/23/2005 Plaintiff Gary Lee Houston

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY

Plaintiff David Eli Kanode TERMINATED: 06/23/2005
Plaintiff Diane Reaties McClinton
Plaintiff Phillip J. Karanauskas TERMINATED: 06/23/2005
Plaintiff Leo Jospeh Kwalik
Plaintiff Mary Lee McNamara TERMINATED: 06/23/2005
Plaintiff Daryl Mackay TERMINATED: 06/23/2005
Plaintiff James Christopher Robison

ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address)

Plaintiff Shauna S. Simmons TERMINATED: 06/23/2005 Plaintiff Sharon J. Moore
Plaintiff James R. Smoker, II
Plaintiff Douglas Patrick TERMINATED: 06/23/2005 Plaintiff Brayton White
Plaintiff Caroline Takahashi
Plaintiff

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by

Phil S. Ardoin TERMINATED: 06/22/2005 Plaintiff Kelly Lynn Boyd
Plaintiff John T. Dudley
Plaintiff Gary E. Thomas
Plaintiff Theresa Ferrini
Plaintiff C. Michael Finnell
Plaintiff

Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sherry A. Thomas
Plaintiff Charles L. Garrison TERMINATED: 06/23/2005 Plaintiff Gary R. Goolsby
Plaintiff John C. Carlisle TERMINATED: 06/22/2005 Plaintiff Ronald J. Cooley
Plaintiff Joe F. Cooper
Plaintiff Steven Earl Davidson TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Myriam Diaz de Jesus
Plaintiff Daniel Gastelum
Plaintiff Mary H. Gillispie
Plaintiff Donna Hartman
Plaintiff Juan Manuel Hernandez
Plaintiff Janis B. Jacks TERMINATED: 03/29/2005

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Diane Jo Luzadder
Plaintiff Karen Lynn TERMINATED: 05/18/2005 Plaintiff Ebenezer Oloyede
Plaintiff Swaine Leland Palmer
Plaintiff Ada Samoilovich
Plaintiff Robert C. Singleton, Sr.

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Stephanie M. Singleton TERMINATED: 06/23/2005 Plaintiff Charles E. Sorenson TERMINATED: 03/29/2005 Plaintiff Brian K. Spomer
Plaintiff Thea Straite
Plaintiff James H. Swartz TERMINATED: 06/23/2005 Plaintiff Beverly Ann Taylor
Plaintiff Margot L. Woolf

represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Michael H. Witt
Plaintiff Sandra M. Cuskaden
Plaintiff Maxine L. Coffey
Plaintiff Hector L. Rios
Plaintiff Socorro Rodriquez
Plaintiff Trinidad Rodriquez
Plaintiff Juan Manuel Ruiz
Plaintiff Sandra Serrano
Plaintiff Dora Torres
Plaintiff Jose A. Martinez
V. Petitioner Randy Moss
Petitioner Curtis B. Overall

represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Hector L. Rios PRO SE
represented by Socorro Rodriquez PRO SE
represented by Trinidad Rodriquez PRO SE
represented by Juan Manuel Ruiz PRO SE
represented by Sandra Serrano PRO SE
represented by Dora Torres PRO SE
represented by Jose A. Martinez PRO SE
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address)

Petitioner Pamela R. Eller
Petitioner Lee Gillian Kinsey TERMINATED: 03/29/2005 Petitioner Adele Pearson
V. Defendant Sprint/United Management Company

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Ashley R. Hurst Rogers & Hardin LLP 2700 International Tower 229 Peachtree Street, N.E. Atlanta, GA 30303−1601 404−522−4700 Fax: 404−525−2224 Email: ahurst@rh−law.com LEAD ATTORNEY PRO HAC VICE
Chris R. Pace Ogletree, Deakins, Nash, Smoak & Stewart, PC − KC 4520 Main Street, Suite 400 Kansas City, MO 64111 816−471−1301 Fax: 816−471−1303 Email: chris.pace@ogletree.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Christine F. Miller Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: christine.miller@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
David M. Eisenberg Baker, Sterchi, Cowden & Rice, LLC − KC 2400 Pershing Road, Suite 500 Kansas City, MO 64108−2533 816−471−2121 Fax: 816−472−0288 Email: eisenberg@bscr−law.com

LEAD ATTORNEY ATTORNEY TO BE NOTICED
David A. Schatz Spencer Fane LLP − KC 1000 Walnut Street, Suite 1400 Kansas City, MO 64106 816−474−8100 Fax: 816−474−3216 Email: dschatz@spencerfane.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
David L. Schenberg Ogletree, Deakins, Nash, Smoak & Stewart, PC − St. Louis 7700 Bonhomme, Suite 650 St. Louis, MO 63105 314−802−3956 Fax: 314−802−3936 Email: david.schenberg@ogletreedeakins.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Gerard K. Rodriguez Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 x 1932 Fax: 314−480−1505 Email: jerry.rodriguez@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Harry B. Wilson , Jr. Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: harry.wilson@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Hunter R. Hughes , III Rogers & Hardin LLP 2700 International Tower 229 Peachtree Street, N.E. Atlanta, GA 30303−1601 404−522−4700 Fax: 404−525−2224 Email: hrh@rh−law.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
J. Timothy McDonald Rogers & Hardin LLP 2700 International Tower 229 Peachtree Street, N.E. Atlanta, GA 30303−1601 404−522−4700

Fax: 404−525−2224 Email: jtm@rh−law.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
James F. Monafo Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: jim.monafo@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Jill S. Ferrel Sprint Nextel Corporation 6220 Sprint Parkway, 5th Floor Overland Park, KS 66251 913−794−3800 Email: jill.ferrel@sprint.com TERMINATED: 02/27/2007 LEAD ATTORNEY
John Da Grosa Smith Rogers & Hardin LLP 2700 International Tower 229 Peachtree Street, N.E. Atlanta, GA 30303−1601 404−522−4700 Fax: 404−525−2224 Email: jds@rh−law.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
John J. Yates 66 Janssen Place Kansas City, Mi 64109−2621 816−668−7620 Email: kclaxdad@gmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joseph H. Guffey Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: joe.guffey@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Joseph H. Knittig The Global Orphan Project 6114 N. 9 Highway Parkville, MO 64152 816−547−1495 Email: joe@goproject.org TERMINATED: 08/15/2003 LEAD ATTORNEY

Kara Dorssom Larson Kansas City Power & Light − Main 1200 Main Street Kansas City, MO 64105 816−556−2097 Email: kara.larson@kcpl.com TERMINATED: 01/06/2006 LEAD ATTORNEY
Mark G. Arnold Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1802 Fax: 314−480−1505 Email: mark.arnold@huschblackwell.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Michael F. Jones Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: michael.jones@huschblackwell.com TERMINATED: 02/17/2006 LEAD ATTORNEY PRO HAC VICE
Nicole Hininger Howell Constangy, Brooks, Smith & Prophete LLP − KC 2600 Grand Boulevard, Suite 750 Kansas City, MO 64108−4600 816−329−5932 Fax: 816−472−6401 Email: nhowell@constangy.com TERMINATED: 01/09/2006 LEAD ATTORNEY
Patrick M. Gavin Sprint Corporation − 6450 6450 Sprint Parkway Overland Park, KS 66251 913−315−1007 Email: Patrick.Gavin@sprint.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Patrick F. Hulla Ogletree, Deakins, Nash, Smoak & Stewart, PC − KC 4520 Main Street, Suite 400 Kansas City, MO 64111 816−471−1301 Fax: 816−471−1303 Email: patrick.hulla@ogletree.com TERMINATED: 10/07/2005 LEAD ATTORNEY
Paul D. Seyferth Seyferth Blumenthal & Harris LLC

4801 Main Street, Suite 310 Kansas City, MO 64112 816−756−0700 Fax: 816−756−3700 Email: paul@sbhlaw.com TERMINATED: 08/15/2003 LEAD ATTORNEY
Philip R. Dupont Sandberg Phoenix & von Gontard PC − KC 4600 Madison Avenue, Suite 1250 Ste 1250 Kansas City, MO 64112−3032 816−627−5534 Fax: 816−627−5532 Email: pdupont@sandbergphoenix.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert Anthony Costello Husch Blackwell LLP − 4801 Main 4801 Main Street, Suite 1000 Kansas City, MO 64112 816−329−4728 Email: Tony.Costello@Huschblackwell.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert C. Johnson Oshkosh Truck Corporation 2307 Oregon Street Oshkosh, WI 54902 920−233−9236 Email: rjohnson@oshtruck.com TERMINATED: 11/15/2006 LEAD ATTORNEY
Sonni L. Fort Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 TERMINATED: 02/26/2004 LEAD ATTORNEY PRO HAC VICE
Stephany J. Newport Sprint 6360 Sprint Parkway KSOPHE0210−2A400 Overland Park, KS 66251−6105 913−762−5824 Fax: 913−523−0390 Email: stephany.newport@sprint.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Tamara M. Spicer Elias Gutzler Spicer LLC 130 S. Bemiston, Ste 302 St. Louis, MO 63105 314−274−3311 Email: tspicer@egslitigation.com LEAD ATTORNEY

Movant Right Management Consultants TERMINATED: 03/29/2004
V. Interested Party Cheryl Bolton and all other plaintiffs in case no. 05−2361−JWL

ATTORNEY TO BE NOTICED
Thomas A. McCarthy Husch Blackwell LLP − Carondelet 190 Carondelet Plaza, Suite 600 St. Louis, MO 63105−3441 314−480−1500 Fax: 314−480−1505 Email: thomas.mccarthy@huschblackwell.com LEAD ATTORNEY PRO HAC VICE
Thomas Joseph Mew , IV Rogers & Hardin LLP 2700 International Tower 229 Peachtree Street, N.E. Atlanta, GA 30303−1601 404−522−4700 Fax: 404−525−2224 Email: tmew@rh−law.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
represented by James A. Durbin Swanson Midgley, LLC − KC 4600 Madison Avenue, Suite 1100 Kansas City, MO 64112−3043 816−842−6100 ext 4803 Fax: 816−842−0013 Email: jadurbin@swansonmidgley.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Andrew H. McCue The Accurso Law Firm 4646 Roanoke Parkway Kansas City, MO 64112 816−561−3900 Fax: 816−561−2992 Email: amccue@accursolaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Bert S. Braud (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian D. DeFrain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Claudio E. Molteni (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Daniel B. Kohrman AARP Foundation Litigation 601 E. Street, NW Washington, DC 20049 202−434−2064 Fax: 202−434−6424 Email: dkohrman@aarp.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Deborah J. Blakely (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dennis E. Egan (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Dirk L. Hubbard (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gene P. Graham , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
John M. Klamann (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth B. McClain (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laurie A. McCann AARP Foundation Litigation 601 E. Street, NW Washington, DC 20049 202−434−2082 Fax: 202−434−6425 Email: lmccann@aarp.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Martin M. Meyers (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Matthew C. Billips (See above for address) TERMINATED: 07/23/2008 LEAD ATTORNEY PRO HAC VICE
Stephen J. Dennis (See above for address)

Interested Party John H. Poehlman

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Thomas W. Osborne AARP Foundation Litigation 601 E. Street, NW Washington, DC 20049 202−434−2060 Fax: 202−434−6424 Email: tosborne@aarp.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
represented by John H. Poehlman 4022 NE 132nd Street Smithville, MO 64089 816−532−1176 PRO SE

Date Filed 04/23/2003 04/23/2003 06/13/2003 06/16/2003 07/08/2003
07/09/2003 07/16/2003
07/16/2003 07/16/2003 07/16/2003 07/23/2003 07/29/2003

# Docket Text
1 COMPLAINT with trial location of Kansas City, Kansas, No Summons Issued, Jury Demand, filed by Plaintiff Shirley Williams.(tub) (Entered: 04/24/2003)
FILING FEE PAID: In the amount of $150.00, receipt number 098547. (tub) (Entered: 04/24/2003)
SUMMONS ISSUED as to Sprint/United Management Company. (mm) (Entered: 06/13/2003)
2 RETURN OF SERVICE filed by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 06/16/2003)
3 MOTION for Leave to file its Answer to Plaintiff's Complaint Out of Time and for Additional Time Within Which to File Its Answer to the Complaint and Memorandum by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit Affidavit of Patrick Hulla)(Yates, John) (Entered: 07/08/2003)
4 NOTICE of Appearance by Patrick F. Hulla on behalf of Sprint/United Management Company (Hulla, Patrick) (Entered: 07/09/2003)
5 ORDER granting 3 Motion for Leave to File Its Answer to Plaintiff's Complaint Out of Time and For Additional Time Within Which to File Its Answer to The Complaint. Defendant is hereby granted leave to file its answer to Plaintiff's Complaint out of time and Defendant shall have until July 23, 2003, within which to file its answer or otherwise respond to Plaintiff's Complaint. Entered by Judge David J. Waxse on 7/16/2003.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jm) (Entered: 07/16/2003)
6 NOTICE of Appearance by Bert S. Braud on behalf of Shirley Williams (Braud, Bert) (Entered: 07/16/2003)
7 ENTRY OF APPEARANCE by John M. Klamann on behalf of Shirley Williams. (Klamann, John) (Entered: 07/16/2003)
8 ENTRY OF APPEARANCE by Deborah J. Blakely on behalf of all plaintiffs. (Blakely, Deborah) (Entered: 07/16/2003)
9 ANSWER to Complaint by Sprint/United Management Company.(Yates, John) (Entered: 07/23/2003)
10 ENTRY OF APPEARANCE by Dirk L. Hubbard on behalf of Shirley Williams. (Hubbard, Dirk) (Entered: 07/29/2003)

07/31/2003 07/31/2003 08/05/2003 08/13/2003 08/13/2003 08/13/2003 08/13/2003 08/13/2003 08/14/2003 08/14/2003 08/14/2003 08/14/2003 08/14/2003 08/14/2003
08/15/2003 08/15/2003 08/18/2003
08/22/2003 08/27/2003 08/28/2003

11 NOTICE of Appearance by Chris R. Pace on behalf of Sprint/United Management Company (Pace, Chris) (Entered: 07/31/2003)
12 NOTICE of Appearance by Martin M. Meyers on behalf of Shirley Williams (Meyers, Martin) (Entered: 07/31/2003)
13 ORDER SETTING SCHEDULING CONFERENCE: Telephone Scheduling Conference set for 9/10/2003 at 10:00 AM before Magistrate Judge David J. Waxse. Signed by Judge David J. Waxse on 8/5/03. (ll) (Entered: 08/05/2003)
14 NOTICE of Shirley Williams of Consent of Jeffrey Moore to Join as Plaintiff by Shirley Williams (Egan, Dennis) (Entered: 08/13/2003)
15 NOTICE of by Shirley Williams of Consent of Joe Norton to Join As Plaintiff by Shirley Williams (Egan, Dennis) (Entered: 08/13/2003)
16 NOTICE of Shirley Williams of consent of Robert O. Smith to Join As Plaintiff by Shirley Williams (Egan, Dennis) (Entered: 08/13/2003)
17 NOTICE of Shirley Williams of Consent of Teresa Warnick to Join As Plaintiff by Shirley Williams (Egan, Dennis) (Entered: 08/13/2003)
18 NOTICE of Appearance by David M Eisenberg on behalf of Sprint/United Management Company (Eisenberg, David) (Entered: 08/13/2003)
19 MOTION for attorney Christine F. Miller to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Christine F. Miller)(Yates, John) (Entered: 08/14/2003)
20 MOTION for attorney James F. Monafo to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit James F. Monafo)(Yates, John) (Entered: 08/14/2003)
21 MOTION for attorney Sonni L. Fort to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Sonni L. Fort)(Yates, John) (Entered: 08/14/2003)
22 MOTION to Withdraw as Attorney by Defendant Sprint/United Management Company (Knittig, Joseph) (Entered: 08/14/2003)
23 MOTION to Withdraw as Attorney by Defendant Sprint/United Management Company (Seyferth, Paul) (Entered: 08/14/2003)
PRO HAC VICE FEE PAID: on 8/14/03 for attorney Sonni Fort, James Monafo, Christine Miller; 19 MOTION for attorney Christine F. Miller to appear pro hac vice, 20 MOTION for attorney James F. Monafo to appear pro hac vice, 21 MOTION for attorney Sonni L. Fort to appear pro hac vice in the amount of $75.00; Receipt Number 099959. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (trs) (Entered: 08/18/2003)
24 ORDER granting 22 Motion to Withdraw as Attorney Joseph H. Knittig terminated; Signed by Judge David J. Waxse on 8/15/03. (trs) (Entered: 08/18/2003)
25 ORDER granted 23 Motion to Withdraw as Attorney Paul D. Seyferth terminated;Signed by Judge David J. Waxse on 8/15/03. (trs) (Entered: 08/18/2003)
26 ORDER granting 19 Motion to Appear Pro Hac Vice by Christine F. Miller, granting 20 Motion to Appear Pro Hac Vice by James F. Monafo, granting 21 Motion to Appear Pro Hac by Sonni L. Fort, all for defendant Sprint/United Management Company; Signed by Judge David J. Waxse on 8/18/03. (trs) (Entered: 08/19/2003)
27 MOTION for Hearing Rule 16 Conference and to Stay Current Scheduling Order by Defendant Sprint/United Management Company (Yates, John) (Entered: 08/22/2003)
28 NOTICE of Consent of Anita Reeves to Join as Plaintiff by Shirley Williams (Egan, Dennis) (Entered: 08/27/2003)
29 RESPONSE by Plaintiff Shirley Williams re 27 MOTION for Hearing Rule 16 Conference and to Stay Current Scheduling Order Plaintiffs' Response in Support of Defendant's Motion for Rule 16 Conference (Egan, Dennis) (Entered: 08/28/2003)

08/28/2003 09/09/2003
09/16/2003 09/17/2003 09/17/2003 09/18/2003 09/18/2003 09/26/2003 10/07/2003 10/13/2003
10/13/2003
10/13/2003
10/13/2003
10/17/2003 10/17/2003 10/20/2003

30 STATEMENT OF CORPORATE INTEREST by Defendant Sprint/United Management Company. (Attachments: # 1)(Yates, John) (Entered: 08/28/2003)
31 ORDER granting 27 Defendant's Motion for Rule 16 Conference and to Stay Current Scheduling Order. The telephone scheduling conference set for September 10, 2003 is cancelled. A joint status conference with the similar cases of Cami V. Owens v. Sprint/United Management Co. (No. 03−2371−JWL) and Yvonne Wood v. Sprint/United Management Co. (No. 03−2384−JWL) is set for September 17, 2003 at 2:00 p.m. before United States District Judge Lungstrum and Magistrate Judge Waxse. (See Order for detail.) Signed by Judge David J. Waxse on 9/9/2003.(jm) (Entered: 09/09/2003)
32 STATEMENT Defendant's Pre−Conference Memorandum by Defendant Sprint/United Management Company. (Yates, John) (Entered: 09/16/2003)
33 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2003)
Status Conference held before Judge John W. Lungstrum and Judge David J. Waxse on 9/17/2003. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jm) (Entered: 10/07/2003)
34 FIRST PHASE SCHEDULING ORDER:, Judge David J. Waxse no longer assigned to case. (SEE ORDER FOR DETAILS). Signed by Judge John W. Lungstrum on 09/18/03. (ses) (Entered: 09/18/2003)
35 ENTRY OF APPEARANCE by Jill S. Ferrell on behalf of Sprint/United Management Company. (Ferrell, Jill) (Entered: 09/18/2003)
36 Unopposed MOTION to Modify Scheduling Order by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 09/26/2003)
37 ORDER granting 36 Motion to Modify . Signed by Judge John W. Lungstrum on 10/07/03. (ses) (Entered: 10/07/2003)
38 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Defendant regarding overview of the corporate, divisional and management organizational structure of Defendant during period of January 1, 2000, to the date of the deposition on October 20, 2003 (Klamann, John) (Entered: 10/13/2003)
39 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized representative of the Defendant to testify regarding Sprint's corporate−wide internal communications, media relations and investor relations during the period January 1, 2000 to the date of this deposition on October 21, 2003 (Klamann, John) (Entered: 10/13/2003)
40 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized representative of Defendant to testify regarding the HR department management structure, the HRIS system and HR policies and procedures during period of January 1, 2000, to the date of the deposition on October 22, 2003 (Klamann, John) (Entered: 10/13/2003)
41 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized representative of Defendant to testify regarding document and data collection and retention, including computerized and electronic documents and data collection, retention and reporting during the period of January 1, 2000, to the date of this deposition on October 23, 2003 (Klamann, John) (Entered: 10/13/2003)
42 MOTION for extension of time Within Which to Answer or Otherwise Respond to Plaintiff's First Request for Production of Documents and First Interrogatories and Memorandum in Support Thereof by Defendant Sprint/United Management Company (Yates, John) (Entered: 10/17/2003)
43 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Yates, John) (Entered: 10/17/2003)
45 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint representative for HR Department and HRIS System on October 22, 2003 (Klamann,

10/20/2003 10/21/2003
10/21/2003
10/21/2003
10/28/2003 10/30/2003 11/03/2003 11/03/2003 11/14/2003 11/14/2003 11/14/2003 11/19/2003 11/20/2003 11/21/2003 11/25/2003 12/01/2003

John) (Entered: 10/20/2003)
46 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint representative regarding corporate, divisional and management organizational structure on October 23, 2003 (Klamann, John) (Entered: 10/20/2003)
47 ORDER setting a Motion Hearing re 42 MOTION for Extension of Time Within Which to Answer or Otherwise Respond to Plaintiff's First Request for Production of Documents and First Interrogatories, filed by Sprint/United Management Company. A Motion Hearing by telephone is hereby set for today, 10/21/2003 at 03:00 PM before Magistrate Judge David J. Waxse, to be initiated by the U.S. Magistrate Judge's office. (THIS IS A TEXT ONLY ENTRY. NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION.) Entered by Judge David J. Waxse on 10/21/2003.(jm) (Entered: 10/21/2003)
48 Minute Entry for Motion Hearing held before Judge David J. Waxse on 10/21/2003 re 42 Defendant's Motion for Extension fo Time Within Which to Answer or Otherwise Respond to Plaintiff's First Request for Production of Documents and First Interrogatories. (THIS IS A TEXT ENTRY ONLY − NO PDF DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION.) (ll) (Entered: 10/21/2003)
49 MINUTE SHEET of motion hearing held 10/21/03 before Judge David J. Waxse: granting 42 Defendant's Motion for Extension fo Time Within Which to Answer or Otherwise Respond to Plaintiff's First Request for Production of Documents and First Interrogatories. The deadline before which Defendant shall serve its responses and objections is extended to Monday, November 3, 2003. (ll) (Modified on 10/22/2003 to clarify text (trs)). (Entered: 10/21/2003)
50 CERTIFICATE OF SERVICE by Shirley Williams Certificate of Service of Discovery. (Braud, Bert) (Entered: 10/28/2003)
51 Joint MOTION for Protective Order by Defendant Sprint/United Management Company (Yates, John) (Entered: 10/30/2003)
52 STIPULATED PROTECTIVE ORDER granting 51 Motion for Protective Order . Signed by Judge John W. Lungstrum on 11/03/03. (ses) (Entered: 11/03/2003)
53 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Yates, John) (Entered: 11/03/2003)
54 MOTION to Compel by Plaintiff Shirley Williams (Attachments: # 1 Exhibit AA (Plaintiffs' First Interrogatories)# 2 Exhibit BB (Defendant's Responses))(Dennis, Stephen) (Entered: 11/14/2003)
55 MEMORANDUM IN SUPPORT of 54 MOTION to Compel by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B)(Dennis, Stephen) (Entered: 11/14/2003)
56 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Dennis, Stephen) (Entered: 11/14/2003)
57 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 54 MOTION to Compel (Attachments: # 1 Exhibit Exhibit A# 2 # 3 # 4 # 5 # 6)(Hulla, Patrick) (Entered: 11/19/2003)
58 NOTICE of Hearing by Telephone on 54 MOTION to Compel: Motion Hearing (by telephone) set for 11/21/2003 at 09:30 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 11/20/2003)
59 ORDER granting 54 Motion to Compel . Signed by Judge John W. Lungstrum on 11/21/2003. (ses) (Entered: 11/21/2003)
60 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Representative on December 8, 2003 (Klamann, John) (Entered: 11/25/2003)
61 CERTIFICATE OF SERVICE by Sprint/United Management Company of Defendant's Responses to Plaintiff's First Requests for Production of Documents. (Yates, John) (Entered: 12/01/2003)

12/02/2003
12/23/2003 01/05/2004 01/05/2004 01/05/2004 01/05/2004 01/09/2004 01/15/2004 01/15/2004 01/15/2004 01/15/2004 01/15/2004 01/15/2004 01/16/2004
01/20/2004
01/22/2004
01/22/2004 01/22/2004 01/22/2004 01/22/2004 01/22/2004
01/22/2004

62 CERTIFICATE OF SERVICE by Sprint/United Management Company for Responses to Plaintiff's Second Request for Production of Documents Directed to Defendant. (Yates, John) (Entered: 12/02/2003)
63 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 12/23/2003)
64 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Representative on January 12, 2004 (Klamann, John) (Entered: 01/05/2004)
65 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint representative on January 13, 2004 (Klamann, John) (Entered: 01/05/2004)
66 NOTICE by Plaintiff Shirley Williams of taking deposition of Certain employees of Sprint on January 15, 2004 (Klamann, John) (Entered: 01/05/2004)
67 NOTICE by Plaintiff Shirley Williams of taking deposition of Ann Morrill on January 19, 2004 (Klamann, John) (Entered: 01/05/2004)
68 NOTICE of Change of Address by Patrick F. Hulla (Hulla, Patrick) (Entered: 01/09/2004)
69 NOTICE by Defendant Sprint/United Management Company of taking deposition of Shirley Williams on March 2, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
70 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeff Moore on March 2, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
71 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert O. Smith on March 2, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
72 NOTICE by Defendant Sprint/United Management Company of taking deposition of Teresa Warnick on March 2, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
73 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joe Norton on March 3, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
74 NOTICE by Defendant Sprint/United Management Company of taking deposition of Anita Reeves on March 2, 2004 (Hulla, Patrick) (Entered: 01/15/2004)
75 MOTION to Amend Scheduling Order Plaintiff's Motion to Extend Deadline for Amending Pleadings; Naming An Expert by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 01/16/2004)
76 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 75 MOTION to Amend Scheduling Order Plaintiff's Motion to Extend Deadline for Amending Pleadings; Naming An Expert (Hulla, Patrick) (Entered: 01/20/2004)
77 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) authorized representative of defendant Sprint on January 30, 2004 (Braud, Bert) (Entered: 01/22/2004)
78 NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management on 2/6/04 (Dennis, Stephen) (Entered: 01/22/2004)
79 NOTICE by Plaintiff Shirley Williams of taking deposition of Ron LeMay on January 29, 2004 (Egan, Dennis) (Entered: 01/22/2004)
80 CERTIFICATE OF SERVICE by Sprint/United Management Company (Hulla, Patrick) (Entered: 01/22/2004)
81 MOTION to Compel Full Discovery Responses by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 01/22/2004)
82 MEMORANDUM IN SUPPORT of 81 MOTION to Compel Full Discovery Responses Tab A by Plaintiff Shirley Williams (Attachments: # 1 Exhibit Attachment)(Egan, Dennis) (Entered: 01/22/2004)
83 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit Compliance Attachment)(Egan, Dennis) (Entered: 01/22/2004)

01/26/2004
01/26/2004 01/27/2004 01/28/2004 01/29/2004 02/02/2004 02/02/2004
02/03/2004 02/03/2004 02/03/2004 02/03/2004 02/03/2004 02/04/2004
02/05/2004 02/05/2004 02/06/2004 02/12/2004

84 ORDER granting 75 Motion to Amend Scheduling Order as set forth in full on the record. Plaintiff's motion to compel 81 is set for hearing on Friday, February 6, 2004 at 9:30 a.m.. Signed by Judge John W. Lungstrum on 01/26/2004. (ses) (Entered: 01/26/2004)
85 NOTICE OF WITHDRAWAL and ENTRY OF APPEARANCE by Stephany J. Newport on behalf of all defendants (Newport, Stephany) (Entered: 01/26/2004)
86 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 01/27/2004)
87 MOTION for Discovery Motion to Clarify Propriety of Depositions of Plaintiffs and Opt−Ins During First Phase Discovery by Plaintiff Shirley Williams (Attachments: # 1 Exhibit)(Egan, Dennis) (Entered: 01/28/2004)
88 CERTIFICATE OF SERVICE by Shirley Williams of Discovery: Plaintiffs' Third Interrogatories and Fourth Document Request to Defendant. (Braud, Bert) (Entered: 01/29/2004)
89 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Fourth Interrogatories to Defendant. (Egan, Dennis) (Entered: 02/02/2004)
90 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 81 MOTION to Compel Full Discovery Responses (Attachments: # 1 Index# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D# 6 Exhibit E# 7 Exhibit F# 8 Exhibit G# 9 Exhibit H# 10 Exhibit I# 11 Exhibit J# 12 Exhibit K# 13 Exhibit L# 14 Exhibit M# 15 Exhibit N# 16 Exhibit O# 17 Exhibit P# 18 Exhibit Q# 19 Exhibit R# 20 Exhibit S)(Hulla, Patrick) (Entered: 02/02/2004)
91 NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent for RIF labeled PCS on To Be Mutually Agreed Upon (Egan, Dennis) (Entered: 02/03/2004)
92 NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent for RIF labeled Network and Information Technologies on To Be Mutually Agreed Upon (Egan, Dennis) (Entered: 02/03/2004)
93 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management on 2/27/04 (Dennis, Stephen) (Entered: 02/03/2004)
94 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent for RIF labeled PCS on To Be Mutually Agreed Upon (Egan, Dennis) (Entered: 02/03/2004)
95 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent for RIF labeled Network and Information Technologies on To Be Mutually Agreed Upon (Egan, Dennis) (Entered: 02/03/2004)
96 RESPONSE by Defendant Sprint/United Management Company re 87 MOTION for Discovery Motion to Clarify Propriety of Depositions of Plaintiffs and Opt−Ins During First Phase Discovery (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Hulla, Patrick) (Entered: 02/04/2004)
97 MOTION to Compel Motion to Shorten Time Within Which Defendant Must Respond to Plaintiff's Fourth Request for Production of Documents by Plaintiff Shirley Williams (Braud, Bert) (Entered: 02/05/2004)
98 NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent of Sprint on 02−16−04 (Meyers, Martin) (Entered: 02/05/2004)
99 ORDER denying 81 Motion to Compel, granting 87 Motion for Discovery, and granting 97 Motion to Compel . (SEE ORDER FOR DETAILS) Signed by Judge John W. Lungstrum on 02/06/2004. (ses) (Entered: 02/06/2004)
100 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiff's Fifth Request for Production of Documents and Things. (Egan, Dennis) (Entered: 02/12/2004)

02/12/2004 02/13/2004 02/13/2004 02/13/2004 02/13/2004 02/13/2004 02/13/2004 02/16/2004 02/17/2004
02/19/2004 02/20/2004 02/20/2004 02/20/2004 02/23/2004 02/23/2004 02/23/2004
02/24/2004 02/24/2004 02/25/2004 02/26/2004

101 MOTION to Compel Plaintiffs' Combined Motion (and Suggestions) to Shorten Time for Defendant's Response to Plaintiffs' Fifth Request for Documents and Data by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 02/12/2004)
102 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 02/13/2004)
103 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 02/13/2004)
104 CERTIFICATE OF SERVICE by Sprint/United Management Company (PCS). (Hulla, Patrick) (Entered: 02/13/2004)
105 CERTIFICATE OF SERVICE by Sprint/United Management Company NET/IT. (Hulla, Patrick) (Entered: 02/13/2004)
106 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 02/13/2004)
107 CERTIFICATE OF SERVICE by Sprint/United Management Company (4thI). (Hulla, Patrick) (Entered: 02/13/2004)
108 CERTIFICATE OF SERVICE by Sprint/United Management Company RPD. (Hulla, Patrick) (Entered: 02/16/2004)
109 ORDER granting 101 Motion to Compel Plaintiffs' Combined Motion (and Suggestions) to Shorten Time for Defendant's Response to Plaintiffs' Fifth Request for Documents and Data. Signed by Judge John W. Lungstrum on 02/17/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 02/17/2004)
110 NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent of Sprint on 2/26/04 (Meyers, Martin) (Entered: 02/19/2004)
111 MOTION to Compel Regarding Adverse Impact Analyses by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B)(Egan, Dennis) (Entered: 02/20/2004)
112 MEMORANDUM IN SUPPORT of 111 MOTION to Compel Regarding Adverse Impact Analyses by Plaintiff Shirley Williams (Attachments: # 1 Attachment)(Egan, Dennis) (Entered: 02/20/2004)
113 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A)(Egan, Dennis) (Entered: 02/20/2004)
114 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (s) of Defendant Sprint on March 5, 2004 (Hubbard, Dirk) (Entered: 02/23/2004)
115 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Dienhart on March 9, 2004 (Braud, Bert) (Entered: 02/23/2004)
116 CERTIFICATE OF SERVICE by Sprint/United Management Company for Defendant's Responses to Plaintiff's Fifth Request for Production of Documents and Things to Defendant Sprint/United Management Company. (Yates, John) (Entered: 02/23/2004)
117 MOTION to Compel regarding Plaintiffs' Fourth Request for Production of Documents by Plaintiff Shirley Williams (Attachments: # 1 Exhibit 1)(Braud, Bert) (Entered: 02/24/2004)
118 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Braud, Bert) (Entered: 02/24/2004)
119 MOTION to Withdraw as Attorney (attorney Sonni L. Fort) by Defendant Sprint/United Management Company (Yates, John) (Entered: 02/25/2004)
120 ORDER granting 119 Motion to Withdraw as Attorney. Attorney Sonni L. Fort terminated . Signed by Judge John W. Lungstrum on 02/26/2004.(This is a TEXT

02/26/2004 02/26/2004 02/26/2004
02/26/2004 02/27/2004 02/27/2004
02/27/2004
02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004

ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 02/26/2004)
121 CERTIFICATE OF SERVICE by Sprint/United Management Company of Defendant's Answers and Objections to Plaintiffs' Third Interrogatories. (Hulla, Patrick) (Entered: 02/26/2004)
122 Unopposed MOTION for extension of time for filing their Motion to file an Amended Complaint by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 02/26/2004)
123 MEMORANDUM in Opposition by Sprint/United Management Company regarding 111 MOTION to Compel Regarding Adverse Impact Analyses (Attachments: #(1) Exhibit A; #(2) Exhibit B; #(3) Exhibit C; #(4) Exhibit D; #(5) Exhibit E; #(6) Exhibit F; #(7) Exhibit G)(Hulla, Patrick) (Modified on 2/27/2004 to correct the filer of this entry. (mg)) (Entered: 02/26/2004)
124 ORDER granting 122 Unopposed Motion for Extension of Time to File Amended Complaint. Deadline for filing of amended complaint extended to April 16, 2004. Signed by Judge John W. Lungstrum on 02/26/2004. (ses) (Entered: 02/26/2004)
125 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management on 3/5/04 (Dennis, Stephen) (Entered: 02/27/2004)
126 SECOND AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of a Sprint Representative regarding numeric/alpha rating system on March 2, 2004. (Klamann, John) (Modified on 3/1/2004 to spell out abbreviations used. (mg)) (Entered: 02/27/2004)
127 ORDER re 111 MOTION to Compel Regarding Adverse Impact Analyses filed by Shirley Williams, 117 MOTION to Compel regarding Plaintiffs' Fourth Request for Production of Documents filed by Shirley Williams Telephone Conference set for 3/2/2004 at 11:30 AM before Chief Judge John W. Lungstrum.. Signed by Judge John W. Lungstrum on 02/27/2004. (ses) (Entered: 02/27/2004)
128 NOTICE of Consent of Bert R. Allen by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
129 NOTICE of Consent of Jesse W. Ballard by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
130 NOTICE of Consent of Patricia Barbe by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
131 NOTICE of Consent of Michael E. Bauman by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
132 NOTICE of Consent of Judy Ann Budihas by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
133 NOTICE of Consent of William Craig Cezar by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
134 NOTICE of Consent of Steven K. Constance by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
135 NOTICE of Consent of Mark A. Cragin by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
136 NOTICE of Consent of Alecia M. Cripps by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
137 NOTICE of Consent of Tammy A. Darling by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
138 NOTICE of Consent of James Dawson by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
139 NOTICE of Consent of Albert M. Frankovich by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)

02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 02/27/2004 03/04/2004

140 NOTICE of Consent of Stephen J. Gallup by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
141 NOTICE of Consent of Thomas M. Gerrity by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
142 NOTICE of Consent of Les Goodwin by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
143 NOTICE of Consent of Michael J. Grahovac by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
144 NOTICE of Consent of Bruce Hertzfield by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
145 NOTICE of Consent of William Hicks by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
146 NOTICE of Consent of Thomas J. Hollingsworth by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
147 NOTICE of Consent of Andrew Justesen by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
148 NOTICE of Consent of James A. Loetel by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
149 NOTICE of Consent of Sam Matier by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
150 NOTICE of Consent of Michael McVicker by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
151 NOTICE of Consent of Joseph A. Morse by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
152 NOTICE of Consent of James A. Noah by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
153 NOTICE of Consent of William E. Pitts by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
154 NOTICE of Consent of Patricia C. Plantenberg by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
155 NOTICE of Consent of Edward O. Rawlings by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
156 NOTICE of Consent of Bruce F. Salisbury by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
157 NOTICE of Consent of Tony D. Schroeder by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
158 NOTICE of Consent of Neil Sieber by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
159 NOTICE of Consent of Clarence Albert Wildes, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 02/27/2004)
160 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Driscoll on March 5, 2004 (Graham, Gene) (Entered: 02/27/2004)
161 NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Agent on March 5, 2004 (Graham, Gene) (Entered: 02/27/2004)
162 ORDER denying 111 Motion to Compel and taking under advisement 117 Motion to Compel . Signed by Judge John W. Lungstrum on 03/04/2004. (ses) (Entered: 03/04/2004)

03/04/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004 03/05/2004

163 ORDER finding as moot plaintiff's 117 Motion to Compel . Signed by Judge John W. Lungstrum on 03/04/2004. (ses) (Entered: 03/04/2004)
164 NOTICE of Consent of Dawne M. Adams by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
165 NOTICE of Consent of Constance J. Bonovich by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
166 NOTICE of Consent of Agus R. Budiardjo by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
167 NOTICE of Consent of Jo Belle Crain by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
168 NOTICE of Consent of Clifford Deal by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
169 NOTICE of Consent of Dan Dietz by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
170 NOTICE of Consent of John L. Eller by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
171 NOTICE of Consent of Jim Fagan by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
172 NOTICE of Consent of Harold Fesmire by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
173 NOTICE of Consent of John Gartin by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
174 NOTICE of Consent of Eleanor Jane Gorton by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
175 NOTICE of Notice of Rex Hull by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
176 NOTICE of Consent of Cheryl L. Hurst by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
177 NOTICE of Consent of Sally A. Juhn by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
178 NOTICE of Consent of Roger Lippold by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
179 NOTICE of Consent of Cathy McNally by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
180 NOTICE of Consent of Kenneth Meinhardt by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
181 NOTICE of Consent of Kathy J. Nicol by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
182 NOTICE of Consent of Robert Oakes by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
183 NOTICE of Consent of Gary Owens by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
184 NOTICE of Consent of Delores Packer by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
185 NOTICE of Consent of Barry Pascal by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
186 NOTICE of Consent of Roy Poe by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)

03/05/2004 03/05/2004 03/05/2004 03/11/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004

187 NOTICE of Consent of Melanie Richards by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
188 NOTICE of Consent of Norman R. Rutkowski by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
189 NOTICE of Consent of Linda Kaye Wissman by Shirley Williams (Dennis, Stephen) (Entered: 03/05/2004)
190 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Dienhart on March 15, 2004 (Braud, Bert) (Entered: 03/11/2004)
191 NOTICE of Consent of Joel R. Blumenthal by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
192 NOTICE of Consent of Cheryl Bolton by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
193 NOTICE of Consent of Alan Boyer by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
194 NOTICE of Consent of Sharon A. Brown by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
195 NOTICE of Consent of Mindy Ann Cleary by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
196 NOTICE of Consent of Darrell D. Denton by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
197 NOTICE of Consent of Thomas M. Digirlamo by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
198 NOTICE of Consent of Pamela A. Emler by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
199 NOTICE of Consent of Jeff D. Garland by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
200 NOTICE of Consent of Juanette Helms−Yates by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
201 NOTICE of Consent of Jerry L. Hipp by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
202 NOTICE of Consent of Robert D. James by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
203 NOTICE of Consent of Eugene R. Laessig by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
204 NOTICE of Consent of Lawrence M. Matt by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
205 NOTICE of Consent of Douglas D. Meng by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
206 NOTICE of Consent of Lenore Meng by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
207 NOTICE of Consent of Georgia L. Milliren by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
208 NOTICE of Consent of Rosemary Milton by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
209 NOTICE of Consent of Robert Nicol by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
210 NOTICE of Consent of Sandra Lynn Norwood−Brown by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)

03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/12/2004 03/16/2004
03/17/2004
03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004

211 NOTICE of Consent of Janet Lynn Poletis by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
212 NOTICE of Consent of Joseph A. Ritt by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
213 NOTICE of Consent of Katherine L. Roe by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
214 NOTICE of Consent of Roger L. Rucker by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
215 NOTICE of Consent of Nancy Tweedy by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
216 NOTICE of Consent of Donald C. Wright by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
217 NOTICE of Consent of Karen S. Staley by Shirley Williams (Dennis, Stephen) (Entered: 03/12/2004)
218 CERTIFICATE OF SERVICE by Shirley Williams of Dr. Jie Chen Expert Report. (Braud, Bert) (Entered: 03/12/2004)
219 CERTIFICATE OF SERVICE by Sprint/United Management Company Responses and Objections to Plaintiffs' 2nd Amended Notice Duces Tecum for Deposition of Designated Agent of Sprint regarding Unity II. (Hulla, Patrick) (Entered: 03/16/2004)
220 CERTIFICATE OF SERVICE by Sprint/United Management Company regarding Defendant's Responses and Objections to Plaintiffs' 2nd Amended Notice Duces Tecum for Defendant Sprint. (Hulla, Patrick) (Entered: 03/17/2004)
221 NOTICE of Consent of Kenneth Lloyd Ballew by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
222 NOTICE of Consent of Edward S. Blinco by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
223 NOTICE of Consent of Robert M. Boehm by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
224 NOTICE of Consent of Larry L. Brice by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
225 NOTICE of Consent of Mary Pat Cavanaugh by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
226 NOTICE of Consent of Kenneth E. Donnelly by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
227 NOTICE of Consent of Barbara R. Frans by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
228 NOTICE of Consent of Travis L. French by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
229 NOTICE of Consent of Jon D. Gallion by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
230 NOTICE of Consent of Rebecca Haaven by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
231 NOTICE of Consent of Ronald Haefner by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
232 NOTICE of Consent of David H. Haskins by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
233 NOTICE of Consent of Julia A. Hicks by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)

03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/19/2004 03/24/2004
03/26/2004
03/29/2004 04/06/2004 04/15/2004
04/16/2004

234 NOTICE of Consent of Bonnie L. Hoopes by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
235 NOTICE of Consent of John Eldon Hoopes by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
236 NOTICE of Consent of Rochelle D. Hughes−Walker by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
237 NOTICE of Consent of Wayne Kuzmich by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
238 NOTICE of Consent of Ralph J. Kwapiszeski by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
239 NOTICE of Consent of William R. Merchant by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
240 NOTICE of Consent of Suzanne C. North by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
241 NOTICE of Consent of Gerald F. Portillo by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
242 NOTICE of Consent of Kenneth Mark Prohoniak by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
243 NOTICE of Consent of Sharon K. Russo by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
244 NOTICE of Consent of Jeri Ann Swafford by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
245 NOTICE of Consent of Harold C. Taylor by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
246 NOTICE of Consent of Peggy Sturgess by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
247 NOTICE of Consent of Mary Jane Jackson by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
248 NOTICE of Consent of Robert D. McManus by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
249 NOTICE of Consent of Linda Gayle Westbrook by Shirley Williams (Dennis, Stephen) (Entered: 03/19/2004)
250 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Michael Dienhart on March 12, 2004 by Personal Service (Egan, Dennis) (Entered: 03/24/2004)
251 MOTION for Protective Order by Movant Right Management Consultants (Attachments: # 1 Exhibit A − List# 2 Exhibit B − Protective Order)(Durbin, James) (Entered: 03/26/2004)
252 PROTECTIVE ORDER granting 251 Motion for Protective Order . Signed by Judge John W. Lungstrum on 03/29/2004. (ses) (Entered: 03/29/2004)
253 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jie Chen, Ph.D. on April 9, 2004 (Yates, John) (Entered: 04/06/2004)
Minute Entry for proceedings held before Judge John W. Lungstrum : Telephone Conference held on 4/15/2004. Plaintiffs shall file their motion to certify this case as a collective action under seal. (Court Reporter Becky Ryder.)(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 04/19/2004)
254 MOTION to Amend Complaint re 1 Complaint by Plaintiff Shirley Williams (Attachments: # 1)(Egan, Dennis) (Entered: 04/16/2004)

04/16/2004 04/19/2004 04/19/2004 04/19/2004 04/19/2004 04/19/2004
04/19/2004 04/21/2004 05/03/2004 05/07/2004 05/12/2004 05/14/2004 05/19/2004 05/19/2004 05/19/2004 05/19/2004

255 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiff's Initial Voluntary Rule 26 Disclosures. (Egan, Dennis) (Entered: 04/16/2004)
256 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED MOTION for Provisonal Certification to Proceed as an ADEA Collective Action, and to Send Notice by Plaintiff Shirley Williams.(mg) (Document(s) added on 7/8/2004. (mg)) (Entered: 04/20/2004)
257 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED MEMORANDUM(SUGGESTIONS) IN SUPPORT of 256 MOTION for Provisonal Certification, and to Send Notice by Plaintiff Shirley Williams. (mg) (Document added on 7/8/2004. (mg)) (Entered: 04/20/2004)
258 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED STATEMENT of Common Facts Supporting 256 MOTION for Provisonal Certification and Notice by Plaintiff Shirley Williams. (mg) (Document added on 7/8/2004. (mg)) (Entered: 04/20/2004)
259 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED AFFIDAVITS regarding 256 MOTION for Provisional Certification to Proceed as an ADEA Collective Action, and to Send Notice by Plaintiff Shirley Williams.(mg) (Documents added on 7/9/2004. (mg)) (Entered: 04/20/2004)
260 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED DEPOSITION EXHIBITS IN SUPPORT of 256 MOTION for Provisional Certification to Proceed as an ADEA Collective Action, and to Send Notice by Plaintiff Shirley Williams. (mg) Modified on 4/20/2004 to correct text. (mg)) (Documents added on 7/9/2004. (mg)) (Entered: 04/20/2004)
261 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED DEPOSITION EXCERPTS IN SUPPORT of 256 MOTION for Provisional Certification to Proceed as an ADEA Collective Action, and to Send Notice by Plaintiff Shirley Williams. (mg) (Documents added on 7/20/2004. (mg)) (Entered: 04/20/2004)
262 MOTION to Unseal Document (Recent Court Filings) and Memorandum in Support by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 04/21/2004)
263 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 262 MOTION to Unseal Document (Recent Court Filings) and Memorandum in Support (Hulla, Patrick) (Entered: 05/03/2004)
264 REPLY to Response to Motion by Plaintiff Shirley Williams re: 262 MOTION to Unseal Document (Recent Court Filings) and Memorandum in Support (mm) (Entered: 05/07/2004)
265 MOTION to Strike Affidavit of Sharon Louk and Memorandum in Support by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Hulla, Patrick) (Entered: 05/12/2004)
266 ORDER amending 34 First Phase Scheduling Order. The defendant shall have until 5/19/2004 to file a response to plaintiff's motion to certify and the plaintiffs shall have until 6/18/2004 to reply. Signed by Judge John W. Lungstrum on 05/14/2004. (ses) (Entered: 05/14/2004)
267 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/19/2004)
268 SEALED MOTION for Partial Summary Judgment by Defendant Sprint/United Management Company. (mg) (hw). (Entered: 05/21/2004)
269 SEALED MEMORANDUM IN SUPPORT of 268 SEALED MOTION for Partial Summary Judgment by Defendant Sprint/United Management Company. (mg) (hw). (Entered: 05/21/2004)
270 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED MEMORANDUM in Support of Its Opposition by Defendant Sprint/United Management Company regarding 256 SEALED MOTION for Conditional Certification.(mg) (Documents added on 8/2/2004. (mg)) (Entered: 05/21/2004)

05/19/2004 05/19/2004 05/19/2004 05/19/2004 05/26/2004 05/28/2004 05/28/2004 06/03/2004 06/04/2004
06/04/2004 06/04/2004 06/16/2004 06/16/2004 06/21/2004 07/02/2004

271 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED COMBINED STATEMENT OF UNCONTROVTERED FACTS by Defendant Sprint/United Management Company. (mg) (Document added on 8/2/2004. (mg)) (Entered: 05/21/2004)
272 SEALED EXHIBITS to 271 Sealed Combined Statement of Uncontroverted Facts by Defendant Sprint/United Management Company. (mg) (hw). (Entered: 05/21/2004)
273 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED DEPOSITIONS to 271 Sealed Combined Statement of Uncontroverted Facts by Defendant Sprint/United Management Company. (mg) (Documents added on 8/2/2004. (mg)) (Entered: 05/21/2004)
274 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED DECLARATIONS AND AFFIDAVITS to 271 Sealed Combined Statement of Uncontroverted Facts by Sprint/United Management Company. (mg) (Documents added on 8/2/2004. (mg)) (Entered: 05/21/2004)
275 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 265 MOTION to Strike Affidavit of Sharon Louk and Memorandum in Support (Dennis, Stephen) (Entered: 05/26/2004)
276 REPLY to plaintiff's memorandum in Opposition to Motion by Defendant Sprint/United Management Company re: 265 MOTION to Strike Affidavit of Sharon Louk and Memorandum in Support (mm, ) (Entered: 05/28/2004)
277 MOTION to Strike defendant's 268 MOTION for Partial Summary Judgment on the issue of pattern and practice by Plaintiff Shirley Williams (mm) (Entered: 06/01/2004)
278 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 277 MOTION to Strike 268 MOTION for Partial Summary Judgment on the Issue of Pattern and Practice (Yates, John) (Entered: 06/03/2004)
279 NOTICE of Telephone Conference regarding 277 MOTION to Strike and 268 MOTION for Partial Summary Judgment: Motion Hearing (Telephone conference) set for 6/4/2004 at 03:00 PM before Chief Judge John W. Lungstrum. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Modified on 6/7/2004 to reflect this is a text entry only. (mg)) (Entered: 06/04/2004)
280 ORDER denying without prejudice the 268 Motion for Partial Summary Judgment, and denying 277 Motion to Strike . Signed by Judge John W. Lungstrum on 06/04/2004. (ses) (Entered: 06/04/2004)
281 Minute Entry for proceedings held before Judge John W. Lungstrum : Telephone Conference held on 6/4/2004 (Court Reporter Becky Ryder.)(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 06/04/2004)
282 MOTION for extension of time of One Day to File Plaintiffs' Reply Brief, pursuant to Court's Order of May 14, 2004 (Doc. 266) by Plaintiff Shirley Williams (Braud, Bert) (Entered: 06/16/2004)
283 ORDER granting 282 Motion for Extension of Time to File reply brief. Reply deadline extended to 06/21/2004. Signed by Judge John W. Lungstrum on 06/16/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 06/16/2004)
284 (UNSEALED ON 07/02/04. SEE DOCUMENT #287.) SEALED REPLY to Response to Motion by Plaintiff Shirley Williams regarding 256 SEALED MOTION for Provisional Certification.(mg) (Document added on 8/2/2004. (mg)) (Entered: 06/22/2004)
285 MEMORANDUM AND ORDER granting 254 Motion to Amend Complaint. Counsel directed to file amended complaint within 10 days., granting 256 Motion for for provisional certification, to join additional plaintiffs and to send notice, granting 262 Motion to Unseal Document, denying 265 Motion to Strike the affidavit of Sharon Louk. The court schedules a telephone conference for Thursday, July 8, 2004 at 3:00 p.m. The parties are to submit no later than 10 days for the date of this order a

07/02/2004 07/02/2004
07/07/2004 07/08/2004 07/15/2004 07/19/2004 07/19/2004
07/20/2004 07/20/2004 07/21/2004 07/22/2004 07/22/2004 07/22/2004 07/22/2004

stipulated case management schedule or respective motions for entry of their own proposed scheduling order. Signed by Judge John W. Lungstrum on 07/02/2004. (ses) (Entered: 07/02/2004)
286 AMENDED COMPLAINT against Sprint/United Management Company, filed by Shirley Williams.(Egan, Dennis) (Entered: 07/02/2004)
287 ORDER unsealing the following documents: 256 MOTION for Order filed by Shirley Williams, 257 Memorandum in Support of Motion filed by Shirley Williams, 258 Statement filed by Shirley Williams, 259 Affidavit in Support of Motion filed by Shirley Williams, 260 Exhibits in Support of Motion filed by Shirley Williams, 270 Memorandum in Opposition to Motion filed by Sprint/United Management Company, 271 Statement filed by Sprint/United Management Company, 272 Supplement filed by Sprint/United Management Company, 284 Reply to Response to Motion filed by Shirley Williams, 261 Exhibits in Support of Motion filed by Shirley Williams, 273 Supplement filed by Sprint/United Management Company, 274 Affidavit filed by Sprint/United Management Company. Counsel shall submit all above listed documents in pdf format to the Clerk of the Court no later than 07/07/2004.. Signed by Judge John W. Lungstrum on 07/02/2004. (ses) (Entered: 07/02/2004)
288 RESPONSE Memorandum Regarding Form of Notice by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit 1)(Yates, John) (Entered: 07/07/2004)
289 Minute Entry for proceedings held before Judge John W. Lungstrum : Telephone Status Conference held on 7/8/2004 (Court Reporter Becky Ryder.)(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 07/08/2004)
290 ANSWER to Amended Complaint by Sprint/United Management Company.(Hulla, Patrick) (Entered: 07/15/2004)
291 Minute Entry for proceedings held before Judge John W. Lungstrum : Status Conference held on 7/19/2004 (Court Reporter Becky Ryder.) (ses) (Entered: 07/20/2004)
292 ORDER re 291 Minute Entry of Status Conference − This case is consolidated with the following cases for the limited purpose of coordination of discovery:04−02273, Cocherl v. Sprint/United Management Company; 04−2238, Selberg v. Sprint/United Management Company; 04−2008, Borel v. Sprint/United Management Company; 03−2384, Wood v. Sprint/United Management Company; and 04−2003 Miller v. Sprint/United Management Company. Signed by Judge John W. Lungstrum on 07/19/2004. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Entered: 07/20/2004)
293 MOTION for attorney Andrew Haynes McCue to appear pro hac vice by Plaintiff Shirley Williams (Meyers, Martin) (Entered: 07/20/2004)
294 AFFIDAVIT of Andrew Haynes McCue re 293 MOTION for attorney Andrew Haynes McCue to appear pro hac vice by Plaintiff Shirley Williams (Meyers, Martin) (Entered: 07/20/2004)
PRO HAC VICE FEE PAID: on 7/20/04 re: 293 MOTION for attorney Andrew Haynes McCue to appear pro hac vice in the amount of $50.00; Receipt Number 104256. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (trs) (Entered: 07/21/2004)
295 CERTIFICATE OF SERVICE by Sprint/United Management Company re 288 Response Amended Certficate of Service. (Yates, John) (Entered: 07/22/2004)
296 MOTION for attorney Daniel B. Kohrman to appear pro hac vice by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 07/22/2004)
297 MOTION for attorney Thomas W. Osborne to appear pro hac vice by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 07/22/2004)
298 MOTION for attorney Laurie A. McCann to appear pro hac vice by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 07/22/2004)

07/22/2004
07/22/2004
07/23/2004
07/23/2004 07/23/2004 07/23/2004 07/23/2004 07/23/2004 07/23/2004 07/23/2004 07/23/2004 07/26/2004
07/26/2004
07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004

PRO HAC VICE FEE PAID: on 7/23/04 re: 298 MOTION for attorney Laurie A. McCann to appear pro hac vice in the amount of $50.00; Receipt Number 104298 (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (trs) (Entered: 07/23/2004)
PRO HAC VICE FEE PAID: on 7/23/04 re: 297 MOTION for attorney Thomas W. Osborne to appear pro hac vice in the amount of $50.00; Receipt Number 104297 (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (trs) (Entered: 07/23/2004)
PRO HAC VICE FEE PAID: on 7/23/04 re: 296 MOTION for attorney Daniel B. Kohrman to appear pro hac vice in the amount of $50.00; Receipt Number 104296 (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (trs) (Entered: 07/23/2004)
299 NOTICE of Consent of Gerold L. Blake by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
300 NOTICE of Consent of Barbara J. Combs by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
301 NOTICE of Consent of Brenda H. Coverdell by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
302 NOTICE of Consent of Kenneth R. Darling by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
303 NOTICE of Consent of Patricia A. Meunier−Muenks by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
304 NOTICE of Consent of Judith V. Shaw by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
305 NOTICE of Consent of Billy Shiplet by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
306 NOTICE of Consent of Kim M. Siewert by Shirley Williams (Dennis, Stephen) (Entered: 07/23/2004)
307 (THIS ORDER HAS BEEN VACATED. See text entry #2673.) SECOND PHASE SCHEDULING ORDER (SEE ORDER FOR DETAILS). Signed by Judge John W. Lungstrum on 07/26/2004. (ses) (Modified on 12/27/2004 to reflect this order is vacated. (mg) (Entered: 07/26/2004)
308 ORDER granting 293 Motion to Appear Pro Hac Vice Andrew H. McCue for Shirley Williams,, granting 296 Motion to Appear Pro Hac Vice Daniel B. Kohrman for Shirley Williams, granting 297 Motion to Appear Pro Hac Vice Thomas W. Osborne for Shirley Williams and granting 298 Motion to Appear Pro Hac Vice Laurie A. McCann for Shirley Williams . Signed by Judge John W. Lungstrum on 07/26/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 07/26/2004)
309 NOTICE of Consent of Paula M. Barree by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
310 NOTICE of Consent of Nancy L. Dalton by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
311 NOTICE of Consent of Carol Lynn Farrow by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
312 NOTICE of Consent of Jon Marc George by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
313 NOTICE of Consent of Linda G. Havens by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
314 NOTICE of Consent of Sherri B. Herren by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)

07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 07/30/2004 08/02/2004
08/03/2004
08/03/2004
08/06/2004 08/06/2004 08/06/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004

315 NOTICE of Consent of Werner R. Kalytka by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
316 NOTICE of Consent of Carol L. Kippes by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
317 NOTICE of Consent of Theresa A. Larson by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
318 NOTICE of Consent of David C. Molz by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
319 NOTICE of Consent of Lisa A. Morehart by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
320 NOTICE of Consent of Bobbie D. Perry by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
321 NOTICE of Consent of Monica R. Pfister by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
322 NOTICE of Consent of Robin R. Smith by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
323 NOTICE of Consent of Jeffrey L. Starbuck by Shirley Williams (Dennis, Stephen) (Entered: 07/30/2004)
324 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Fifth Interrogatories, and Plaintiffs' Sixth Request for Production of Documents. (Egan, Dennis) (Entered: 08/02/2004)
325 CERTIFICATE OF SERVICE by Sprint/United Management Company of Defendant's First Request for Production of Documents to 17 Opt−in Plaintiffs. (Hulla, Patrick) (Entered: 08/03/2004)
326 CERTIFICATE OF SERVICE by Sprint/United Management Company of Defendant's First Request for Production of Documents, First Interrogatories and First Request for Admissions to Plaintiff Shirley Williams. (Hulla, Patrick) (Entered: 08/03/2004)
327 NOTICE of Consent of Roosevelt J. Draine by Shirley Williams (Dennis, Stephen) (Entered: 08/06/2004)
328 NOTICE of Consent of Daniel R. Honeycutt by Shirley Williams (Dennis, Stephen) (Entered: 08/06/2004)
329 NOTICE of Consent of Shirley J. Myers by Shirley Williams (Dennis, Stephen) (Entered: 08/06/2004)
330 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 08/13/2004)
331 NOTICE of Consent of Gregory W. Alewel by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
332 NOTICE of Consent of Catherine F. Bartholow by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
333 NOTICE of Consent of Gordon Dean Brown by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
334 NOTICE of Consent of David A. Carmel by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
335 NOTICE of Consent of Dale Aaron Dupuis by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
336 NOTICE of Consent of Linda Ford by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)

08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/13/2004 08/18/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004

337 NOTICE of Consent of Terry L. Hibben by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
338 NOTICE of Consent of Susan Lin by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
339 NOTICE of Consent of Brenda M. Long by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
340 NOTICE of Consent of Alan D. Rock by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
341 NOTICE of Consent of Gerry Scott by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
342 NOTICE of Consent of Denisa Smith by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
343 NOTICE of Consent of Steven R. Smith by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
344 NOTICE of Consent of John A. Stinehour by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
345 NOTICE of Consent of Ralph James Sweatte by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
346 NOTICE of Consent of Benjamin F. Tate by Shirley Williams (Dennis, Stephen) (Entered: 08/13/2004)
347 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 08/18/2004)
348 NOTICE of Consent of Miguel Arredondo, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
349 NOTICE of Consent of Michael A. Broccoli by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
350 NOTICE of Consent of Peggy Virginia Broughton by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
351 NOTICE of Consent of Margret L. Bruckner Adams by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
352 NOTICE of Consent of John W. Curry by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
353 NOTICE of r Arnita L. Davis−Colter by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
354 NOTICE of Consent of Eldon J. Elliott by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
355 NOTICE of Consent of Alvin Enoch by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
356 NOTICE of Consent of Edward B. Flournoy by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
357 NOTICE of Consent of Joseph Domenic Gallo by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
358 NOTICE of Consent of Theresa Leona Goodson by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
359 NOTICE of Consent of Sonia A. Graddick by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
360 NOTICE of Consent of Hillard Hart by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)

08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/20/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004

361 NOTICE of Consent of Maxine E. Jordan by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
362 NOTICE of Consent of Delbert H. Kelley by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
363 NOTICE of Consent of Thomas Lauro by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
364 NOTICE of Consent of Jack E. McElroy by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
365 NOTICE of Consent of Brenda Joyce Miller by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
366 NOTICE of Consent of Marsha Lynn Moody by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
367 NOTICE of Consent of Linda B. Newcomer by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
368 NOTICE of Consent of Alan Otto by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
369 NOTICE of Consent of Carol L. Rollins by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
370 NOTICE of Consent of Stephen C. Rood by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
371 NOTICE of Consent of Kathleen R. Ruis by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
372 NOTICE of Consent of Willie G. Small by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
373 NOTICE of Consent of Robert J. Stine by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
374 NOTICE of Consent of Robert A. Valentine by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
375 NOTICE of Consent of Patricia A. Whitaker by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
376 NOTICE of Consent of Cinda Marie Wittman by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
377 NOTICE of Consent of Yvonne Arlene Wood−Olson by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
378 NOTICE of Consent of Leonard C. Zody by Shirley Williams (Dennis, Stephen) (Entered: 08/20/2004)
379 NOTICE of Consent of Rodney E. Abel by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
380 NOTICE of Consent of Michael D. Albers by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
381 NOTICE of Consent of Lois Eileen Anderson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
382 NOTICE of Consent of Sharon Lee Asciutto by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
383 NOTICE of Consent of Cortez C. Aylor, III by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
384 NOTICE of Consent of Bobby Joe Bailey by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)

08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004

385 NOTICE of Consent of Beverly Banks by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
386 NOTICE of Consent of Michael R. Barbour by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
387 NOTICE of Consent of Joseph E. Baughman by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
388 NOTICE of Consent of Fred Benjamin by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
389 NOTICE of Consent of Gloria Jean Britt by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
390 NOTICE of Consent of Richard Brumbaugh by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
391 NOTICE of Consent of Peter Inglis Buchan by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
392 NOTICE of Consent of Bobby N. Burch by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
393 NOTICE of Consent of Loring Bush by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
394 NOTICE of Consent of Valerie Jean Byrd by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
395 NOTICE of Consent of Kimberly Yvonne Carlson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
396 NOTICE of Consent of Jerry B. Carnes by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
397 NOTICE of Consent of Rafael Carrizales−Yerena by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
398 NOTICE of Consent of Rebecca V. Castro by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
399 NOTICE of Consent of Mary F. Christiansen by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
400 NOTICE of Consent of Don Cobb by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
401 NOTICE of Consent of Miguel Codina by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
402 NOTICE of Consent of Evelyn Conner by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
403 NOTICE of Consent of Elois Brooks Cotton by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
404 NOTICE of Consent of David Otto Daugherty by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
405 NOTICE of Consent of Cheryl Davis by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
406 NOTICE of Consent of Leroy Davis by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
407 NOTICE of Consent of Charlie Dominguez by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
408 NOTICE of Consent of Mike Dougherty by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)

08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004

409 NOTICE of Consent of Josie L. Doyle by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
410 NOTICE of Consent of Willie L. Ellison by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
411 NOTICE of Consent of Jerald D. Epstein by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
412 NOTICE of Consent of Kevin W. Flanagan by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
413 NOTICE of Consent of Carolyn J. Gates by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
414 NOTICE of Consent of Gary L. Graber by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
415 NOTICE of Consent of James E. Hamilton by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
416 NOTICE of Consent of Charles O. Hammond by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
417 NOTICE of Consent of Theodore Thomas Herring by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
418 NOTICE of Consent of Deborah J. Hingston by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
419 NOTICE of Consent of Raymond C. Holk by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
420 NOTICE of Consent of Linda Hosack by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
421 NOTICE of Consent of J. Roger Hunt by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
422 NOTICE of Consent of Richard A. Izzo by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
423 NOTICE of Consent of Kalyan Jana by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
424 NOTICE of Consent of David W. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
425 NOTICE of Consent of Stanley N. Jones by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
426 NOTICE of Consent of Willie U. Jones by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
427 NOTICE of Consent of Stanley Kim by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
428 NOTICE of Consent of Mary Kimbrough by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
429 NOTICE of Consent of Wallen Ugene Klann by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
430 NOTICE of Consent of David R. Klingler by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
431 NOTICE of Consent of Nolan R. Krueger by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
432 NOTICE of Consent of Philip Leanza by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)

08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004

433 NOTICE of Consent of Michael F. Lense by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
434 NOTICE of Consent of Lee R. Lewis by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
435 NOTICE of Consent of John Littler by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
436 NOTICE of Consent of Charles I. Mandrell by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
437 NOTICE of Consent of Dianne Maxwell Lambert by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
438 NOTICE of Consent of Jerry C. McKee by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
439 NOTICE of Consent of Rasendra G. Mehta by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
440 NOTICE of Consent of Dwala K. Miles by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
441 NOTICE of Consent of Sharon S. Miller by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
442 NOTICE of Consent of William H. Morris by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
443 NOTICE of Consent of Lana L. Nevils by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
444 NOTICE of Consent of Jerald Vernon Nevonen by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
445 NOTICE of Consent of Mike John O'Brien by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
446 NOTICE of Consent of William M. O'Loughlin by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
447 NOTICE of Consent of Mary A. Parks by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
448 NOTICE of Consent of Joyce E. Parsons by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
449 NOTICE of Consent of Erik D. Pedersen by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
450 NOTICE of Consent of John Wesley Persaud by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
451 NOTICE of Consent of Antoinette M. Phillips by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
452 NOTICE of Consent of Gil Pierson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
453 NOTICE of Consent of Roberta S. Pietrzak by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
454 NOTICE of Consent of Suzanne T. Reed by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
455 NOTICE of Consent of Kenneth L. Rhudy by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
456 NOTICE of Consent of Jean Robinson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)

08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 08/27/2004 09/01/2004 09/01/2004

457 NOTICE of Consent of Walter Edward Robinson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
458 NOTICE of Consent of Luis Angel Roman by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
459 NOTICE of Consent of William A. Rosenberg by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
460 NOTICE of Consent of Thomas MacRae Ryan by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
461 NOTICE of Consent of Sandra S. Scott by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
462 NOTICE of Consent of Kim Marie Soeder by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
463 NOTICE of Consent of Robert G. Spann by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
464 NOTICE of Consent of Linda M. Spencer by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
465 NOTICE of Consent of Thadeusz Stachow by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
466 NOTICE of Consent of Fernando Viera by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
467 NOTICE of Consent of Laurie A. Viles by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
468 NOTICE of Consent of William C. Wakeman by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
469 NOTICE of Consent of Ralph W. Wasko by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
470 NOTICE of Consent of Charles Watson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
471 NOTICE of Consent of Darrell R. Webster by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
472 NOTICE of Consent of Janice Sue Wheeler by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
473 NOTICE of Consent of Brenda J. Wilson by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
474 NOTICE of Consent of George K.B. Winful by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
475 NOTICE of Consent of Sheila Badu Winful by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
476 NOTICE of Consent of Joe Lewis Wright by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
477 NOTICE of Consent of Michele G. Wursta by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
478 NOTICE of Consent of Andrzej H. Zurniewicz by Shirley Williams (Dennis, Stephen) (Entered: 08/27/2004)
479 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 09/01/2004)
480 CERTIFICATE OF SERVICE by Alan Boyer, Kenneth E. Donnelly, John L. Eller, Jim Fagan, Barbara R. Frans, Thomas M. Gerrity, Les Goodwin, Bonnie L. Hoopes,

09/01/2004 09/02/2004
09/02/2004
09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004

Wayne Kuzmich, Ralph J. Kwapiszeski, Robert D. McManus, Cathy McNally, Michael McVicker, William E. Pitts, Kenneth Mark Prohoniak, Robert O. Smith, Karen S. Staley, Shirley Williams (Dennis, Stephen) (Entered: 09/01/2004)
481 Unopposed MOTION for extension of time by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 09/01/2004)
482 ORDER granting 481 Motion for Extension of Time to File . Signed by Judge John W. Lungstrum on 09/02/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 09/02/2004)
483 ORDER REFERRING CASE to Magistrate Judge David J. Waxse for pretrial proceedings. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Entered: 09/02/2004)
484 NOTICE of Consent of Keith R. Allen by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
485 NOTICE of Consent of Charles E. Appleby by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
486 NOTICE of Consent of Christi Sue Austin by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
487 NOTICE of Consent of Maury Bimberg by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
488 NOTICE of Consent of Leonard Birney by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
489 NOTICE of Consent of Thomas Carmalt Blow, II by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
490 NOTICE of Consent of Gwendolyn Bridges by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
491 NOTICE of Consent of Maurice William Castellon by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
492 NOTICE of Consent of Toni Chang by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
493 NOTICE of Consent of Lana Sue Coleman by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
494 NOTICE of Consent of Edgar L. Cox by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
495 NOTICE of Consent of Kathe Leann Cronin by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
496 NOTICE of Consent of James P. De−La−Roche by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
497 NOTICE of Consent of Jesse R. Diaz by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
498 NOTICE of Consent of David K. Dober by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
499 NOTICE of Consent of Carole L. Enyings by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
500 NOTICE of Consent of Elizabeth Evans by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
501 NOTICE of Consent of Rebecca G. Ferrell by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)

09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004

502 NOTICE of Consent of Edmund Brian Fick by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
503 NOTICE of Consent of Everlee J. Flanigan by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
504 NOTICE of Consent of John James Fleming by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
505 NOTICE of Consent of Paula L. Fonzo by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
506 NOTICE of Consent of Robert Fowler by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
507 NOTICE of Consent of Donald D. Franklin by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
508 NOTICE of Consent of Nancy Fretwell by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
509 NOTICE of Consent of Kathleen S. Fulton by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
510 NOTICE of Consent of Mary L. Gaston−Davis by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
511 NOTICE of Consent of Deborah Gibson by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
512 NOTICE of Consent of Earlene Gillespie by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
513 NOTICE of Consent of Glenn Golden by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
514 NOTICE of Consent of Russell D.T. Gorrell, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
515 NOTICE of Consent of Walter C. Gross, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
516 NOTICE of Consent of Richard Guth by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
517 NOTICE of Consent of Ronald J. Guzell by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
518 NOTICE of Consent of Richard D. Harper by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
519 NOTICE of Consent of Jane Pleasants Hathaway by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
520 NOTICE of Consent of Gloria D. Hevener by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
521 NOTICE of Consent of Garry Wayne Hicks by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
522 NOTICE of Consent of Stephen Homan by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
523 NOTICE of Consent of Ralph F. Horne by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
524 NOTICE of Consent of Linda J. Horton by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
525 NOTICE of Consent of Gene R. Huffman by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)

09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004

526 NOTICE of Consent of Inez E. Jenkins by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
527 NOTICE of Consent of Veletta Johnson by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
528 NOTICE of Consent of Virginia L. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
529 NOTICE of Consent of Roger S. Kelly by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
530 NOTICE of Consent of Suzanne C. Kilpatrick by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
531 NOTICE of Consent of Rosemary Kocher by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
532 NOTICE of Consent of Barbara Ann Kuklenski by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
533 NOTICE of Consent of Christina Y. Lane by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
534 NOTICE of Consent of Adrienne E. Lanigan by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
535 NOTICE of Consent of Paul J. LeMay by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
536 NOTICE of Consent of Norman Londot by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
537 NOTICE of Consent of Aaron Lott, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
538 NOTICE of Consent of Ronald Matz by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
539 NOTICE of Consent of Diana L. McNabney by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
540 NOTICE of Consent of Denise Ann Moles by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
541 NOTICE of Consent of Denise Ann Moles by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
542 NOTICE of Consent of Rafael A. Molina by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
543 NOTICE of Consent of Deborah P. Morton by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
544 NOTICE of Consent of Terri Murray by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
545 NOTICE of Consent of Adrian J. O'Boyle by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
546 NOTICE of Consent of Rose F. Parker by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
547 NOTICE of Consent of Mark Daniel Provost by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
548 NOTICE of Consent of Thomas H. Rasco by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
549 NOTICE of Consent of Steven M. Rich by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)

09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004 09/03/2004

550 NOTICE of Consent of Robert S. Robinson by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
551 NOTICE of Consent of Robert Louis Rumel by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
552 NOTICE of Consent of Betty E. Ryder by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
553 NOTICE of Consent of Gary W. Schafer by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
554 NOTICE of Consent of Gary L. Scott by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
555 NOTICE of Consent of Gladys J. Searcy by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
556 NOTICE of Consent of Colleen Shockey by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
557 NOTICE of Consent of Douglas Wayne Simerly by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
558 NOTICE of Consent of James L. Smith by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
559 NOTICE of Consent of Julie Louise Smith by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
560 NOTICE of Consent of Walter Stanton by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
561 NOTICE of Consent of Jeffrey Strogin by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
562 NOTICE of Consent of Michael S. Swaim by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
563 NOTICE of Consent of William F. Tarr by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
564 NOTICE of Consent of John J. Thomas, IV by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
565 NOTICE of Consent of Terry R. Thomas by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
566 NOTICE of Consent of Vella M. Thomasson by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
567 NOTICE of Consent of Judith D. Tinnell by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
568 NOTICE of Consent of Richard Jeffrey Vogel by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
569 NOTICE of Consent of Michael E. Votypka by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
570 NOTICE of Consent of Rex Allen Webb by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
571 NOTICE of Consent of Robert L. Westphal by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
572 NOTICE of Consent of Julius Williams by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
573 NOTICE of Consent of Colleen J. Wirt by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)

09/03/2004 09/03/2004 09/03/2004 09/07/2004
09/07/2004
09/08/2004 09/09/2004
09/09/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004

574 NOTICE of Consent of Rocio Wright by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
575 NOTICE of Consent of Mark R. Yengle by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
576 NOTICE of Consent of Kathleen T. Young by Shirley Williams (Dennis, Stephen) (Entered: 09/03/2004)
577 CERTIFICATE OF SERVICE by Sprint/United Management Company Regarding Response to Plaintiffs' Sixth Request for Production of Documents. (Hulla, Patrick) (Entered: 09/07/2004)
578 CERTIFICATE OF SERVICE by Sprint/United Management Company Regarding Answers and Objections to Plaintiffs' Fifth Interrogatories to Defendant. (Hulla, Patrick) (Entered: 09/07/2004)
579 Second MOTION for extension of time to respond to discovery requests by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 09/08/2004)
580 ORDER SETTING STATUS CONFERENCE: Upon Plaintiffs' request, the Court hereby sets a status conference in this case on September 14, 2004 at 3:30 p.m. before Magistrate Judge David J. Waxse. The status conference will be held in Courtroom 223. Entered by Magistrate Judge David J. Waxse on 9/9/2004. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 09/09/2004)
581 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 09/09/2004)
582 NOTICE of Consent of Gloria Adamson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
583 NOTICE of Consent of Robert Hunter Anderson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
584 NOTICE of Consent of Russell Asato by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
585 NOTICE of Consent of Marsha Baldwin by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
586 NOTICE of Consent of Bonnie B. Balliet by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
587 NOTICE of Consent of William J. Beaver by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
588 NOTICE of Consent of Dinah L. Blackmon by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
589 NOTICE of Consent of Diane K. Bland by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
590 NOTICE of Consent of David H. Boyer by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
591 NOTICE of Consent of Robert Bruce Brower by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
592 NOTICE of Consent of Robert Earl Brown by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
593 NOTICE of Consent of Sheila Bruce by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
594 NOTICE of Consent of Steven Dale Colton by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
595 NOTICE of Consent of Debra Ann Cook by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)

09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004

596 NOTICE of Consent of Cynthia Gail Crews by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
597 NOTICE of Consent of Lennox K. Danielson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
598 NOTICE of Consent of Donald Richard Darden by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
599 NOTICE of Consent of James G. Davidson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
600 NOTICE of Consent of Anthony V. Dilluvio by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
601 NOTICE of Consent of Susan C. Doherty by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
602 NOTICE of Consent of Sandra J. Eastin by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
603 NOTICE of Consent of Brenda Edoukoun by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
604 NOTICE of Consent of Sandra Fay Tompkins Edwards by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
605 NOTICE of Consent of James Elder III by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
606 NOTICE of Consent of Mary F. Gilbert by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
607 NOTICE of Consent of Marijo Goetz by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
608 NOTICE of Consent of Glenda O. Hayes by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
609 NOTICE of Consent of Paul Hefley by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
610 NOTICE of Consent of Diane R. Helton by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
611 NOTICE of Consent of Kevin L. Henry by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
612 NOTICE of Consent of William Bradley Herring III by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
613 NOTICE of Consent of Dawn Johnson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
614 NOTICE of Consent of Marlene A. Karbula by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
615 NOTICE of Consent of Thomas L. Kulka by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
616 NOTICE of Consent of Anne W. Logue by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
617 NOTICE of Consent of Bradley C. Mayeux by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
618 NOTICE of Consent of Susan A. Melton by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
619 NOTICE of Consent of Carla Merlotti by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)

09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004 09/10/2004
09/10/2004
09/10/2004
09/13/2004
09/13/2004
09/14/2004

620 NOTICE of Consent of Carol Morahan by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
621 NOTICE of Consent of Michael Stephen Nabi by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
622 NOTICE of Consent of Richard Nelli by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
623 NOTICE of Consent of Randolph H. Phillips by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
624 NOTICE of Consent of John M. Schafer by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
625 NOTICE of Consent of John C. Scheele by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
626 NOTICE of Consent of Donald M. Shook by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
627 NOTICE of Consent of Sharon L. Shults by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
628 NOTICE of Consent of Reginald Simmons by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
629 NOTICE of Consent of Leslie Slow−Goldfine by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
630 NOTICE of Consent of Mark R. Smith by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
631 NOTICE of Consent of Michael David Tate by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
632 NOTICE of Consent of Howard L. Tiffany by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
633 NOTICE of Consent of Sandra L. Wardell by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
634 NOTICE of Consent of Wendell D. Wilson by Shirley Williams (Dennis, Stephen) (Entered: 09/10/2004)
635 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint on September, 2004 (Klamann, John) (Entered: 09/10/2004)
636 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re alpha training system on September 2004 (Klamann, John) (Entered: 09/10/2004)
637 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint regarding Towers Perrin, etc. on September 2004 (Klamann, John) (Entered: 09/10/2004)
638 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint regarding Bell Curve on September 2004 (Klamann, John) (Entered: 09/10/2004)
639 Pre−Conference Memorandum by Sprint/United Management Company. (Attachments: #(1) Exhibit A; #(2) Exhibit B; #(3) Exhibit C; #(4) Exhibit D; #(5) Exhibit E; #(6) Exhibit F)(Yates, John) (Modified on 9/14/2004 to amend document document title and to remove duplicate text. (mg)) (Entered: 09/13/2004)
640 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Responses to Defendant's Second Request for Production of Documents. (Egan, Dennis) (Entered: 09/13/2004)
641 Minute Entry for Status Conference held before Magistrate Judge David J. Waxse on 9/14/2004. Order to follow. (Tape #04−32 (2605−end); #04−33 (0−1073))(This is a

09/16/2004
09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004

TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(byk) (Entered: 09/14/2004)
642 ORDER finding as moot 579 Plaintiffs' Second Motion for Extension of Time to File. (See Order for further detail from Status Conference of 9/14/2004.) Signed by Magistrate Judge David J. Waxse on 9/16/2004.(jm) (Entered: 09/16/2004)
643 NOTICE of Consent of Larry W. Allen by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
644 NOTICE of Consent of Mamadou Badiane by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
645 NOTICE of Consent of Sherrie Bartlett by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
646 NOTICE of Consent of Edward Russell Birch by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
647 NOTICE of Consent of Julie Bowden by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
648 NOTICE of Consent of Roy Bradford by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
649 NOTICE of Consent of Marion Branch by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
650 NOTICE of Consent of Belinda A. Brown by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
651 NOTICE of Consent of Daniel R. Byrne by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
652 NOTICE of Consent of Patricia A. Cahoon by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
653 NOTICE of Consent of Joseph F. Carroll by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
654 NOTICE of Consent of LaVerne Clark by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
655 NOTICE of Consent of Gregory S. Collins by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
656 NOTICE of Consent of Michael Conradi by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
657 NOTICE of Consent of Francis J. Correll by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
658 NOTICE of Consent of Kenneth P. Cromley by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
659 NOTICE of Consent of Carl Fallik by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
660 NOTICE of Consent of David Hunter Fitzgerald by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
661 NOTICE of Consent of Michael J. Frost by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
662 NOTICE of Consent of Deborah Ann Gant by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
663 NOTICE of Consent of Robert Goodman by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)

09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004

664 NOTICE of Consent of Clel A. Hall by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
665 NOTICE of Notice of Emma J. Hancock by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
666 NOTICE of Consent of Gary R. Hanson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
667 NOTICE of Consent of M. Diane Hostetter by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
668 NOTICE of Consent of Kent Thomas Humphry by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
669 NOTICE of Consent of Bertie Lynette Justice by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
670 NOTICE of Consent of Inder Kainth by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
671 NOTICE of Consent of Dennis C. Klemp by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
672 NOTICE of Consent of Barbara J. Lamar by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
673 NOTICE of Consent of Debra A. Leeds by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
674 NOTICE of Consent of Kathy J. Lockaby by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
675 NOTICE of Consent of Kevin Marshall by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
676 NOTICE of Consent of Kathleen C. Martin by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
677 NOTICE of Consent of Yolanda Mathews by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
678 NOTICE of Consent of Gerard W. Mercuri by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
679 NOTICE of Consent of Connie M. Miller by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
680 NOTICE of Consent of Henry B. Miller by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
681 NOTICE of Consent of Karen K. Miller by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
682 NOTICE of Consent of Paul W. Myers by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
683 NOTICE of Consent of Gail N. Nishida by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
684 NOTICE of Consent of Michael J. Read by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
685 NOTICE of Consent of Cecile Grimwood Richardson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
686 NOTICE of Consent of Yvonne R. Richardson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
687 NOTICE of Consent of Myron J. Rittenhouse by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)

09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004

688 NOTICE of Consent of Jacob Rodriguez by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
689 NOTICE of Consent of William Rose by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
690 NOTICE of Consent of Elizabeth L. Roy by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
691 NOTICE of Consent of Steve Rubin by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
692 NOTICE of Consent of Regina D. Shadle by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
693 NOTICE of Consent of David Sharp by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
694 NOTICE of Consent of Paul Solomon by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
695 NOTICE of Consent of Mark S. Stone by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
696 NOTICE of Consent of Patrick H. Stritch by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
697 NOTICE of Consent of Donald A. Summers by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
698 NOTICE of Consent of Michelle L. Palmer Washington by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
699 NOTICE of Consent of Patricia Ann Webster by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
700 NOTICE of Consent of Lisa Marie White−Turney by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
701 NOTICE of Consent of Philip G. Williamson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
702 NOTICE of Consent of Cheryl Elliott Wilson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
703 NOTICE of Consent of Dennis Wilson by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
704 NOTICE of Consent of Yanwen Xia by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
705 NOTICE of Consent of Richard Zabic by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
706 NOTICE of Consent of Jerry Zolman by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
707 NOTICE of Consent of Michael E. Brief by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
708 NOTICE of Consent of Karen Anita Byrd by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
709 NOTICE of Consent of Gwendolyn J. Frison by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
710 NOTICE of Consent of Delaino L. Jones by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
711 NOTICE of Consent of Debra Susan Kramer by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)

09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/17/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/23/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004

712 NOTICE of Consent of Michael E. Potter by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
713 NOTICE of Consent of Aaron N. Shaddox by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
714 NOTICE of Consent of Lang H. Tran by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
715 NOTICE of Consent of Sandra M. Washington by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
716 NOTICE of Consent of Chris Willoughby by Shirley Williams (Dennis, Stephen) (Entered: 09/17/2004)
717 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dan Fenn on 9/24/04 (Yates, John) (Entered: 09/23/2004)
718 NOTICE by Defendant Sprint/United Management Company of taking deposition of Alan Boyer on October 14, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
719 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Donnelly on October 13, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
720 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Fagan on October 4, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
721 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Gerrity on October 7, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
722 NOTICE by Defendant Sprint/United Management Company of taking deposition of Wayne Kuzmich on September 29, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
723 NOTICE by Defendant Sprint/United Management Company of taking deposition of Catherine McNally on October 6, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
724 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Pitts on September 30, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
725 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth M. Prohoniak on October 12, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
726 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Smith on October 5, 2004 (Hulla, Patrick) (Entered: 09/23/2004)
727 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bonnie Hoopes on October 14, 2004 (Hulla, Patrick) (Entered: 09/24/2004)
728 NOTICE by Defendant Sprint/United Management Company of taking deposition of Barbara Frans on October 6, 2004 (Hulla, Patrick) (Entered: 09/24/2004)
729 NOTICE of Consent of Diana J. Anderson by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
730 NOTICE of Consent of Larry D. Auxier by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
731 NOTICE of Consent of Henry Ayer, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
732 NOTICE of Consent of Renee M. Balcom by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
733 NOTICE of Consent of Patricia A. Bicknell by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
734 NOTICE of Consent of Sandra Lynn Brown by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
735 NOTICE of Consent of Judith A. Buckner by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)

09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004

736 NOTICE of Consent of Betty P. Cabello by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
737 NOTICE of Consent of Sharon T. Carmody by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
738 NOTICE of Consent of Carmen M. Chandler by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
739 NOTICE of Consent of Rostine Coleman by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
740 NOTICE of Consent of Carlotta C. Craft by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
741 NOTICE of Consent of Charles David Curtis by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
742 NOTICE of Consent of Margaret DeGennaro by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
743 NOTICE of Consent of Robert D. Eicher by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
744 NOTICE of Consent of Charles W. Fisher by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
745 NOTICE of Consent of Delbert Harrison Flint by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
746 NOTICE of Consent of Marcus A. Fortier, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
747 NOTICE of Consent of Diane Geier by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
748 NOTICE of Consent of Charles B. George by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
749 NOTICE of Consent of Sharon J. Hindenach by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
750 NOTICE of Consent of Wendell A. Hines by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
751 NOTICE of Consent of Robert C. Huffer by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
752 NOTICE of Consent of Cheryl R. Jackson by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
753 NOTICE of Consent of Sheryl Yvonne Jones by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
754 NOTICE of Consent of John Karcher by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
755 NOTICE of Consent of Carol A. Kirk by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
756 NOTICE of Consent of Leslie H. Kreger by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
757 NOTICE of Consent of Frank J. Kulikowski by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
758 NOTICE of Consent of Kathleen D. McBride by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
759 NOTICE of Consent of Francis J. McDonough by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)

09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004

760 NOTICE of Consent of Janelle D. McMechan by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
761 NOTICE of Consent of Brian K. McNiff, Sr. by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
762 NOTICE of Consent of Marvin Mizrahi by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
763 NOTICE of Consent of Louis Isiah Moorman by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
764 NOTICE of Consent of Alberta M. Nichols by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
765 NOTICE of Consent of Teresa Lynn Nichols by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
766 NOTICE of Consent of Clara Perkins by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
767 NOTICE of Consent of Clifton Odell Pryor by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
768 NOTICE of Consent of Sandra K. Ridings by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
769 NOTICE of Consent of Kevin S. Rowan by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
770 NOTICE of Consent of Leonard J. Schiffer by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
771 NOTICE of Consent of Roger Allen Sherburne by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
772 NOTICE of Consent of Michael B. Smith by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
773 NOTICE of Consent of Valerie Smith by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
774 NOTICE of Consent of Susan Ann Snider by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
775 NOTICE of Consent of Michael J. Sumner by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
776 NOTICE of Consent of Denise M. Svacina by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
777 NOTICE of Consent of Thomas A. Taylor by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
778 NOTICE of Consent of Malcolm Tears by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
779 NOTICE of Consent of Veretta B. Thomas by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
780 NOTICE of Consent of Danny R. Van Voorhis by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
781 NOTICE of Consent of Kelvin Lynn Vineyard by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
782 NOTICE of Consent of J. Steven Whayne by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
783 NOTICE of Consent of Jeffrey Richard Whiteside by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)

09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/24/2004 09/28/2004
09/28/2004 09/28/2004 09/28/2004 09/28/2004 09/28/2004 09/28/2004 09/28/2004 09/29/2004 09/30/2004 09/30/2004
09/30/2004
09/30/2004 09/30/2004
10/01/2004 10/01/2004 10/01/2004

784 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Eller on October 22, 2004 (Hulla, Patrick) (Entered: 09/24/2004)
785 NOTICE of Consent of Joseph F. Williams by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
786 NOTICE of Consent of Thomas V. Woodall by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
787 NOTICE of Consent of Robert L. Yarmo by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
788 NOTICE of Consent of Lisa J. Zolman by Shirley Williams (Dennis, Stephen) (Entered: 09/24/2004)
789 NOTICE by All Plaintiffs of taking deposition of Sandy Price. (Klamann, John) (Modified on 10/21/2004 to remove the list of all plaintiffs' names. (mg)) (Entered: 09/28/2004)
790 NOTICE by Plaintiff Shirley Williams of taking deposition of Richard Dinkins (Klamann, John) (Entered: 09/28/2004)
791 NOTICE by Plaintiff Shirley Williams of taking deposition of Di Wuthnow (Klamann, John) (Entered: 09/28/2004)
792 NOTICE by Plaintiff Shirley Williams of taking deposition of Ken Koves (Klamann, John) (Entered: 09/28/2004)
793 NOTICE by Defendant Sprint/United Management Company of taking deposition of Shirley Williams on October 21, 2004 (Hulla, Patrick) (Entered: 09/28/2004)
794 NOTICE by Defendant Sprint/United Management Company of taking deposition of Terry Cocherl on October 20, 2004 (Hulla, Patrick) (Entered: 09/28/2004)
795 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Borel on October 19, 2004 (Hulla, Patrick) (Entered: 09/28/2004)
796 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael McVicker on October 19, 2004 (Hulla, Patrick) (Entered: 09/28/2004)
797 ENTRY OF APPEARANCE by Philip R. Dupont on behalf of Sprint/United Management Company (Dupont, Philip) (Entered: 09/29/2004)
798 MOTION for attorney Tamara M. Spicer to appear pro hac vice by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 09/30/2004)
799 AFFIDAVIT of Tamara M. Spicer re 798 MOTION for attorney Tamara M. Spicer to appear pro hac vice by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 09/30/2004)
800 AFIDAVIT in Support of Motion for attorney Harry B. Wilson, Jr. to appear pro hac vice by Defendant Sprint/United Management Company. (Hulla, Patrick) (Modified on 9/30/2004 to amend document title in docket text. This document has been correctly re−filed as document #802. (mg)) (Entered: 09/30/2004)
801 MOTION for attorney Harry B. Wilson, Jr. to appear pro hac vice by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 09/30/2004)
802 AFFIDAVIT of Harry B. Wilson, Jr. re 801 MOTION for attorney Harry B. Wilson, Jr. to appear pro hac vice by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 09/30/2004)
803 NOTICE by Defendant Sprint/United Management Company of taking deposition of Les Goodwin on October 13, 2004 (Hulla, Patrick) (Entered: 10/01/2004)
804 NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Staley on October 15, 2004 (Hulla, Patrick) (Entered: 10/01/2004)
805 NOTICE of Consent of Michael A. Affolder by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)

10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004

806 NOTICE of Consent of Edward J. Anstead by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
807 NOTICE of Consent of Janice L. Biehls by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
808 NOTICE of Consent of John H. Boldrey by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
809 NOTICE of Consent of Douglas Bolton by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
810 NOTICE of Consent of Joe Chan by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
811 NOTICE of Consent of Worth Joe Clark by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
812 NOTICE of Consent of Judith P. Cobb by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
813 NOTICE of Consent of Debra R. Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
814 NOTICE of Consent of Phyllis A. Drake by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
815 NOTICE of Consent of Jeffrey L. Dunbar by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
816 NOTICE of Consent of Matthew S. Dunn by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
817 NOTICE of Consent of Deborah A. Ehr by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
818 NOTICE of Consent of Thomas W. Falls by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
819 NOTICE of Consent of Peter B. Flum by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
820 NOTICE of Consent of Jakov Gavrushenko by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
821 NOTICE of Consent of David Golan by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
822 NOTICE of Consent of Marvin J. Gomez by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
823 NOTICE of Consent of Sheree L. Goodhart by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
824 NOTICE of Consent of Robert J. Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
825 NOTICE of Consent of Ruby J. Harvey−Burgin by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
826 NOTICE of Consent of John Fred Hopson by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
827 NOTICE of Consent of Carolyn J. Horner by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
828 NOTICE of Consent of Earl Hughes by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
829 NOTICE of Consent of Larry G. James by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)

10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004

830 NOTICE of Consent of Joseph Jerrick by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
831 NOTICE of Consent of Bonnie Lee Kennon by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
832 NOTICE of Consent of John F. Kenny by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
833 NOTICE of Consent of Kermie Carroll Lackey by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
834 NOTICE of Consent of Sally Leon−Guerrero by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
835 NOTICE of Consent of Judith R. Limbach by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
836 NOTICE of Consent of Lorraine M. Martin by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
837 NOTICE of Consent of Sharon E. McCarty by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
838 NOTICE of Consent of Jacquie K. Mitchell by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
839 NOTICE of Consent of Phyllis Marie Moore by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
840 NOTICE of Consent of Ralph Moore by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
841 NOTICE of Consent of Robert E. Moore by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
842 NOTICE of Consent of Rebecca Neff by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
843 NOTICE of Consent of Jose R. Nieves by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
844 NOTICE of Consent of Donna B. Noble by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
845 NOTICE of Consent of Brian J. O'Connor by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
846 NOTICE of Consent of Linda E. Palacios−Ramirez by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
847 NOTICE of Consent of Rebecca Ann Perry by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
848 NOTICE of Consent of Arnie Phillips by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
849 NOTICE of Consent of Chaitram Raghu by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
850 NOTICE of Consent of Pamela J. Raines by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
851 NOTICE of Consent of Louis G. Rocha by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
852 NOTICE of Consent of Randall C. Schulenberg by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
853 NOTICE of Consent of Joseph Sciulli by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)

10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004 10/01/2004
10/01/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004

854 NOTICE of Consent of Shirley Sebeniecher by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
855 NOTICE of Consent of David T. Settles by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
856 NOTICE of Consent of Shiverla K. Shannon by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
857 NOTICE of Consent of Jane O'Neal Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
858 NOTICE of Consent of Patricia Szekely by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
859 NOTICE of Consent of Jennifer Lee Titus by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
860 NOTICE of Consent of Curtis M. Tostie by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
861 NOTICE of Consent of Nikimi D. Ward by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
862 NOTICE of Consent of Jimmy Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/01/2004)
863 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert McManus on October 20, 2004 (Hulla, Patrick) (Entered: 10/01/2004)
PRO HAC VICE FEE PAID: on 10/01/04 for attorneys Tamara M. Spicer and Harry B. Wilson, Jr. regarding 798 MOTION for attorney Tamara M. Spicer to appear pro hac vice, and 801 MOTION for attorney Harry B. Wilson, Jr. to appear pro hac vice, in the amount of $50.00 each, $100.00 total. Receipt Number: #105308. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (mg) (Entered: 10/01/2004)
864 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ralph Kwapiszeski on October 19, 2004 (Hulla, Patrick) (Entered: 10/01/2004)
865 NOTICE of Consent of Joan M. Boro by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
866 NOTICE of Consent of Janise L. Collins by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
867 NOTICE of Consent of William Anthony Dandridge by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
868 NOTICE of Consent of Mary L. deVore by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
869 NOTICE of Consent of Scott Farley by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
870 NOTICE of Consent of Jonathan L. Fry by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
871 NOTICE of Consent of Robert R. Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
872 NOTICE of Consent of Arline B. Hodges by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
873 NOTICE of Consent of Pamela S. Huffman by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
874 NOTICE of Consent of Harry G. Kavalary by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)

10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/04/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004

875 NOTICE of Consent of Gerald P. Keith by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
876 NOTICE of Consent of Connie G. Krenning by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
877 NOTICE of Consent of Sharon Mendoza by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
878 NOTICE of Consent of Randy Moss by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
879 NOTICE of Consent of Linda S. Parker by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
880 NOTICE of Consent of Rebecca S. Perkins by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
881 NOTICE of Consent of Michelle Stone by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
882 NOTICE of Consent of Ronald T. Stoner by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
883 NOTICE of Consent of Maggie E. Thomason by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
884 NOTICE of Consent of Wade H. Toubassi by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
885 NOTICE of Consent of Valerie D. Vann by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
886 NOTICE of Consent of Peggy Eileen Watkins−Case by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
887 NOTICE of Consent of Esteban S. Yepez by Shirley Williams (Dennis, Stephen) (Entered: 10/04/2004)
888 NOTICE of Consent of Sharon Kay Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
889 NOTICE of Consent of Steven L. Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
890 NOTICE of Consent of Douglas L. Curts by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
891 NOTICE of Consent of Mary Beth Harford by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
892 NOTICE of Consent of Donna R. Kofsky by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
893 NOTICE of Consent of Bobbie J. Mitchell by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
894 NOTICE of Consent of Scott T. Rowe by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
895 NOTICE of Consent of Warren Snitzer by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
896 NOTICE of Consent of Kevin Daryl Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
897 NOTICE of Consent of Mitchel Robert Carlson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
898 NOTICE of Consent of Walter V. Emery by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)

10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004

899 NOTICE of Consent of Cindy Engelbrecht by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
900 NOTICE of Consent of Earl L. Fowler by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
901 NOTICE of Consent of Barbara J. Gibbs by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
902 NOTICE of Consent of Linda S. Hague by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
903 NOTICE of Consent of Evelyn J. Hildebrand by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
904 NOTICE of Consent of Martha M. Lally by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
905 NOTICE of Consent of Kenneth A. Machamer by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
906 NOTICE of Consent of Kathryn J. McCourt by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
907 NOTICE of Consent of William A. McSpadden by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
908 NOTICE of Consent of Glenda R. Mixer by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
909 NOTICE of Consent of Julio M. Morales by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
910 NOTICE of Consent of Tom Rohlfing by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
911 NOTICE of Consent of David L. Schaecher by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
912 NOTICE of Consent of Ronald Wayne Schutte by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
913 NOTICE of Consent of Jeffrey C. Shipley by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
914 NOTICE of Consent of Gregory L. Simmons by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
915 NOTICE of Consent of Wesley Lee Tyree by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
916 NOTICE of Consent of Timothy Marshall Boyd by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
917 NOTICE of Consent of Chuck Diaz by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
918 NOTICE of Consent of David L. Jungert by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
919 NOTICE of Consent of Katherine A. Ritchie by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
920 NOTICE of Consent of Gladys M. Sanderson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
921 NOTICE of Consent of David G. Weerts by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
922 NOTICE of Consent of Samuel E. Bagwell by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)

10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004

923 NOTICE of Consent of David C. Brage by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
924 NOTICE of Consent of Susan Eriksen by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
925 NOTICE of Consent of Edward A. Espinosa by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
926 NOTICE of Consent of Regina Gail Meeks Fine by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
927 NOTICE of Consent of Leonard E. Fus by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
928 NOTICE of Consent of James D. Gideon by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
929 NOTICE of Consent of Cheryl J. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
930 NOTICE of Consent of Vera M. Kipper by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
931 NOTICE of Consent of Roger D. Leimkuehler by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
932 NOTICE of Consent of Richard S. Mason by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
933 NOTICE of Consent of Rita Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
934 NOTICE of Consent of Mark Oglesby by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
935 NOTICE of Consent of James W. Parsons by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
936 NOTICE of Consent of Duane Porter by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
937 NOTICE of Consent of Robert Lee Rogers by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
938 NOTICE of Consent of Karen Shertz by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
939 NOTICE of Consent of Mary Catherine Swett by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
940 NOTICE of Consent of Sherry Lee VanNoy by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
941 NOTICE of Consent of John A. Wansing by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
942 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Driscoll on October 12, 2004 (Graham, Gene) (Entered: 10/05/2004)
943 NOTICE of Consent of Kenneth A. Cronk by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
944 NOTICE of Consent of David L. Evans by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
945 NOTICE of Consent of JoAnn Hughes by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
946 NOTICE of Consent of Bradley F. Rogers by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)

10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004

947 NOTICE of Consent of Paul Rowland by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
948 NOTICE of Consent of Anthony F. Scelza by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
949 NOTICE of Consent of Morris Edward Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
950 NOTICE of Consent of Mariellen Bell Wiemann by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
951 NOTICE of Consent of Albert M. Atkinson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
952 NOTICE of Consent of Stephen J. Bek by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
953 NOTICE of Consent of Earl H. Boyd by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
954 NOTICE of Consent of Douglas H. Freeman by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
955 NOTICE of Consent of Reta M. Juiliano by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
956 NOTICE of Consent of Charles H. Kroll by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
957 NOTICE of Consent of David L. Lanter by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
958 NOTICE of Consent of Pyotr Lipavsky by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
959 NOTICE of Consent of Paul James McAllister by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
960 NOTICE of Consent of Ronald M. Mears by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
961 NOTICE of Consent of Michael Meyer by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
962 NOTICE of Consent of Virginia J. Nooner by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
963 NOTICE of Consent of Curtis B. Overall by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
964 NOTICE of Consent of Kathleen M. Parks by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
965 NOTICE of Consent of Sherry Peterson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
966 NOTICE of Consent of Catherine Prazenica by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
967 NOTICE of Consent of Craig T. Price by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
968 NOTICE of Consent of Cathy R. Sanders by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
969 NOTICE of Consent of Clifford W. Schick by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
970 NOTICE of Consent of Eddie T. Settles by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)

10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/05/2004 10/06/2004 10/06/2004 10/06/2004 10/06/2004 10/06/2004 10/06/2004 10/06/2004 10/06/2004

971 NOTICE of Consent of Syed Sa Shah by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
972 NOTICE of Consent of Megan M. Spohrer by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
973 NOTICE of Consent of Richard Allen Starling by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
974 NOTICE of Consent of Mavis L. Tuttle by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
975 NOTICE of Consent of Ida M. Walker by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
976 NOTICE of Consent of William R. White by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
977 NOTICE of Consent of Thomas A. Armstrong by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
978 NOTICE of Consent of Bruce J. Beard by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
979 NOTICE of Consent of Lorraine M. Hatz by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
980 NOTICE of Consent of Patricia Ann Jackson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
981 NOTICE of Consent of Betty Minard by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
982 NOTICE of Consent of Edith M. Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
983 NOTICE of Consent of Michael Rhodes by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
984 NOTICE of Consent of Karen F. Rook by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
985 NOTICE of Consent of Michelle T. Shaw by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
986 NOTICE of Consent of Teri S. Shelton by Shirley Williams (Dennis, Stephen) (Entered: 10/05/2004)
987 NOTICE of Consent of Ivan Blue by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
988 NOTICE of Consent of Sue B. Britt by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
989 NOTICE of Consent of David McNeill by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
990 NOTICE of Consent of Dominic V. Orlando by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
991 NOTICE of Consent of Terresa E. Rodriguez by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
992 NOTICE of Consent of Mary Frances Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
993 NOTICE of Consent of Lauden T. Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
994 NOTICE of Consent of Christopher Allen by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)

10/06/2004 995 NOTICE of Consent of Steve L. Bidwell by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 996 NOTICE of Consent of James K. Blake by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 997 NOTICE of Consent of David C. Bryant by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 998 NOTICE of Consent of William Eddy by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 999 NOTICE of Consent of Priscilla Yvonne Ferden by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1000 NOTICE of Consent of Robert Kolterman by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1001 NOTICE of Consent of Giray H. Koprucu by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1002 NOTICE of Consent of Debbie Jo Krsa Pellegrino by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1003 NOTICE of Consent of Lynn Anne Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1004 NOTICE of Consent of Howell D. McClain by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1005 NOTICE of Consent of Walter Franklin McKinley, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1006 NOTICE of Consent of Kathleen M. Miles by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1007 NOTICE of Consent of Carri L. Moore by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1008 NOTICE of Consent of Stephen Petty by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1009 NOTICE of Consent of David V. Poggi by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1010 NOTICE of Consent of Daniel L. Robbins by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1011 NOTICE of Consent of Margaret S. Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1012 NOTICE of Consent of Joyce E. Swarn by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1013 NOTICE of Consent of Steve S. Voultepsis by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1014 NOTICE of Consent of Linda L. Altman by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1015 NOTICE of Consent of John Wesley Atkins by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1016 NOTICE of Consent of Katalin Buffington by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1017 NOTICE of Consent of Cynthia Muse Christopher by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1018 NOTICE of Consent of Teresa M. Commons−Moore by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)

10/06/2004 1019 NOTICE of Consent of Mari Dauphine by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1020 NOTICE of Consent of Myra Jan DeVall by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1021 NOTICE of Consent of Carol Irene Faucher by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1022 NOTICE of Consent of Rebecca S. George (Allen) by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1023 NOTICE of Consent of Harold E. Gray III by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1024 NOTICE of Consent of Joy L. Gregg by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1025 NOTICE of Consent of Ronald E. Hebert by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1026 NOTICE of Consent of Dale W. Husbands by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1027 NOTICE of Consent of Lynn B. Iffland by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1028 NOTICE of Consent of Susan K. Jacobson by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1029 NOTICE of Consent of Sandra E. Janini by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1030 NOTICE of Consent of Daniel Wayne Knodle by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1031 NOTICE of Consent of Donna L. Krug by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1032 NOTICE of Consent of Elizabeth Ann Mahoney by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1033 NOTICE of Consent of Lloyd M. Mallory, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1034 NOTICE of Consent of Nanci Myer by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1035 NOTICE of Consent of Jeanette Norwood by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1036 NOTICE of Consent of Henry D. Pohl by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1037 NOTICE of Consent of Dennis Potwora by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1038 NOTICE of Consent of Bernard W. Mayse by Shirley Williams (Brown, Sarah) (Entered: 10/06/2004)
10/06/2004 1039 NOTICE of Consent of Jesse S. Sanders by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1040 NOTICE of Consent of Ronald C. Stein by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1041 NOTICE of Consent of Ian Stong by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1042 NOTICE of Consent of Linda S. Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)

10/06/2004 1043 NOTICE of Consent of Peter J. Volante by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1044 NOTICE of Consent of Robert L. Wittenberg by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1045 NOTICE of Consent of Hugh T. Womer by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1046 NOTICE of Consent of Jeffery D. Baker by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1047 NOTICE of Consent of Raymond Joseph Ballan by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1048 NOTICE of Consent of Ann Marie Bohlander by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1049 NOTICE of Consent of Karen S. Breshears by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1050 NOTICE of Consent of Cynthia L. Brewer−Bulk by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1051 NOTICE of Consent of James R. Canter by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1052 NOTICE of Consent of Samir S. Demian by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1053 NOTICE of Consent of Elizabeth A. Floyd by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1054 NOTICE of Consent of David E. Fraser by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1055 NOTICE of Consent of Janice C. Guidry by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1056 NOTICE of Consent of James Michael Harper by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1057 NOTICE of Consent of Buddy Edward Jedd by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1058 NOTICE of Consent of Ruth Kagan by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1059 NOTICE of Consent of Amr Khalifa by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1060 NOTICE of Consent of Lynda M. Kidwell by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1061 NOTICE of Consent of Michael A. LaMontia by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1062 NOTICE of Consent of Karen D. McCarty by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1063 NOTICE of Consent of Hugh M. Menking by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1064 NOTICE of Consent of Vera Ortega by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1065 NOTICE of Consent of Debra Morales Perry by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1066 NOTICE of Consent of Linda A. Petersen by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)

10/06/2004 1067 NOTICE of Consent of Michael C. Petronella by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1068 NOTICE of Consent of Karl Paul Pettigrew by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1069 NOTICE of Consent of Ruth Ann Richardson by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1070 NOTICE of Consent of Debra Joyce Sherrod by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1071 NOTICE of Consent of Robert H. Steinmetz by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1072 NOTICE of Consent of Jo Ellen Strahle by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1073 NOTICE of Consent of Randall R. Warren by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1074 NOTICE of Consent of Curtis R. White by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1075 NOTICE of Consent of Jon Zeiger by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1076 NOTICE of Consent of Heyun Zheng by Shirley Williams (Dennis, Stephen) (Entered: 10/06/2004)
10/06/2004 1077 ENTRY OF APPEARANCE by Stephen J. Dennis on behalf of all plaintiffs. (Dennis, Stephen) (Entered: 10/06/2004)
10/07/2004 1078 ENTRY OF APPEARANCE by Jennifer L. Martin on behalf of all plaintiffs (Martin, Jennifer) (Entered: 10/07/2004)
10/07/2004 1079 ENTRY OF APPEARANCE by Martin M. Meyers on behalf of all plaintiffs (Meyers, Martin) (Entered: 10/07/2004)
10/07/2004 1080 ENTRY OF APPEARANCE by Deborah J. Blakely on behalf of all plaintiffs (Blakely, Deborah) (Entered: 10/07/2004)
10/07/2004 1081 ENTRY OF APPEARANCE by Gene P. Graham Jr on behalf of all plaintiffs (Graham, Gene) (Entered: 10/07/2004)
10/07/2004 1082 ENTRY OF APPEARANCE by Bert S. Braud on behalf of all plaintiffs. (Braud, Bert) (Entered: 10/07/2004)
10/07/2004 1083 ENTRY OF APPEARANCE by Dennis E. Egan on behalf of all plaintiffs. (Egan, Dennis) (Entered: 10/07/2004)
10/07/2004 1084 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert McManus on October 20, 2004 (Hulla, Patrick) (Entered: 10/07/2004)
10/07/2004 1085 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Ralph Kwapiszeski on October 19, 2004 (Hulla, Patrick) (Entered: 10/07/2004)
10/07/2004 1086 NOTICE of Consent of Martha J. Alley by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1087 NOTICE of Consent of Walter Roy Copeland by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1088 NOTICE of Consent of John Eckholm by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1089 NOTICE of Consent of Mark W. Lundy by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)

10/07/2004 1090 NOTICE of Consent of James McCance by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1091 NOTICE of Consent of Robert L. McIlrath by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1092 NOTICE of Consent of David S. Nichols by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1093 NOTICE of Consent of Gary Douglas Urton by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1094 NOTICE of Consent of Thomas David Waddell by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1095 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 10/07/2004)
10/07/2004 1096 NOTICE of Consent of Khaled Al−Zouhbi by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1097 NOTICE of Consent of Tamara Arlene Ansaldo by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1098 NOTICE of Consent of Marilyn J. Balderson by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1099 NOTICE of Consent of Robyn M. Barrett by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1100 NOTICE of Consent of Terri Bogina by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1101 NOTICE of Consent of Michelle Brauer by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1102 NOTICE of Consent of Terry Bridges by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1103 NOTICE of Consent of Kathy Marie Britton by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1104 NOTICE of Consent of Mark S. Capell by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1105 NOTICE of Consent of Leslie Joe Coker by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1106 NOTICE of Consent of Patricia A. Coker by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1107 NOTICE of Consent of James R. Colyer by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1108 NOTICE of Consent of Augustine Alvin Cotten by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1109 NOTICE of Consent of Donald K. Cowick by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1110 NOTICE of Consent of Lynda Day by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1111 NOTICE of Consent of Vicki Dickinson by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1112 NOTICE of Consent of Bobbie J. Dunn by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1113 NOTICE of Consent of John F. Dunne by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)

10/07/2004 1114 NOTICE of Consent of Cynthia R. Erwert by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1115 NOTICE of Consent of Karry W. Foster by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1116 NOTICE of Consent of James H. Franklin by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1117 NOTICE of Consent of Jeffrey L. Gaughan by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1118 NOTICE of Consent of Glenn T. Gillihan by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1119 NOTICE of Consent of Merrie M. Glenn by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1120 NOTICE of Consent of Sharon K. Goldring by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1121 NOTICE of Consent of Martha Harry by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1122 NOTICE of Consent of Paul J. Hartl by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1123 NOTICE of Consent of Myra Penny Hobley by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1124 NOTICE of Consent of Sherry Lynn Hudson by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1125 NOTICE of Consent of Chaim Ivry by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1126 NOTICE of Consent of Kumkum A. Jain by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1127 NOTICE of Consent of Ricky A. Jordan by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1128 NOTICE of Consent of Rufus J. Kemp by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1129 NOTICE of Consent of John Barry Kite by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1130 NOTICE of Consent of Justine E. Bowen Koch by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1131 NOTICE of Consent of Harrell Wayne Lewis by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1132 NOTICE of Consent of Jean Lofflin by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1133 NOTICE of Consent of Bruce Logsdon by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1134 NOTICE of Consent of Patricia Dill McAdam by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1135 NOTICE of Consent of Deborah McDonald by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1136 NOTICE of Consent of Sara E. Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1137 NOTICE of Consent of Stephen Curtis Newton by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)

10/07/2004 1138 NOTICE of Consent of Christian U. Nwabara by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1139 NOTICE of Consent of Larry L. O'Neil by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1140 NOTICE of Consent of Richard G. Parks by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1141 NOTICE of Consent of Charles N. Parrish by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1142 NOTICE of Consent of Warren P. Pierson III by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1143 NOTICE of Consent of Michael B. Renner by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1144 NOTICE of Consent of Tracy Rickett by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1145 NOTICE of Consent of Phillip Rosenfeld by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1146 NOTICE of Consent of Kenneth J. Sawyer by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1147 NOTICE of Consent of Julie F. Schuman by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1148 NOTICE of Consent of Mary L. Secrest by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1149 NOTICE of Consent of Wendy Shaeffer by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1150 NOTICE of Consent of Preston Stauffer by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1151 NOTICE of Consent of Ann G. Stephens by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1152 NOTICE of Consent of Daniel L. Strader by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1153 NOTICE of Consent of Michael K. Stubbs by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1154 NOTICE of Consent of Bruce C. Voiles by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/07/2004 1155 NOTICE of Consent of William Albert Wood Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/07/2004)
10/08/2004 1156 NOTICE of Consent of Annette Boldridge by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1157 NOTICE of Consent of Scott D. Graham by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1158 NOTICE of Consent of Ronald E. Hammond by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1159 NOTICE of Consent of Charles M. Miner by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1160 NOTICE of Consent of Loreatha E. Nicholson by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1161 NOTICE of Consent of Steven T. Spackeen by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)

10/08/2004 1162 NOTICE of Consent of Jack A. Vielleux by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1163 NOTICE of Consent of Stacy L. Villines by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1164 NOTICE of Consent of Christine Vose by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1165 NOTICE of Consent of Josephine Zloty by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1166 NOTICE of Consent of John Buglino by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1167 NOTICE of Consent of Sally Genise Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1168 CERTIFICATE OF SERVICE by Sprint/United Management Company re Sprint Supplemental Answers and Objections to Plaintiffs' Fifth Interrogatories. (Hulla, Patrick) (Entered: 10/08/2004)
10/08/2004 1169 CERTIFICATE OF SERVICE by Sprint/United Management Company re Defendant's 3rd Request for Production of Documents to Plaintiff. (Hulla, Patrick) (Entered: 10/08/2004)
10/08/2004 1170 CERTIFICATE OF SERVICE by Sprint/United Management Company re Defendant's 3rd Interrogatories to Plaintiff. (Hulla, Patrick) (Entered: 10/08/2004)
10/08/2004 1171 NOTICE of Consent of Donna Lee A. Andrews by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1172 NOTICE of Consent of Godfrey I. Archibong by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1173 NOTICE of Consent of Derek R. Bailey by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1174 NOTICE of Consent of Betsy Berens by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1175 NOTICE of Consent of Thomas E. Bleckley by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1176 NOTICE of Consent of Lois R. Boldt by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1177 NOTICE of Consent of James Eldon Boynton by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1178 NOTICE of Consent of David S. Bresnahan by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1179 NOTICE of Consent of Christine Carnahan by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1180 NOTICE of Consent of Bertha W. Carter by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1181 NOTICE of Consent of Ginger Chase by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1182 NOTICE of Consent of Denise Criddle−Jenkins by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1183 NOTICE of Consent of Susan M. D'Alessandro by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1184 NOTICE of Consent of John Kelly Dannelley by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)

10/08/2004 1185 NOTICE of Consent of Nancy M. Demorest by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1186 NOTICE of Consent of Timothy E. Demorest by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1187 NOTICE of Consent of Janette M. Diehl by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1188 NOTICE of Consent of Timothy Dillon by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1189 NOTICE of Consent of Melvyn Dunkerley by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1190 NOTICE of Consent of Diane Eberhart by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1191 NOTICE of Consent of Catherine Evans by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1192 NOTICE of Consent of Bruce H. Fields by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1193 NOTICE of Consent of Patricia Eileen Fierst by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1194 NOTICE of Consent of Thomas C. Foerster by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1195 NOTICE of Consent of Alan M. Freemire by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1196 NOTICE of Consent of Kathryn C. Gardner by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1197 NOTICE of Consent of Byron Gudmestad by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1198 NOTICE of Consent of Connie L. Gutierrez by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1199 NOTICE of Consent of Clarence R. Hanson by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1200 NOTICE of Consent of Jack Michael Harry by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1201 NOTICE of Consent of Ronald Dean Havens by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1202 NOTICE of Consent of Joseph E. Hernandez by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1203 NOTICE of Consent of Drema H. Hill by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1204 NOTICE of Consent of Howard Owen Holbrook by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1205 NOTICE of Consent of Gerry Hollingshead by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1206 NOTICE of Consent of Lemuel B. Ivie by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1207 NOTICE of Consent of Thomas Michael Jackson by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1208 NOTICE of Consent of Jeffrey O.C. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)

10/08/2004 1209 NOTICE of Consent of Willie James Johnson, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1210 NOTICE of Consent of Larry M. Jurak by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1211 NOTICE of Consent of Carole L. Kann by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1212 NOTICE of Consent of Elizabeth D. Kaufman by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1213 NOTICE of Consent of Leslie U. Kimiecik by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1214 NOTICE of Consent of Burma Knowles by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1215 NOTICE of Consent of Steven D. Koch by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1216 NOTICE of Consent of David E. Koerner by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1217 NOTICE of Consent of William Russell Kumpe by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1218 NOTICE of Consent of John T. Kurpinski Sr. by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1219 NOTICE of Consent of Carol Laundy by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1220 NOTICE of Consent of Bernice Lewis by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1221 NOTICE of Consent of David L. Lingardo by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1222 NOTICE of Consent of Amy Lutz by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1223 NOTICE of Consent of Anthony M. Martucci by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1224 NOTICE of Consent of Jeanne M. Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1225 NOTICE of Consent of Nelda J. Monroe by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1226 NOTICE of Consent of Edward Anthony Mosczynski by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1227 NOTICE of Consent of Michael F. Nicosia by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1228 NOTICE of Consent of Jeong Oh by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1229 NOTICE of Consent of Donna S. Oltmann by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1230 NOTICE of Consent of Farifteh Parniani−Eatman by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1231 NOTICE of Consent of Vincent Perlongo by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1232 NOTICE of Consent of Anthony Pierce by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)

10/08/2004 1233 NOTICE of Consent of Diana Pinkins by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1234 NOTICE of Consent of Carlos J. Poteet Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1235 NOTICE of Consent of Susan T. Pringle by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1236 NOTICE of Consent of Michael Edwin Ragan by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1237 NOTICE of Consent of David A. Ray by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1238 NOTICE of Consent of Daniel J. Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1239 NOTICE of Consent of John Garland Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1240 NOTICE of Consent of Alissa Karen Ross by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1241 NOTICE of Consent of Joyce A. Savage by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1242 NOTICE of Consent of Ralph B. Schneider by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1243 NOTICE of Consent of Toni Selman by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1244 NOTICE of Consent of Russell C. Simmons by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/08/2004 1245 NOTICE of Consent of Victoria Rose Simone by Shirley Williams (Dennis, Stephen) (Entered: 10/08/2004)
10/09/2004 1246 NOTICE of Consent of Jeffery B. Anderson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1247 NOTICE of Consent of Veronica C. Armstrong by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1248 NOTICE of Consent of Loyal Charles Auman by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1249 NOTICE of Consent of Karen L. Barquist by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1250 NOTICE of Consent of Jeanette M. Bass by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1251 NOTICE of Consent of Elmer Leroy Benson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1252 NOTICE of Consent of Sharon Berlint by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1253 NOTICE of Consent of Robert Harry Biniek by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1254 NOTICE of Consent of Bobby Harold Boggs by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1255 NOTICE of Consent of James R. Bollinger by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1256 NOTICE of Consent of Thomas A. Bradley by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1257 NOTICE of Consent of Richard M. Breitenbach by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1258 NOTICE of Consent of Joan K. Burton by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1259 NOTICE of Consent of John J. Carter by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1260 NOTICE of Consent of Lucy Chapa by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1261 NOTICE of Consent of Janiece Ann Cline by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1262 NOTICE of Consent of Richard J. Clisso by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1263 NOTICE of Consent of Robert E. Cody by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1264 NOTICE of Consent of Lonnie Aaron Daniels, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1265 NOTICE of Consent of Richard F. Danjou by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1266 NOTICE of Consent of Susan L. Davidson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1267 NOTICE of Consent of Beatrice M. Dewing by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1268 NOTICE of Consent of Dennis Eugene Edney by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1269 NOTICE of Consent of Gladys Marie English by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1270 NOTICE of Consent of A. Ron Evangelista by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1271 NOTICE of Consent of James S. Fish by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1272 NOTICE of Consent of Lisa R. Franceschini by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1273 NOTICE of Consent of James E. Friendly by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1274 NOTICE of Consent of Judy K. Gaffney by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1275 NOTICE of Consent of Michael D. Gaffney by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1276 NOTICE of Consent of Fred Giuntini by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1277 NOTICE of Consent of Robert Graham by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1278 NOTICE of Consent of Walter D. Grba by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1279 NOTICE of Consent of Robert W. Greenhut by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1280 NOTICE of Consent of Greg Harper by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1281 NOTICE of Consent of Ronald Keith Harper, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1282 NOTICE of Consent of Patricia M. Harrelson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1283 NOTICE of Consent of Teresa L. Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1284 NOTICE of Consent of Angela Haynes by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1285 NOTICE of Consent of Joan M. Heacker by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1286 NOTICE of Consent of John Hendrix by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1287 NOTICE of Consent of Dixie L. Heyl by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1288 NOTICE of Consent of Sheldon G. Hootner by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1289 NOTICE of Consent of Joe A. Jamison by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1290 NOTICE of Consent of Linda C. Johns by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1291 NOTICE of Consent of Linda L. Johnston by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1292 NOTICE of Consent of Robert L. Jones by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1293 NOTICE of Consent of James Robert Jorrie by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1294 NOTICE of Consent of Daniel Bruce Kennedy by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1295 NOTICE of Consent of David Keyes by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1296 NOTICE of Consent of Kevin W. Dacy by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1297 NOTICE of Consent of Tae H. Kim by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1298 NOTICE of Consent of Gary Walter Kloss by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1299 NOTICE of Consent of Trudi L. Krugh by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1300 NOTICE of Consent of Terry L. Leber by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1301 NOTICE of Consent of Deborah H. Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1302 NOTICE of Consent of Jacqueline Lisby by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1303 NOTICE of Consent of Carol L. Little by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1304 NOTICE of Consent of Linda H. Lowery by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1305 NOTICE of Consent of Max M. Lugauer by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1306 NOTICE of Consent of Douglas Lundstrom by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1307 NOTICE of Consent of Linda L. Lyman by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1308 NOTICE of Consent of Steve E. Macy by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1309 NOTICE of Consent of Carolyn J. Mahn by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1310 NOTICE of Consent of Tamara J. Maichel by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1311 NOTICE of Consent of Linda S. Mancino by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1312 NOTICE of Consent of Dennis J. Mays by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1313 NOTICE of Consent of Beverly A. McCoy by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1314 NOTICE of Consent of Terry R. Mollett by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1315 NOTICE of Consent of Roxie L. Moreland by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1316 NOTICE of Consent of Kevin Keith Nartker by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1317 NOTICE of Consent of Kevin Olmstead by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1318 NOTICE of Consent of Richard A. Olson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1319 NOTICE of Consent of W. Wayne Parsons by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1320 NOTICE of Consent of Peter A. Pasquale by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1321 NOTICE of Consent of Donna J. Patrick by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1322 NOTICE of Consent of Barbara J. Radtke by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1323 NOTICE of Consent of Joan M. Rambo by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1324 NOTICE of Consent of Vinnie Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1325 NOTICE of Consent of Harold Grant Robinson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1326 NOTICE of Consent of Michael A. Rogers by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1327 NOTICE of Consent of Irene Ruler by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1328 NOTICE of Consent of Joan Elizabeth Rupp by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1329 NOTICE of Consent of Joseph P. Rutten by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1330 NOTICE of Consent of Charles Edward Salters by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1331 NOTICE of Consent of Larry A. Sharpe by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1332 NOTICE of Consent of Samuel Edward Shelton by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1333 NOTICE of Consent of Donna Sweet by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1334 NOTICE of Consent of Stanley R. Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1335 NOTICE of Consent of Debra Louise Tolbert by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1336 NOTICE of Consent of Deborah L. Viebrock by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1337 NOTICE of Consent of James B. Wagner by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1338 NOTICE of Consent of Alvenia W. Warren by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1339 NOTICE of Consent of Jane P. Watts by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1340 NOTICE of Consent of Katheryn Louise Webster by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1341 NOTICE of Consent of Hyla B. Weeks by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1342 NOTICE of Consent of Frank B. Wigfall, Sr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1343 NOTICE of Consent of Gerald Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1344 NOTICE of Consent of Elaine Wilson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1345 NOTICE of Consent of Joy C. Adorante by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1346 NOTICE of Consent of Deborah F. Alt by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1347 NOTICE of Consent of Quirino C. Amore, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1348 NOTICE of Consent of David E. Andrews by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1349 NOTICE of Consent of Virginia Z. Ansell by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1350 NOTICE of Consent of Tery M. Ayers by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1351 NOTICE of Consent of Donna M. Baer by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1352 NOTICE of Consent of Marjorie A. Bailey by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1353 NOTICE of Consent of Patricia C. Ballard by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1354 NOTICE of Consent of Judy Barnett by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1355 NOTICE of Consent of Nolan B. Beatty by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1356 NOTICE of Consent of Brenda Blackshear by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1357 NOTICE of Consent of Louis Blum by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1358 NOTICE of Consent of Timothy N. Bowser by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1359 NOTICE of Consent of Gerry M. Osterberg by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1360 NOTICE of Consent of Diana Lyn Bland by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1361 NOTICE of Consent of Maurice Lee Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1362 NOTICE of Consent of Stephen R. Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1363 NOTICE of Consent of George O. Bryce by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1364 NOTICE of Consent of Jeanne Butcher by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1365 NOTICE of Consent of Alcee Butler, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1366 NOTICE of Consent of Richard W. Cahoon by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1367 NOTICE of Consent of Dennis William Campbell by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1368 NOTICE of Consent of Karen L. Carpenter by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1369 NOTICE of Consent of Mildred Carter−Grueninger by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1370 NOTICE of Consent of H. Marie Church by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1371 NOTICE of Consent of Ernestine Cole by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1372 NOTICE of Consent of Rhonda Comer by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1373 NOTICE of Consent of Thomas D. Conrow by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1374 NOTICE of Consent of Jay D. Cox by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1375 NOTICE of Consent of Rosa Lee Darby by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1376 NOTICE of Consent of Kevin T. Farley by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1377 NOTICE of Consent of Sheila M. Farris by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1378 NOTICE of Consent of Nathan E. Feimster by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1379 NOTICE of Consent of Regina A. Ferguson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1380 NOTICE of Consent of Duane F. Filsinger by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1381 NOTICE of Consent of Arvie Fisher by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1382 NOTICE of Consent of Gregory P. Flotard by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1383 NOTICE of Consent of Barbara J. Garcia by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1384 NOTICE of Consent of Thomas Garza by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1385 NOTICE of Consent of Bette Getz by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1386 NOTICE of Consent of Hilda Sutton Gibson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1387 NOTICE of Consent of LaVerne E. Gildner, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1388 NOTICE of Consent of Thomas M. Goff by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1389 NOTICE of Consent of Flora L. Grayson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1390 NOTICE of Consent of Pablo B. Gausch by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1391 NOTICE of Consent of Wayne Wesley Hartman, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1392 NOTICE of Consent of David Hopkins by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1393 NOTICE of Consent of David B. Jackson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1394 NOTICE of Consent of Julie Jaillet by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1395 NOTICE of Consent of Keith Jamour by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1396 NOTICE of Consent of Leava Jones by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1397 NOTICE of Consent of Kimberlea P. Joyner−Wortman by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1398 NOTICE of Consent of Michael L. Kaufhold, Sr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1399 NOTICE of Consent of Paul R. Lamoree by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1400 NOTICE of Consent of Beverly P. Lane by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)

10/09/2004 1401 NOTICE of Consent of Paul A. Lero by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1402 NOTICE of Consent of Brian Long by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1403 NOTICE of Consent of Michael H. Lovett by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1404 NOTICE of Consent of Teresa L. Major by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1405 NOTICE of Consent of Robert L. Marion by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1406 NOTICE of Consent of Anne C. McAuley by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1407 NOTICE of Consent of Arnie Byron McKinnis III by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1408 NOTICE of Consent of Carl N. Morgan by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1409 NOTICE of Consent of Kathy S. Morgan by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1410 NOTICE of Consent of Susan Lynn Neill by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1411 NOTICE of Consent of Ronald Wayne Nuhring by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1412 NOTICE of Consent of Darrell L. Parks by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1413 NOTICE of Consent of Rebecca Patton by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1414 NOTICE of Consent of John R. Paul, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1415 NOTICE of Consent of Kenneth R. Peterson by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1416 NOTICE of Consent of Khiem Phan by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1417 NOTICE of Consent of Jani Pryne by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1418 NOTICE of Consent of Vincent L. Rohloff II by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1419 NOTICE of Consent of Donna M. Salinas by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1420 NOTICE of Consent of Gary A. Schauperl by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1421 NOTICE of Consent of Phyllis Jean Schierioth by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1422 NOTICE of Consent of Christine L. Sheppard (Link) by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/09/2004 1423 NOTICE of Consent of Sandra Cox Snead by Shirley Williams (Dennis, Stephen) (Entered: 10/09/2004)
10/10/2004 1424 NOTICE of Consent of Alexander A. Smircich by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1425 NOTICE of Consent of Billie J.Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1426 NOTICE of Consent of Stephen F. Spooner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1427 NOTICE of Consent of Margaret E. Spriggs by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1428 NOTICE of Consent of Michael Ray Steele by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1429 NOTICE of Consent of Sandra Sturgeon by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1430 NOTICE of Consent of Maria Surrell by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1431 NOTICE of Consent of Brenda Jean Tanner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1432 NOTICE of Consent of Bruce E. Taylor by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1433 NOTICE of Consent of Karen Shepherd Tenison by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1434 NOTICE of Consent of Ronald Eugene Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1435 NOTICE of Consent of Eric S. Thomsen by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1436 NOTICE of Consent of Colleen M. Thornbrugh by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1437 NOTICE of Consent of Graceann E. Tompkins by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1438 NOTICE of Consent of Diane B. Townes by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1439 NOTICE of Consent of Steve T. Tran by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1440 NOTICE of Consent of Carol Lee Truitt by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1441 NOTICE of Consent of Diane Turechek by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1442 NOTICE of Consent of Camilla S. Walton by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1443 NOTICE of Consent of Shelia Denise Webb by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1444 NOTICE of Consent of Elizabeth Terri Weber by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1445 NOTICE of Consent of Peggy J. Wilson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1446 NOTICE of Consent of Susan G. Wunder by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1447 NOTICE of Consent of John A. Young by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1448 NOTICE of Consent of Aleksandra Zinoryeva by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1449 NOTICE of Consent of A. Doreen Snyder by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1450 NOTICE of Consent of David B. Snypes by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1451 NOTICE of Consent of Edith L. Splain by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1452 NOTICE of Consent of Paul D. Sprout, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1453 NOTICE of Consent of Sharon Uyvonne Steele by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1454 NOTICE of Consent of David T. Stevens by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1455 NOTICE of Consent of Edwin F. Stewart by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1456 NOTICE of Consent of Alonzo Street by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1457 NOTICE of Consent of Diane K. Strefling by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1458 NOTICE of Consent of Phyllis A. Taylor by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1459 NOTICE of Consent of Sheila Thomas−Peterson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1460 NOTICE of Consent of Sammy Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1461 NOTICE of Consent of Patrick Trainor by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1462 NOTICE of Consent of Kenneth A. Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1463 NOTICE of Consent of Mary Wagner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1464 NOTICE of Consent of Diane A. Weege by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1465 NOTICE of Consent of Deborah Denise Whalen by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1466 NOTICE of Consent of Stephen Wibbenmeyer by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1467 NOTICE of Consent of Joseph Wilcox by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1468 NOTICE of Consent of Arthur L. Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1469 NOTICE of Consent of DiAnna Lynn Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1470 NOTICE of Consent of Kuo−Kong Woo by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1471 NOTICE of Consent of Joy M. Acree by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1472 NOTICE of Consent of Debra L. Arck by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1473 NOTICE of Consent of Scott Barger by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1474 NOTICE of Consent of Dale M. Deal by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1475 NOTICE of Consent of Bernadine Ann Goens by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1476 NOTICE of Consent of Tiha Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1477 NOTICE of Consent of Lucy M. Harrison by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1478 NOTICE of Consent of Debra A. Kehn by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1479 NOTICE of Consent of JoAnn Kelly by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1480 NOTICE of Consent of Lee Gillian Kinsey by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1481 NOTICE of Consent of Steven J. Koester by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1482 NOTICE of Consent of Diane Licavoli by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1483 NOTICE of Consent of Bruce Allen Lipson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1484 NOTICE of Consent of Michael Morris Poindexter by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1485 NOTICE of Consent of Carmen Ramirez by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1486 NOTICE of Consent of Elton L. Reynolds by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1487 NOTICE of Consent of David A. Richards by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1488 NOTICE of Consent of Kelly Ann Schneider by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1489 NOTICE of Consent of Donna Kaye Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1490 NOTICE of Consent of Ronald L. Steinour by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1491 NOTICE of Consent of Glenda B. Sumner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1492 NOTICE of Consent of Geraldine Richard Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1493 NOTICE of Consent of Clifford Joel Waugh by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1494 NOTICE of Consent of Brenda O. Weatherford by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1495 NOTICE of Consent of Donald Wingard by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1496 NOTICE of Consent of Cheryl J. Alexander by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1497 NOTICE of Consent of Dennis Dean Ayers by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1498 NOTICE of Consent of DeLece Renae Barker by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1499 NOTICE of Consent of Mark R. Brennaman by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1500 NOTICE of Consent of Beverly S. Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1501 NOTICE of Consent of Gerald M. Caswell by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1502 NOTICE of Consent of Reynold J. Chen by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1503 NOTICE of Consent of William Chen by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1504 NOTICE of Consent of Glinda Currin−Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1505 NOTICE of Consent of Troy G. Green by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1506 NOTICE of Consent of Christopher F. Guarino by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1507 NOTICE of Consent of Serena James by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1508 NOTICE of Consent of Jan McDaniel by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1509 NOTICE of Consent of Debbie L. McElvain−Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1510 NOTICE of Consent of Russell D. Mehl by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1511 NOTICE of Consent of Rodney A. Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1512 NOTICE of Consent of James W. Murch by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1513 NOTICE of Consent of James W. Murch by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1514 NOTICE of Consent of Robin S. Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1515 NOTICE of Consent of Jeffrey L. Nichols by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1516 NOTICE of Consent of Steven P. Reutter by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1517 NOTICE of Consent of Mary R. Scott by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1518 NOTICE of Consent of Kevin A. Shannon by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1519 NOTICE of Consent of Ginger W. Sullivan by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1520 NOTICE of Consent of Jacquline L. Vickrey by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1521 NOTICE of Consent of Joseph B. Ziegler by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1522 NOTICE of Cosent of Charles Morris Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1523 NOTICE of Consent of James Charlie Benedict by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1524 NOTICE of Consent of James Charlie Benedict by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1525 NOTICE of Consent of Bernard L. Bland, III by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1526 NOTICE of Consent of George Laurence Carter by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1527 NOTICE of Consent of Keith W. Cecil, III by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1528 NOTICE of Consent of Ronald L. Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1529 NOTICE of Consent of Cherry L. Jackson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1530 NOTICE of Consent of Lillian June Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1531 NOTICE of Consent of Donald L. Kentopp by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1532 NOTICE of Consent of Cheryl V. List by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1533 NOTICE of Consent of Cathy J. Mark by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1534 NOTICE of Consent of Lydon Capra McCallon by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1535 NOTICE of Consent of Jefferey Trent McGill by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1536 NOTICE of Consent of Michael L. Mennuti by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1537 NOTICE of Consent of Gerry B. Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1538 NOTICE of Consent of ChloeAnn Petty by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1539 NOTICE of Consent of Robin Posey−Blue by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1540 NOTICE of Consent of Sylvan R. Rossi by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1541 NOTICE of Consent of Richard A. Sage by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1542 NOTICE of Consent of Sherree D. Sammons by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1543 NOTICE of Consent of Gary Dean Shappell by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1544 NOTICE of Consent of Michael Spoon by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1545 NOTICE of Consent of Rex A. Steyskal by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1546 NOTICE of Consent of Carolyn J. Winston by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1547 NOTICE of Consent of Phil Yan by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1548 NOTICE of Consent of Tommie Lee Arnick, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1549 NOTICE of Consent of Dale Michael Aston by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1550 NOTICE of Consent of Steven R. Castro by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1551 NOTICE of Consent of Robert B. Cullinan by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1552 NOTICE of Consent of Karen Duraney by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1553 NOTICE of Consent of Pamela Fellows by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1554 NOTICE of Consent of Willie E. Ford, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1555 NOTICE of Consent of David W. Garbush by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1556 NOTICE of Consent of Stuart R. Goble by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1557 NOTICE of Consent of Jeanette M. Gonzales by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1558 NOTICE of Consent of Mary C. Heritage by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1559 NOTICE of Consent of Thomas Mennona by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1560 NOTICE of Consent of Michael M. Murchison by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1561 NOTICE of Consent of Catharine M. Murphy by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1562 NOTICE of Consent of Laima Narubin by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1563 NOTICE of Consent of Leslie D. Perry by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1564 NOTICE of Consent of Marlene Waltmon Ponce by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1565 NOTICE of Consent of Shirley A. Ragins by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1566 NOTICE of Consent of David R. Satterfield by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1567 NOTICE of Consent of Gloria Ann Armour Sawyer by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1568 NOTICE of Consent of Herbert E. Skidmore by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1569 NOTICE of Consent of Linda J. Tufano by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1570 NOTICE of Consent of Albert W. Vogel, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1571 NOTICE of Consent of Helena E. Young by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1572 NOTICE of Consent of Helena E. Young by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1573 NOTICE of Consent of Joanne Elaine Zubal by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1574 NOTICE of Consent of Catherine Arline Brauner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1575 NOTICE of Consent of David Mark Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1576 NOTICE of Consent of Robyn Butler by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1577 NOTICE of Consent of Charles Caton by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1578 NOTICE of Consent of Mary Ann Crisp by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1579 NOTICE of Consent of Linda DeMatteis by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1580 NOTICE of Consent of Donna Jane Diehm by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1581 NOTICE of Consent of Kent Gooden by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1582 NOTICE of Consent of Randall E. Graham by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1583 NOTICE of Consent of Susan E. Guthrie by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1584 NOTICE of Consent of Robin M. Hobbs by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1585 NOTICE of Consent of Phyllis R. Janes by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1586 NOTICE of Consent of Denise Karen Dunn King by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1587 NOTICE of Consent of Lewis A. Levy by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1588 NOTICE of Consent of Larrie Loehr by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1589 NOTICE of Consent of Douglas Edward Marlowe by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1590 NOTICE of Consent of Aderele Teddy Mason by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1591 NOTICE of Consent of Michael E. Mulvaney by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1592 NOTICE of Consent of Hoyt Eldean Neal, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1593 NOTICE of Consent of Ehi Parker by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1594 NOTICE of Consent of Earl Simmons by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1595 NOTICE of Consent of Madelyn Velasquez−Almansa by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1596 NOTICE of Consent of Debra Walker by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1597 NOTICE of Consent of Patrick H. Walsh by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1598 NOTICE of Consent of Jacquet Wishropp by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1599 NOTICE of Consent of Clark Abrahamson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1600 NOTICE of Consent of Larry E. Bell by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1601 NOTICE of Consent of Daniel James Blevins by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1602 NOTICE of Consent of Joyce D. Brodberg by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1603 NOTICE of Consent of Sandra S. Conrad by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1604 NOTICE of Consent of Catherine M. Gilbert by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1605 NOTICE of Consent of Judith C. Hadar by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1606 NOTICE of Consent of Linda C. Hardy by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1607 NOTICE of Consent of Jillian James by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1608 NOTICE of Consent of Edwin C. Kisiel, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1609 NOTICE of Consent of Sue M. Mange by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1610 NOTICE of Consent of Deborah A. Mitchell by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1611 NOTICE of Consent of Charlotte Wright Parker by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1612 NOTICE of Consent of Lisa Y. Perez by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1613 NOTICE of Consent of Russell W. Rackley by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1614 NOTICE of Consent of Bradley J. Roth by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1615 NOTICE of Consent of Louis Ruiz by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1616 NOTICE of Consent of Althea W. Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)

10/10/2004 1617 NOTICE of Consent of Angileen Noreen Stewart by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1618 NOTICE of Consent of P.J. Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1619 NOTICE of Consent of Judy Vodas by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1620 NOTICE of Consent of Brian Warrick by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1621 NOTICE of Consent of Gary L. Willis by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1622 NOTICE of Consent of Theresa M. Wilson by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1623 NOTICE of Consent of Jeffrey David Zak by Shirley Williams (Dennis, Stephen) (Entered: 10/10/2004)
10/10/2004 1624 NOTICE of Consent of Gerard B. Arena by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/10/2004 1625 NOTICE of Consent of Janette H. Darmer Blackmon by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/10/2004 1626 NOTICE of Consent of Mary Alice Brinson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/10/2004 1627 NOTICE of Consent of M. Dale Carter by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1628 NOTICE of Consent of Gary L. Daehnke by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1629 NOTICE of Consent of Joel R. Darden by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1630 NOTICE of Consent of Nathaniel J. Dobin by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1631 NOTICE of Consent of Brenda R. Eversole by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1632 NOTICE of Consent of John Finley by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1633 NOTICE of Consent of Linda Gail Goss by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1634 NOTICE of Consent of Richard James Grady by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1635 NOTICE of Consent of Gwendolen M. Guthrie−Rudacille by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1636 NOTICE of Consent of Randal P. Hammond by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1637 NOTICE of Consent of Robbie Jo Hernandez by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1638 NOTICE of Consent of Marvita L. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1639 NOTICE of Consent of Michael D. Lawson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1640 NOTICE of Consent of Thomas C. Lindzy by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1641 NOTICE of Consent of Thomas J. Prescott by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1642 NOTICE of Consent of L. Renee Routzong by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1643 NOTICE of Consent of Harold F. Simon by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1644 NOTICE of Consent of Martin A. Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1645 NOTICE of Consent of Juliette A. Stevens by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1646 NOTICE of Consent of Janice F. Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1647 NOTICE of Consent of Brenda L. Weber by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1648 NOTICE of Consent of Timothy A. Wonder by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1649 NOTICE of Consent of Joe Ann Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1650 NOTICE of Consent of Betty R. Allen by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1651 NOTICE of Consent of Elvy Paulette Andis by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1652 NOTICE of Consent of William J. Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1653 NOTICE of Consent of Richard James Courtice by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1654 NOTICE of Consent of Michael D. Dadisman by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1655 NOTICE of Consent of Rosemary Delpino by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1656 NOTICE of Consent of Gary W. Fry by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1657 NOTICE of Consent of Robert J. Haley by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1658 NOTICE of Consent of Alice Whitaker Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1659 NOTICE of Consent of Joyce M. Hecht by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1660 NOTICE of Consent of Sharon Gentry Jones by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1661 NOTICE of Consent of Timothy Allen Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1662 NOTICE of Consent of Robert A. Moritz by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1663 NOTICE of Consent of Donald M. Osborn by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1664 NOTICE of Consent of Nancy L. Patton by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1665 NOTICE of Consent of Rick Rawlings by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1666 NOTICE of Consent of Tina Richter by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1667 NOTICE of Consent of Karen M. Rider by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1668 NOTICE of Consent of Sally Thompson Rosine by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1669 NOTICE of Consent of Peggy Schniegenberg by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1670 NOTICE of Consent of Susan M. Sites by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1671 NOTICE of Consent of Darrel Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1672 NOTICE of Consent of Christeen Vergith by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1673 NOTICE of Consent of Alfonso Zamorano by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1674 ENTRY OF APPEARANCE by Dirk L. Hubbard on behalf of all plaintiffs. (Hubbard, Dirk) (Entered: 10/11/2004)
10/11/2004 1675 ENTRY OF APPEARANCE by John M. Klamann on behalf of all plaintiffs. (Klamann, John) (Entered: 10/11/2004)
10/11/2004 1676 NOTICE of Consent of David Emmett Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1677 NOTICE of Consent of John J. Butler by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1678 NOTICE of Consent of Sandra J. Crow by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1679 NOTICE of Consent of Tracy J. Delnegro by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1680 NOTICE of Consent of Mark Gaff by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1681 NOTICE of Consent of Ronald L. Hetrick by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1682 NOTICE of Consent of Helen Hill by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1683 NOTICE of Consent of Jerome F. Kacheroski by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1684 NOTICE of Consent of Suzan Malady by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1685 NOTICE of Consent of Annette N. McCabe by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1686 NOTICE of Consent of Cynthia S. McCandless by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1687 NOTICE of Consent of Pamela E. Mullen by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1688 NOTICE of Consent of Patricia Murzyn by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1689 NOTICE of Consent of LaWanda F. Roche by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1690 NOTICE of Consent of Anne M. Stern by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1691 NOTICE of Consent of Reggie Thompson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1692 NOTICE of Consent of Helen VanNess by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1693 NOTICE of Consent of Angela Walker by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1694 NOTICE of Consent of Michael B. Wynter by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1695 NOTICE of Consent of Susan Yaw by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1696 NOTICE of Consent of Nancy Sue Cabray by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1697 NOTICE of Consent of Michael A. Canty by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1698 NOTICE of Consent of Candy M. Colwell by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1699 NOTICE of Consent of Barbara Motes Coon by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1700 NOTICE of Consent of Eileen T. Darrah by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1701 NOTICE of Consent of Leslie Ann Douglas by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1702 NOTICE of Consent of Ted A. Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1703 NOTICE of Consent of Donna K. Hubert by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1704 NOTICE of Consent of Denise M. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1705 NOTICE of Consent of Shelly R. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1706 NOTICE of Consent of Wanda King by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1707 NOTICE of Consent of Mary Louise Mackey by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1708 NOTICE of Consent of Shirley Randle Parks by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1709 NOTICE of Consent of Kandy D. Planco by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1710 NOTICE of Consent of Kimberly Prock by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1711 NOTICE of Consent of Rosemary J. Stombaugh by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1712 NOTICE of Consent of Louise Vandercar by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1713 NOTICE of Consent of Robert N. Wilson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1714 NOTICE of Consent of Eddie C. Wu by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1715 NOTICE of Consent of Toby Young by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1716 NOTICE of Consent of Judith S. Ballesteros by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1717 NOTICE of Consent of Raymond Lydale Campbell by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1718 NOTICE of Consent of Noemi Caraballo by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1719 NOTICE of Consent of Allen H. Dandeneau by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1720 NOTICE of Consent of Mark Dowell by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1721 NOTICE of Consent of Gloria Mae Hughes by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1722 NOTICE of Consent of Thomas J. Lipari by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1723 NOTICE of Consent of Douglas S. MacLean by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1724 NOTICE of Consent of David L. McLaughlin by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1725 NOTICE of Consent of Joan A. Molek by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1726 NOTICE of Consent of Christopher R. Nichols by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1727 NOTICE of Consent of William J. Overley by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1728 NOTICE of Consent of Timothy Parker−Price by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1729 NOTICE of Consent of William Raaf by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1730 NOTICE of Consent of Mark J. Saxton by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1731 NOTICE of Consent of Cheryl Ann Hall Stillwell by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1732 NOTICE of Consent of Jacqueline Taylor by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1733 NOTICE of Consent of Sherri L. Tubbs by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1734 NOTICE of Consent of Johnnie Mae Walker by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1735 NOTICE of Consent of Jane Ann Zolotor by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1736 NOTICE of Consent of Patricia A. Barrett by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1737 NOTICE of Consent of Dennis Christy by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1738 NOTICE of Consent of Willie F. Cosby by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1739 NOTICE of Consent of LaNeishae V. Edison by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1740 NOTICE of Consent of Marie Edwards by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1741 NOTICE of Consent of Jacklynn D. Goforth by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1742 NOTICE of Consent of Carldene Green by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1743 NOTICE of Consent of Ellen S. Hare by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1744 NOTICE of Consent of John Anthony Kaye by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1745 NOTICE of Consent of David G. Kern by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1746 NOTICE of Consent of Steve Lacey by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1747 NOTICE of Consent of Jeanette Kathryn Saunders by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1748 NOTICE of Consent of Barbara Schoenberger by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1749 NOTICE of Consent of Manuel A. Torrez by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1750 NOTICE of Consent of Ethel Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1751 NOTICE of Consent of Carla Raye Waddy by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1752 NOTICE of Consent of Nancy L. Wallace by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1753 NOTICE of Consent of J.C. Weathersby by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1754 NOTICE of Consent of Brenda Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1755 NOTICE of Consent of Candis Yarsulik by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1756 NOTICE of Consent of Catherine Ann Anzick by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1757 NOTICE of Consent of Charles A. Bell by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1758 NOTICE of Consent of Evelyn Faye Berry by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1759 NOTICE of Consent of Larry A. Capps by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1760 NOTICE of Consent of Sandra Kay Charles by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1761 NOTICE of Consent of Barbara Anne Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1762 NOTICE of Consent of Julio J. Di Palma by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1763 NOTICE of Consent of Suzanne Fee by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1764 NOTICE of Consent of Betty K. Fletcher by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1765 NOTICE of Consent of Curtis Ann Herbert by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1766 NOTICE of Consent of Theodore P. Hoagland by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1767 NOTICE of Consent of Ronald L. Hons by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1768 NOTICE of Consent of Jackie R. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1769 NOTICE of Consent of Karen Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1770 NOTICE of Consent of Timothy C. Newcomb by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1771 NOTICE of Consent of Betty J. Snowden by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1772 NOTICE of Consent of Thomas C. Stanfield by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1773 NOTICE of Consent of Richard L. Thomas by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1774 NOTICE of Consent of Mark Allen Triplett by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1775 NOTICE of Consent of Steven A. Young by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1776 NOTICE of Consent of Joyce Ann Bixler by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1777 NOTICE of Consent of Dayna Bozile by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1778 NOTICE of Consent of Randall D. Crabtree by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1779 NOTICE of Consent of Heidi H. Dupre by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1780 NOTICE of Consent of Debbie Evans−Guillen by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1781 NOTICE of Consent of Bruce J. Freitas by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1782 NOTICE of Consent of John L. Hale by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1783 NOTICE of Consent of Charles Richard Keene by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1784 NOTICE of Consent of Berrie B. Lawson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1785 NOTICE of Consent of Robert Delano Lerch by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1786 NOTICE of Consent of Richard E. Pendleton by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1787 NOTICE of Consent of Mike Stephen Perkins by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1788 NOTICE of Consent of Mary Jeanne Ratway by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1789 NOTICE of Consent of Mary Anne Read by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1790 NOTICE of Consent of Carl E. Robinson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1791 NOTICE of Consent of Janet Seamon by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1792 NOTICE of Consent of Carol Waggener by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1793 NOTICE of Consent of Jeffrey Wagner by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1794 NOTICE of Consent of Janet Lynn Weller by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1795 NOTICE of Consent of Leslie Westland by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1796 NOTICE of Consent of Michael Battin by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1797 NOTICE of Consent of Janice Bishop by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1798 NOTICE of Consent of Joseph L. Browne by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1799 NOTICE of Consent of Terri G. Christian by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1800 NOTICE of Consent of Kenneth Corniello by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1801 NOTICE of Consent of James Lee Fisk by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1802 NOTICE of Consent of James E. Hinds by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1803 NOTICE of Consent of Maynard M. Kealiher by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1804 NOTICE of Consent of Willie Maudeen Miles by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1805 NOTICE of Consent of Brenda B. Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1806 NOTICE of Consent of John R. Mueller by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1807 NOTICE of Consent of Brenda Lynette Newman by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1808 NOTICE of Consent of Eugene Rainville by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)

10/11/2004 1809 NOTICE of Consent of Betty F. Richards by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1810 NOTICE of Consent of Richard L. Roberson by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1811 NOTICE of Consent of Janet M. Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1812 NOTICE of Consent of Michael F. Santillo by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1813 NOTICE of Consent of Peggy Crenshaw Talbott by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1814 NOTICE of Consent of Leonard Weinberg by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/11/2004 1815 NOTICE of Consent of Suzanne Woods by Shirley Williams (Dennis, Stephen) (Entered: 10/11/2004)
10/12/2004 1816 NOTICE of Consent of Ronald J. Aitken, Sr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1817 NOTICE of Consent of Cynthia L. Beatty by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1818 NOTICE of Consent of Steven M. Bohlander by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1819 NOTICE of Consent of Diana Duncan by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1820 NOTICE of Consent of Ernest Boyd Erlbeck, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1821 NOTICE of Consent of DiAnna Thomas Etheridge by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1822 NOTICE of Consent of Byron J. Folse by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1823 NOTICE of Consent of Cathe Frantz by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1824 NOTICE of Consent of Sue Anne Fulton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1825 NOTICE of Consent of Monique Guadalupe by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1826 NOTICE of Consent of John K. Hickman by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1827 NOTICE of Consent of Ann K. Hicks by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1828 NOTICE of Consent of Randall L. Lasiter by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1829 NOTICE of Consent of J. Kevan Norris by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1830 NOTICE of Consent of Mark Schaefer by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1831 NOTICE of Consent of David Senator by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1832 NOTICE of Consent of Alexandra Szykowny by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)

10/12/2004 1833 NOTICE of Consent of Ed Troop by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1834 NOTICE of Consent of Jerry Lee Winchell by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1835 NOTICE of Consent of Mitchell J. Adams by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1836 NOTICE of Consent of Richard C. Anglada by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1837 NOTICE of Consent of Walter D. Bennett by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1838 NOTICE of Consent of Paulette D. Bowen by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1839 NOTICE of Consent of Michael G. Butts by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1840 NOTICE of Consent of Pamela S. Byers by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1841 NOTICE of Consent of Marybeth Chis by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1842 NOTICE of Consent of Richard L. Eaton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1843 NOTICE of Consent of Antonio Flaquer by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1844 NOTICE of Consent of Paul A. Juarez by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1845 NOTICE of Consent of Evelyn Marie Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1846 NOTICE of Consent of Patty Jo Lynch by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1847 NOTICE of Consent of Edward P. Megrant by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1848 NOTICE of Consent of Patricia S. O'Donnell by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1849 NOTICE of Consent of Brenda Oliver by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1850 NOTICE of Consent of Denise Rodriguez by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1851 NOTICE of Consent of Debra L. Sharts by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1852 NOTICE of Consent of Carole Ann Spiller by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1853 NOTICE of Consent of Jay C. Swisher, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1854 NOTICE of Consent of Audry Marie Wise by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1855 NOTICE of Consent of Irma Ames by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1856 NOTICE of Consent of JoAnne Bloxham by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1857 NOTICE of Consent of Robert Diaz by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1858 NOTICE of Consent of Candis Kay Dolan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1859 NOTICE of Consent of Pamela W. Forehand by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1860 NOTICE of Consent of Susan Marie Forget by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1861 NOTICE of Consent of Dennis L. Gill by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1862 NOTICE of Consent of Brenda P. Graves by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1863 NOTICE of Consent of Sally Ann Grossi by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1864 NOTICE of Consent of Dianne Vines Hamdan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1865 NOTICE of Consent of Brenda D. Head by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1866 NOTICE of Consent of Judith I. Howard by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1867 NOTICE of Consent of Gerald Robert Mersing by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1868 NOTICE of Consent of Paula Nourse by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1869 NOTICE of Consent of Maria E. Oliva by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1870 NOTICE of Consent of Steve W. Petty by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1871 NOTICE of Consent of Victor Preddie by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1872 NOTICE of Consent of Sally D. Preston by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1873 NOTICE of Consent of Vernita Preston by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1874 NOTICE of Consent of Charles J. Sandberg by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1875 NOTICE of Consent of Kathleen E. Alloune by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1876 NOTICE of Consent of Carol Alvarez by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1877 NOTICE of Consent of Lynwood C. Bowen, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1878 NOTICE of Consent of Margaret R. Capone by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1879 NOTICE of Consent of Martha R. Custer by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1880 NOTICE of Consent of Edward F. Hassman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1881 NOTICE of Consent of Judith M. Hickman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1882 NOTICE of Consent of Jeffery E. Huffman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1883 NOTICE of Consent of Alimamy G. Kargbo by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1884 NOTICE of Consent of Mark J. Linde by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1885 NOTICE of Consent of Grace Diane Marott by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1886 NOTICE of Consent of Dianne Martin by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1887 NOTICE of Consent of Susan Q. Mason by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1888 NOTICE of Consent of Laurie M. Ortiz by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1889 NOTICE of Consent of Kathy M. Pine by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1890 NOTICE of Consent of Julia J. Reitzes by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1891 NOTICE of Consent of Norman M. Snow by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1892 NOTICE of Consent of Barbara A. Snowden by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1893 NOTICE of Consent of Diana M. Strickland by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1894 NOTICE of Consent of Mickey Thomas by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1895 NOTICE of Consent of Juanita F. Ambristee by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1896 NOTICE of Consent of Martin B. Bishop by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1897 NOTICE of Consent of Hal Boggess by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1898 NOTICE of Consent of Dennis P. Callahan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1899 NOTICE of Consent of Larry W. Davis by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1900 NOTICE of Consent of Faye Ellen Dornan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1901 NOTICE of Consent of Charles E. Ebner by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1902 NOTICE of Consent of Sherri Fasse by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1903 NOTICE of Consent of Carl L. Grady by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1904 NOTICE of Consent of Kimberly Hartzell by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1905 NOTICE of Consent of Linda Henderson by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1906 NOTICE of Consent of Jack Hyndman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1907 NOTICE of Consent of Doreen M. Ledig by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1908 NOTICE of Consent of Donna S. Mackey by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1909 NOTICE of Consent of Richard G. McPheeters by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1910 NOTICE of Consent of Jacqueline M. Minne by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1911 NOTICE of Consent of Nettie Rosner Schait by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1912 NOTICE of Consent of Marilynn Y. Smallwood by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1913 NOTICE of Consent of Tammy L. Turner by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1914 NOTICE of Consent of Debbie S. Vital by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1915 NOTICE of Consent of Karen J. Andre by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1916 NOTICE of Consent of Yvonne Adele Bennett by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1917 NOTICE of Consent of Barbara Brown by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1918 NOTICE of Consent of Herbert Campbell by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1919 NOTICE of Consent of Susan L. Cunningham by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1920 NOTICE of Consent of Betty H. Dorrity by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1921 NOTICE of Consent of Christine Evelyn Monticue by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1922 NOTICE of Consent of Arya Vir Pathria by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1923 NOTICE of Consent of Carlton Lewis Payne by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1924 NOTICE of Consent of William Robert Payne by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1925 NOTICE of Consent of Cheryl Rollwagen by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1926 NOTICE of DongJean Schin by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1927 NOTICE of Consent of Katherine E. Sellers by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1928 NOTICE of Consent of Ann Miles Shelly by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1929 NOTICE of Consent of Natalie Slade by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1930 NOTICE of Consent of Cathy Thurston−Seignious by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1931 NOTICE of Consent of E. Jean Wright by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1932 NOTICE of Consent of Rosalyn F. Wright by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1933 NOTICE of Consent of Debra G. Zissis by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1934 NOTICE of Consent of Susan Allen by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004

1935

ORDER granting 798 and 801 Motions to Appear Pro Hac Vice. Tamara M. Spicer and Harry B. Wilson are granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a registration form at www.ksd.uscourts.gov/features/forms/pdfforms/efilereg.pdf. Signed by Magistrate Judge David J. Waxse on 10/12/04. (mg) (Entered: 10/12/2004)

10/12/2004 1936 NOTICE of Consent of Richard N. Barraco by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1937 NOTICE of Consent of Felix Berenguer by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1938 NOTICE of Consent of Eugene Michael Gaughan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1939 NOTICE of Consent of Richard L. Green by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1940 NOTICE of Mary O. Hodge by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1941 NOTICE of Consent of Gwen C. Johnson by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1942 NOTICE of Consent of Daniel J. Kohlrieser by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1943 NOTICE of David S. MacNamara by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1944 NOTICE of Consent of Richard G. Maronay by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1945 NOTICE of Consent of Thomas B. McCulloch, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1946 NOTICE of Consent of David Lee Molinaro by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1947 NOTICE of Consent of Delores Ellen Neis by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1948 NOTICE of Consent of Joaquin Porras by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1949 NOTICE of Consent of David A. Pressell by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1950 NOTICE of Consent of Luis Rodriguez by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1951 NOTICE of Consent of Susan Marie Schwartz by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1952 NOTICE of Consent of Brenda Tatum by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1953 NOTICE of Consent of Sharon Faye Vogelsong by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1954 NOTICE of Consent of Angela Byrd Wilson by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1955 NOTICE of Consent of Harold Bradshaw by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1956 NOTICE of Consent of Brenda Sue Bryan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1957 NOTICE of Consent of Arnie L. Dales by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1958 NOTICE of Consent of Adrianne Elizabeth Ford by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1959 NOTICE of Consent of Clinton L. Heintzelman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1960 NOTICE of Consent of Chris Lewis by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1961 NOTICE of Consent of Beth A. Mann by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1962 NOTICE of Consent of Alan L. Matthews, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1963 NOTICE of Consent of Donna S. McCoy by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1964 NOTICE of Consent of Michael R. Mears by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1965 NOTICE of Consent of Gale Meyer by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1966 NOTICE of Consent of Theresa A. Moore by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1967 NOTICE of Consent of Jill Ann Newman by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1968 NOTICE of Consent of Wayne Obidowicz by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1969 NOTICE of Consent of Timothy John O'Brien by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1970 NOTICE of Consent of Molly R. Parker by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1971 NOTICE of Consent of Richard Dean Piercy by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1972 NOTICE of Consent of Gerald E. Purinton by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1973 NOTICE of Consent of Yuk−Wa Suen by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1974 NOTICE of Consent of Loretta E. Tyre by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1975 NOTICE of Consent of Susan Odette Acevedo by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1976 NOTICE of Consent of Sonja M. Allen by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1977 NOTICE of Consent of Kathy L. Bell by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1978 NOTICE of Consent of Brent Branley by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1979 NOTICE of Consent of Gordon F. Clark by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1980 NOTICE of Consent of Jerald Alan Bethke by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1981 NOTICE of Consent of Shirley W. Francis by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1982 NOTICE of Consent of Johnny W. Giles by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1983 NOTICE of Consent of Fred R. Boughton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1984 NOTICE of Consent of Roger H. Hempeck by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1985 NOTICE of Consent of Henry J. Holst, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1986 NOTICE of Consent of Clifford E. McGeehon by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1987 NOTICE of Consent of Elvis Lloyd Morehead, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1988 NOTICE of Consent of Michael C. Notarianni by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1989 NOTICE of Consent of Debora G. Padgett by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1990 NOTICE of Consent of Lee Poindexter by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1991 NOTICE of Consent of Juliann Radford by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1992 NOTICE of Consent of Francis Xavier Saucedo by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1993 NOTICE of Consent of Michael Schlobohm by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1994 NOTICE of Consent of Ronald J. Schmidt by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1995 NOTICE of Consent of Richard E. Scott, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 1996 NOTICE of Consent of Robert Todd Cohen by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1997 NOTICE of Consent of Barbara B. Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 1998 NOTICE of Consent of Linda W. Shields by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 1999 NOTICE of Consent of Merrill G. Detweiler by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2000 NOTICE of Consent of Gale Lee Dorman by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2001 NOTICE of Consent of Judy M. Stephens by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2002 NOTICE of Consent of Michael L.J. Downer by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2003 NOTICE of Consent of Javier Fernandez by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2004 NOTICE of Consent of Kenneth Lee Gregory by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2005 NOTICE of Consent of Richard S. Hill by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2006 NOTICE of Consent of Bruce H. Hogan Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2007 NOTICE of Consent of Nancy Horton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2008 NOTICE of Consent of Purushottam V. Kamat by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2009 NOTICE of Consent of Raymond J. Lewis by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2010 NOTICE of Consent of Markus E. Merrill by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2011 NOTICE of Consent of Leon H. Simpkins by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2012 NOTICE of Consent of Lynette D. Tolar by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2013 NOTICE of Consent of Judy J. Watson by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2014 NOTICE of Consent of Yoshikazu Yamada by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2015 NOTICE of Consent of Anne L. Aalderink by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2016 NOTICE of Consent of Ronnie Graham Cashwell by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2017 NOTICE of Consent of Diane D. Franklin by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2018 NOTICE of Consent of Carolyn Hardin by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2019 NOTICE of Consent of Belinda J. Jackson−Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2020 NOTICE of Consent of Barbara L. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2021 NOTICE of Consent of Leonard D. Klamm by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2022 NOTICE of Consent of Paul Nicholas Mastel by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)

10/12/2004 2023 NOTICE of Consent of Lourdes A. Perez by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2024 NOTICE of Consent of Thomas Anthony Albanese by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2025 NOTICE of Consent of James E. Prime by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2026 NOTICE of Consent of Charolette B. Reeder by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2027 NOTICE of Consent of Dean Axford by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2028 NOTICE of Consent of Ellen Carter Reeves by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2029 NOTICE of Consent of Brent Conte by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2030 NOTICE of Consent of Carole Karron Rynston by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2031 NOTICE of Consent of Cheyenne Thomas by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2032 NOTICE of Consent of Kimberly DeCamp by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2033 NOTICE of Consent of Pelagio Del Mar, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2034 NOTICE of Consent of Pamela Turner by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2035 NOTICE of Consent of Dorothy Joan Duncan by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2036 NOTICE of Consent of Ronald S. Beaton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2037 NOTICE of Consent of Thomas Lee Fenton by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2038 NOTICE of Consent of Theresa L. Cassity by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2039 NOTICE of Consent of Patricia A. Decker by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2040 NOTICE of Consent of Paul Joseph Flake by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2041 NOTICE of Consent of Marcia Dorothy Dominguez by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2042 NOTICE of Consent of Tim D. Elliott by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2043 NOTICE of Consent of Stephen C. Gilbert by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2044 NOTICE of Consent of Zoe Ann Freeland by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2045 NOTICE of Consent of Steven Hanoski by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2046 NOTICE of Consent of Calaine Griggs by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)

10/12/2004 2047 NOTICE of Consent of Rona Sozanne Hartwick by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2048 NOTICE of Consent of Margaret H. Hay by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2049 NOTICE of Consent of Marjorie A. Hattrup by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2050 NOTICE of Consent of Robert Eugene Hudson Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2051 NOTICE of Consent of Kirk T. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2052 NOTICE of Consent of Sandra F. Jolly by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2053 NOTICE of Consent of Marilyn S. Lankard by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2054 NOTICE of Consent of Dare W. Little by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2055 NOTICE of Consent of Roxanne Miles by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2056 NOTICE of Consent of Stephen Ray McWilliams by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2057 NOTICE of Consent of Robert C. Miller by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2058 NOTICE of Consent of Evelyn G. Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2059 NOTICE of Consent of Patricia L. Pauscher by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2060 NOTICE of Consent of Arik Pollak by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2061 NOTICE of Consent of Deborah S. Scott by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2062 NOTICE of Consent of Joseph Robbins, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2063 NOTICE of Consent of James L. Siders by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2064 NOTICE of Consent of Caren J. Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2065 NOTICE of Consent of Sylvia A. Trevino by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2066 NOTICE of Consent of Charles Whitman Stephens Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2067 NOTICE of Consent of Peggy Sue Timms by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2068 NOTICE of Consent of Ahmed Omar Adaweh by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2069 NOTICE of Consent of Denise Vanausdoll by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2070 NOTICE of Consent of Terri−Lynn Bartolome by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)

10/12/2004 2071 NOTICE of Consent of Connie Woody Blackburn by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2072 NOTICE of Consent of James W. White by Shirley Williams (Egan, Dennis) (Entered: 10/12/2004)
10/12/2004 2073 NOTICE of Consent of Agnes C. Boyd by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2074 NOTICE of Consent of Teryl E. Casey by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2075 NOTICE of Consent of Randy W. Eaton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2076 NOTICE of Consent of Gloria J. Elix by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2077 NOTICE of Consent of Richard P. Freni by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2078 NOTICE of Consent of Gerard R. Gagnier by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2079 NOTICE of Consent of Maria V. Graffeo by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2080 NOTICE of Consent of LaMarl Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2081 NOTICE of Consent of Frank Ikpeze by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2082 NOTICE of Consent of Robert Kestner by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2083 NOTICE of Consent of William R. Lerand by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2084 NOTICE of Consent of Rafael Lorie by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2085 NOTICE of Consent of Linda McGann by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2086 NOTICE of Consent of Roger Newton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2087 NOTICE of Consent of Karen Pence (Rosenzweig) by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2088 NOTICE of Consent of Floyd B. Summa by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2089 NOTICE of Consent of Catherine Mary Wood by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2090 NOTICE of Consent of David L. Borreson by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2091 NOTICE of Consent of Russell H. Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2092 NOTICE of Consent of Mark Browne by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2093 NOTICE of Consent of Lydia Ann Burton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2094 NOTICE of Consent of James Frank Gandy Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)

10/12/2004 2095 NOTICE of Consent of Eduardo S. Garrido by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2096 NOTICE of Consent of Albert L. Goodwin by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2097 NOTICE of Consent of Clifford M. Hallock by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2098 NOTICE of Consent of Michael R. Hart by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2099 NOTICE of Consent of John R. Hegstrom by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2100 NOTICE of Consent of Mary Ellen Jaeger by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2101 NOTICE of Consent of Diane L. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2102 NOTICE of Consent of Susan E. Lejserowits by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2103 NOTICE of Consent of Robert Loughbom Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2104 NOTICE of Consent of Trudy L. Newton by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2105 NOTICE of Consent of Judy K. Novosel by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2106 NOTICE of Consent of Mercy Porter by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2107 NOTICE of Consent of Ysabel Sanchez Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2108 NOTICE of Consent of Ruth M. Stepien by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/12/2004 2109 NOTICE of Consent of Gradietta B. Woods by Shirley Williams (Dennis, Stephen) (Entered: 10/12/2004)
10/13/2004 2110 NOTICE of Consent of Gregory Lee Chapman by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2111 NOTICE of Consent of Ronald Ciampolillo by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2112 NOTICE of Consent of Emily H. Fong by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2113 NOTICE of Consent of Katherine S. Fowler by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2114 NOTICE of Consent of Terry M. Gunnell by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2115 NOTICE of Consent of Therese Ann Hearl by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2116 NOTICE of Consent of Karen L. Henderson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2117 NOTICE of Consent of Cynthia Ann Lackner by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2118 NOTICE of Consent of Debra A. Marsh by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2119 NOTICE of Consent of Michael L. Marshall by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2120 NOTICE of Consent of Kelly S. Murphy by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2121 NOTICE of Consent of Treston R. Perkins by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2122 NOTICE of Consent of Richard A. Ritari by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2123 NOTICE of Consent of Steven Victor Roland by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2124 NOTICE of Consent of Nancy B. Sherrill by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2125 NOTICE of Consent of Anna L. Sipe by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2126 NOTICE of Consent of Michael Smolen by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2127 NOTICE of Consent of Mark G. vonHausen by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2128 NOTICE of Consent of Berniece Branch Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2129 NOTICE of Consent of Ferna P. Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2130 NOTICE of Consent of Ernest Alvarez by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2131 NOTICE of Consent of Patricia Ona Barnett by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2132 NOTICE of Consent of Arnetta R. Conley by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2133 NOTICE of Consent of Peter H. Duspiva by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2134 NOTICE of Consent of Tracy Ann Dykes by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2135 NOTICE of Consent of Ruth Fair by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2136 NOTICE of Consent of Tunja Jewel Gardner by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2137 NOTICE of Consent of John A. Hultquist Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2138 NOTICE of Consent of Raymond C. Kirtland by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2139 NOTICE of Consent of Kristine Marie Lehane by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2140 NOTICE of Consent of Frederick R. Merz by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2141 NOTICE of Consent of Shirley Morris by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2142 NOTICE of Consent of Colleen L. Neill by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2143 NOTICE of Consent of Therese Rigano by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2144 NOTICE of Consent of Ricque L. Robinson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2145 NOTICE of Consent of Dianne E. Sams by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2146 NOTICE of Consent of Gregory J. Scott by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2147 NOTICE of Consent of Patricia J. Sheets by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2148 NOTICE of Consent of James A. Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2149 NOTICE of Consent of Clifford P. Wright Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2150 NOTICE by All Plaintiffs of taking deposition of Dan Fogleman on 10/21/2004. (Meyers, Martin) (Modified on 10/21/2004 to remove the list of all planitiffs' names. (mg)) (Entered: 10/13/2004)
10/13/2004 2151 NOTICE of Consent of Christopher D. Blalock by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2152 NOTICE of Consent of Nancy A. Budd by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2153 NOTICE of Consent of Karen E. Campbell by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2154 NOTICE of Consent of Garrett Kent Carpenter by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2155 NOTICE of Consent of William A. Chance by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2156 NOTICE of Consent of James G. DiDio by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2157 NOTICE of Consent of Barry Ferrell by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2158 NOTICE of Consent of Fellman George, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2159 NOTICE of Consent of Philip J. Gooselaw by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2160 NOTICE of Consent of Rochelle Hawkins by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2161 NOTICE of Consent of Deborah M. Hufnagel by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2162 NOTICE of Consent of Curtis L. Humphries by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2163 NOTICE of Consent of Robin Lee Karres by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2164 NOTICE of Consent of Deborah S. Kistner by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2165 NOTICE of Consent of Richard J. McCune by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2166 NOTICE of Consent of Carol S. Povolish by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2167 NOTICE of Consent of James Curtis Proctor, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2168 NOTICE of Consent of Christina Siemens by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2169 NOTICE of Consent of Edwin J. Terry by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2170 NOTICE of Consent of Linda S. Wilkerson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2171 NOTICE of Consent of Randal Blough by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2172 NOTICE of Consent of Eva Carter by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2173 NOTICE of Consent of Gloria M. Fisher by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2174 NOTICE of Consent of Latifah N. Hisham by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2175 NOTICE of Consent of Deborah Lynn Klundt by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2176 AMENDED NOTICE by All Plaintiffs of taking deposition of John Fogleman on 10/21/2004. (Meyers, Martin) (Modified on 10/21/2004 to remove names of all listed plaintiffs. (mg)) (Entered: 10/13/2004)
10/13/2004 2177 NOTICE of Consent of Toni Marie Lewis by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2178 NOTICE of Consent of William D. Lewis by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2179 NOTICE of Consent of James R. Lord by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2180 NOTICE of Consent of Frank F. Luppens by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2181 NOTICE of Consent of Diane A. Marciel by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2182 NOTICE of Consent of Laura F. Mixon by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2183 NOTICE of Consent of Jeffrey A. Nispel by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2184 NOTICE of Consent of Mitchell L. Nutterfield by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2185 NOTICE of Consent of Steven Pepper by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2186 NOTICE of Consent of Douglas B. Roberson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2187 NOTICE of Consent of Lloyd E. Sanders by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2188 NOTICE of Consent of Joy L. Saxton by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2189 NOTICE of Consent of Cynthia J. Shaffer by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2190 NOTICE of Consent of Anthony R. Sosa by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2191 NOTICE of Consent of Ruben J. Zaragoza by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2192 NOTICE of Consent of Laurie A. Aguilar by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2193 NOTICE of Consent of Shirley A. Bassett by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2194 NOTICE of Consent of Catherine A. Berzinski by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2195 NOTICE of Consent of Annie M. Burton by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2196 NOTICE of Consent of Catherine Cuevas by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2197 NOTICE of Consent of Edna H. Davis by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2198 NOTICE of Consent of Donald A. Fedge by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2199 NOTICE of Consent of Marcie A. Kenley by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2200 NOTICE of Consent of Mary Elizabeth Lacy by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2201 NOTICE of Consent of Frank J. Matranga by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2202 NOTICE of Consent of Georgia McCormack by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2203 NOTICE of Consent of Darryl A. Miller by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2204 NOTICE of Consent of Debra Lynn Mitcham by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2205 NOTICE of Consent of Ellen M. Perkett by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2206 NOTICE of Consent of Alan F. Steinbrecher by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2207 NOTICE of Consent of Jerry Lynn Tomlinson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2208 NOTICE of Consent of Deborah L. Vaughan by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2209 NOTICE of Consent of Pamela Janice Vicchio−Cabral by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2210 NOTICE of Consent of Charlotte Weissman by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2211 NOTICE of Consent of Randy H. Yates by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2212 NOTICE of Consent of Linda S. Bardot by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2213 NOTICE of Consent of Carolyn Jo Bednarz by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2214 NOTICE of Consent of Gregory M. Bolinski by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2215 NOTICE of Consent of Donald E. Contreras by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2216 NOTICE of Consent of Frederic G. Fischer by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2217 NOTICE of Consent of Kenneth T. Fu by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2218 NOTICE of Consent of Daniel R. Honeycutt by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2219 NOTICE of Consent of David Hulbert by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2220 NOTICE of Consent of Rasiah Alfred Jey by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2221 NOTICE of Consent of Isaac W. Lamm by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2222 NOTICE of Consent of Thomas Lewis Long by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2223 NOTICE of Consent of Charles Agee by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2224 NOTICE of Consent of Harold G. Baumhardt by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2225 NOTICE of Consent of Linda N. McElroy by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2226 NOTICE of Consent of Robert George Bibbings, II by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2227 NOTICE of Consent of Nancy B. Newlin by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2228 NOTICE of Consent of Thomas Bilvin by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2229 NOTICE of Consent of Debra Sharlene Olson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2230 NOTICE of Consent of Vivian S. Carter by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2231 NOTICE of Consent of Pamela Sanchez by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2232 NOTICE of Consent of Sherry Drury by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2233 NOTICE of Consent of Bruce Sidener by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2234 NOTICE of Consent of Deborah A. Theno by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2235 NOTICE of Consent of Larry Fultz by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2236 NOTICE of Consent of Jacqueline Ann Tyre by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2237 NOTICE of Consent of Carol A. Gabriel by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2238 NOTICE of Consent of Jessica A. Vinzant by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2239 NOTICE of Consent of Roger Geimer by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2240 NOTICE of Consent of Carol Ann Zumbrunn by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2241 NOTICE of Consent of Evelyn P. Harris by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2242 NOTICE of Consent of Gene M. Haskins by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2243 NOTICE of Consent of Nina Hollowell by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2244 NOTICE of Consent of Ada Carol Keene by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2245 NOTICE of Consent of Bruce Krueger by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2246 NOTICE of Consent of Russell A. Payton, Sr. by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2247 NOTICE of Consent of Wilfredo Aleman by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2248 NOTICE of Consent of Dori M. Porche by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2249 NOTICE of Consent of Andre P. Rack by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2250 NOTICE of Consent of John Adamson Beall by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2251 NOTICE of Consent of Mark W. Simmons by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2252 NOTICE of Consent of Karen Turner by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2253 NOTICE of Consent of Charles Curtis Blake by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2254 NOTICE of Consent of Rosemary E. Weidler by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2255 NOTICE of Consent of Nichole Bledsoe−Wise by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2256 NOTICE of Consent of Teresa J. Blevins by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2257 NOTICE of Consent of Christopher O. Dougherty by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2258 NOTICE of Consent of Stephen L. Eastridge by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2259 NOTICE of Consent of Peter Ellsworth by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2260 NOTICE of Consent of Kathy M. Hill by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2261 NOTICE of Consent of Kenneth Hoeflich by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2262 NOTICE of Consent of Duane S. Koziel by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2263 NOTICE of Consent of Frances A. Lindholm by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2264 NOTICE of Consent of James R. McVicker by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2265 NOTICE of Consent of Cheryl Lynn Messenger by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2266 NOTICE of Consent of Sherryl Ann Nealy by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2267 NOTICE of Consent of Kenneth Roy Newell by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2268 NOTICE of Consent of Dianne M. Nunez by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2269 NOTICE of Consent of Adele Pearson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2270 NOTICE of Consent of Frederick D. Raby by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2271 NOTICE of Consent of Richard A. Wright, Sr. by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2272 NOTICE of Consent of Ann Marie Carney Adams by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2273 NOTICE of Consent of Carl Trent Alexander by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2274 NOTICE of Consent of Joyce E. Anderson by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2275 NOTICE of Consent of Mark H. Cohen by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2276 NOTICE of Consent of Barbara L. Cook by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2277 NOTICE of Consent of Larry L. Coyle by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2278 NOTICE of Consent of Barbara Ann DeMarie by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2279 NOTICE of Consent of Lee G. Hampshire by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2280 NOTICE of Consent of Betsy B. Krueger by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2281 NOTICE of Consent of Jo McCuaig Lillig by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2282 NOTICE of Consent of Joan Macewich by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2283 NOTICE of Consent of Michael P. Murphy by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2284 NOTICE of Consent of Terry A. Phillips by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)

10/13/2004 2285 NOTICE of Consent of Linda Ann Pilgreen by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2286 NOTICE of Consent of Esperanza Riojas by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2287 NOTICE of Consent of Ronald E. Sieve by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2288 NOTICE of Consent of Joyce B. Simmons by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2289 NOTICE of Consent of Leah Velasquez by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2290 NOTICE of Consent of Joanna Welch by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2291 NOTICE of Consent of Marsha A. Willyard by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2292 NOTICE of Consent of Julia Atkeisson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2293 NOTICE of Consent of Pamela Barbieri by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2294 NOTICE of Consent of Daniel J. Chapman by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2295 NOTICE of Consent of Rachel D. Coleman by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2296 NOTICE of Consent of Mary Susan Cook by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2297 NOTICE of Consent of Patricia S. Cash by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2298 NOTICE of Consent of Daniel Burton Gilliam by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2299 NOTICE of Consent of Timothy Markham Goff by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2300 NOTICE of Consent of Leticia C. Gonzalez by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2301 NOTICE of Consent of Patricia A. Hammon by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2302 NOTICE of Consent of Abraham M. Harding by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2303 NOTICE of Consent of Janet C. Hawkins by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2304 NOTICE of Consent of Richard M. Daniel by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2305 NOTICE of Consent of Cynthia S. Ellis by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2306 NOTICE of Consent of Alice Marie Helt by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2307 NOTICE of Consent of Robert Cecil Horne, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2308 NOTICE of Consent of Teresa C. Espinoza by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2309 NOTICE of Consent of Michael J. Frymyer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2310 NOTICE of Consent of Ruth A. Jobe by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2311 NOTICE of Consent of Min Liu by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2312 NOTICE of Consent of Jacqueline Luczak by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2313 NOTICE of Consent of Cynthia Gordon by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2314 NOTICE of Consent of Kristina Wood Lunde by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2315 NOTICE of Consent of Mark D. Hagen by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2316 NOTICE of Consent of Gary Lee Houston by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2317 NOTICE of Consent of David Eli Kanode by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2318 NOTICE of Consent of Diane Reaties McClinton by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2319 NOTICE of Consent of Phillip J. Karanauskas by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2320 NOTICE of Consent of Leo Joseph Kwalik by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2321 NOTICE of Consent of Mary Lee McNamara by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2322 NOTICE of Consent of Daryl Mackay by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2323 NOTICE of Consent of James Christopher Robison by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2324 NOTICE of Consent of Shauna S. Simmons by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2325 NOTICE of Consent of Sharon J. Moore by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2326 NOTICE of Consent of James R. Smoker II by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2327 NOTICE of Consent of Douglas Patrick by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2328 NOTICE of Consent of Brayton White by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2329 NOTICE of Consent of Caroline Takahashi by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2330 NOTICE of Consent of Phil S. Ardoin by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2331 NOTICE of Consent of Kelly Lynn Boyd by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2332 NOTICE of Consent of John T. Dudley by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2333 NOTICE of Consent of Gary E. Thomas by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2334 NOTICE of Consent of Theresa Ferrini by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2335 NOTICE of Consent of C. Michael Finnell by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2336 NOTICE of Consent of Sherry A. Thomas by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2337 NOTICE of Consent of Charles L. Garrison by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2338 NOTICE of Consent of Gary R. Goolsby by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2339 NOTICE of Consent of Robert G. Hannaway, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2340 NOTICE of Consent of Fulvia Hoffmann by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2341 NOTICE of Consent of Kelly Koop by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2342 NOTICE of Consent of Robert E. LaGrand, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2343 NOTICE of Consent of Soledad Marie Leath by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2344 NOTICE of Consent of Anita M. Lock by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2345 NOTICE of Consent of Donna E. Allman by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2346 NOTICE of Consent of Shandy McCollough by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2347 NOTICE of Consent of Joe Kevin McGowan by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2348 NOTICE of Consent of James Pat Beard by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2349 NOTICE of Consent of Jill E. Michaels by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2350 NOTICE of Consent of Willie Mack Palmer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2351 NOTICE of Consent of Phil Bodine by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2352 NOTICE of Consent of Charles F. Breininger by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2353 NOTICE of Consent of Patricia A. Ricketts by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2354 NOTICE of Consent of Pamela R. Eller by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2355 NOTICE of Consent of Dennis C. Wike by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2356 NOTICE of Consent of Debra Fields−Williams by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2357 NOTICE of Consent of Benjamin Woodrow Fincher by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2358 NOTICE of Consent of Timothy L. Armintrout by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2359 NOTICE of Consent of Joanne K. Foster by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2360 NOTICE of Consent of Virender Kumar by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2361 NOTICE of Consent of Donald Eugene Freeman by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2362 NOTICE of Consent of Michael J. Hayde by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2363 NOTICE of Consent of Jeanne D. Logan by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2364 NOTICE of Consent of Shirley Hodge by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2365 NOTICE of Consent of Gary Nolte by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2366 NOTICE of Consent of Deborah Lynn Phillips by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2367 NOTICE of Consent of Dave Janiga by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2368 NOTICE of Consent of Cortez H. Liggins by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2369 NOTICE of Consent of Peggy Sue McRedmond by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2370 NOTICE of Consent of Cheryle Moore by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2371 NOTICE of Consent of Bonnie B. Watts by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2372 NOTICE of Consent of Kenneth R. Murry by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2373 NOTICE of Consent of Carole A. Young by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2374 NOTICE of Consent of Brian R. Orner by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2375 NOTICE of Consent of Lynn M. Abud by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2376 NOTICE of Consent of Dave Compton by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2377 NOTICE of Consent of Roberta S. Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2378 NOTICE of Consent of Rich Reindel by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2379 NOTICE of Consent of Janet S. Deckard by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2380 NOTICE of Consent of John D. Toole by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)

10/13/2004 2381 NOTICE of Consent of Michael E. Tekampe by Shirley Williams (Egan, Dennis) (Entered: 10/13/2004)
10/13/2004 2382 NOTICE of Consent of Charline Whipper by Shirley Williams (Braud, Bert) (Entered: 10/13/2004)
10/13/2004 2383 NOTICE of Consent of Karen Flores−Pell by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2384 NOTICE of Consent of Michael Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2385 NOTICE of Consent of Robert E. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2386 NOTICE of Consent of Everton W. Knight by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2387 NOTICE of Consent of Robert William Kunkle by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2388 NOTICE of Consent of Dena Janetta Lee by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2389 NOTICE of Consent of William Thomas Lightfoot by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2390 NOTICE of Consent of James A. Mitchell by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2391 NOTICE of Consent of Douglas L. Neudeck by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2392 NOTICE of Consent of Kevin Leo Neuer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2393 NOTICE of Consent of Kalayla O'Connor by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2394 NOTICE of Consent of Donald W. Payne by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2395 NOTICE of Consent of Thomas Portee by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2396 NOTICE of Consent of Charles Wyane Ratliff by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2397 NOTICE of Consent of Wayne Snyder by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2398 NOTICE of Consent of Rose Woolfrey by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2399 NOTICE of Consent of James J. Aragon by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2400 NOTICE of Consent of Andre A. Begin by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2401 NOTICE of Consent of Linda Bernskoetter by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2402 NOTICE of Consent of Brenda J. Caldwell by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2403 NOTICE of Consent of John W. Dedovesh by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2404 NOTICE of Consent of Rhonda L. Dents by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2405 NOTICE of Consent of Ralph E. Evans, II by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2406 NOTICE of Consent of Ronald F. Frampton by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2407 NOTICE of Consent of Robert E. Groeger by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2408 NOTICE of Consent of Aryan Heydari by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2409 NOTICE of Consent of Kenneth E. Horner by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2410 NOTICE of Consent of Margaret A. Kennedy by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2411 NOTICE of Consent of Marla S. Lowe by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2412 NOTICE of Consent of Robert James Nielsen by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2413 NOTICE of Consent of Nicholas M. Romanich by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2414 NOTICE of Consent of Judith A. Shafer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2415 NOTICE of Consent of Laura M. Sumner by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2416 NOTICE of Consent of Pearl M. Walker by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2417 NOTICE of Consent of Glenda Wilson−Brown by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2418 NOTICE of Consent of John Wesley Wright by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2419 NOTICE of Consent of Gary J. App by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2420 NOTICE of Consent of Don Broome by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2421 NOTICE of Consent of Ken Chevasin by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2422 NOTICE of Consent of Judy E. Coughlin by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2423 NOTICE of Consent of Robert D. Ferguson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2424 NOTICE of Consent of E. Blair Ford by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2425 NOTICE of Consent of Julia W. Frei by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2426 NOTICE of Consent of Oneeda W. Gerald by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2427 NOTICE of Consent of Lee G. Haglund by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2428 NOTICE of Consent of Husain A. Hasham by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)

10/13/2004 2429 NOTICE of Consent of Fairlyon E. Hill by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2430 NOTICE of Consent of Mickey Mae Hobbs by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2431 NOTICE of Consent of Gary D. Jackson by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2432 NOTICE of Consent of Cyrus Matin−Nia by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2433 NOTICE of Consent of Ann Miller by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2434 NOTICE of Consent of Jimmie L. Norfleet by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2435 NOTICE of Consent of Robert M. Schaffer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2436 NOTICE of Consent of Thomas A. Strickland, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2437 NOTICE of Consent of Katherine A. Trummer by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2438 NOTICE of Consent of Anne Welty by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2439 NOTICE of Consent of Gary L. Bailey by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2440 NOTICE of Consent of Thomas L. Ginnick by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2441 NOTICE of Consent of Richard Leon Harris by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2442 NOTICE of Consent of Iza Pyatt by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/13/2004 2443 NOTICE of Consent of Thaddeus R. Sobon by Shirley Williams (Dennis, Stephen) (Entered: 10/13/2004)
10/14/2004 2444 NOTICE of Consent of Dave Compton by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2445 NOTICE of Consent of Karen R. Abolt by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2446 NOTICE of Consent of Jean Ann Forster by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2447 NOTICE of Consent of Roy J. Gregerson by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2448 NOTICE of Consent of Teresa Ann Hemingway by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2449 NOTICE of Consent of Michael Hinson by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2450 NOTICE of Consent of David C. Hinton by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2451 NOTICE of Consent of Lillian Hodges by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2452 NOTICE of Consent of Craig D. Jones by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)

10/14/2004 2453 NOTICE of Consent of Jerry Kwan by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2454 NOTICE of Consent of Annie Ray by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2455 NOTICE of Consent of Billie F. Smith by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2456 NOTICE of Consent of Terri Tansey by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2457 NOTICE of Consent of Michael West by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2458 NOTICE of Consent of Dan J. Chavez by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2459 NOTICE of Karen D. Cordier by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2460 NOTICE of Consent of Eve M. Crane by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2461 NOTICE of Consent of Janet Edmunds by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2462 NOTICE of Consent of James Frame by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2463 NOTICE of Consent of Barbara B. Grill by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2464 NOTICE of Consent of Susan Grissom by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2465 NOTICE of Consent of Debra G. Clark by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2466 NOTICE of Consent of Ann E. Hanlon by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2467 NOTICE of Consent of Coletta L. Staggers by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2468 NOTICE of Consent of Patricia A. Holmes by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2469 NOTICE of Consent of Danise Paula Yeager by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2470 NOTICE of Consent of Charles A. Johnson, Jr. by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2471 NOTICE of Consent of Joseph J. Lederhos by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2472 NOTICE of Consent of Vanessa Boyd Napper by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2473 NOTICE of Consent of Sunny Cyprian Onwuzuruike by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2474 NOTICE of Consent of Augustine Onyejiaka by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2475 NOTICE of Consent of Mazie M. Ratliffe−Newton by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2476 NOTICE of Consent of Christine Schmidt by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)

10/14/2004 2477 NOTICE of Consent of Kevin Walton Seydler by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2478 NOTICE of Consent of Cynthia A. Shafer by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2479 NOTICE of Consent of Dolores Soria by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2480 NOTICE of Consent of Kelly Wood by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2481 NOTICE of Consent of Andrew Burkhart by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2482 NOTICE of Consent of Sherri Lynn Chavora by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2483 NOTICE of Consent of John Conklin by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2484 NOTICE of Consent of Marcell Jeanne Estes by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2485 NOTICE of Consent of Michael J. Fairlie by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2486 NOTICE of Consent of Dean Goodwin by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2487 NOTICE of Consent of Wendy Ann Hamilton by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2488 NOTICE of Consent of Carolyn Adams Hawkins by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2489 NOTICE of Consent of Sandra Hernandez by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2490 NOTICE of Consent of Wintino B. Jones by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2491 NOTICE of Consent of Jeffrey C. Martin by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2492 NOTICE of Consent of Victor Merrekous Mitchell by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2493 NOTICE of Consent of LaVonn L. Montgomery by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2494 NOTICE of Consent of Frederick William Parkin by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2495 CERTIFICATE OF COMPLIANCE by Defendant Sprint/United Management Company With Local Rule 37.2. (Attachments: # 1 Exhibit 1 − September 29, 2004 letter# 2 Exhibit 2 − October 6, 2004 letter# 3 Exhibit 3 − October 8, 2004 letter)(Dupont, Philip) (Entered: 10/14/2004)
10/14/2004 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents by Defendant Sprint/United Management Company (Dupont, Philip) (Entered: 10/14/2004)
10/14/2004 2497 NOTICE of Consent of Rosalyn Carol Reese by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2498 NOTICE of Consent of Kent Paul Smith by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)
10/14/2004 2499 NOTICE of Consent of Marca E. Snook by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)

10/14/2004 2500 NOTICE of Consent of Edna Ashley Williams by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)

10/14/2004 2501 NOTICE of Consent of Merrill Wittmer by Shirley Williams (Egan, Dennis) (Entered: 10/14/2004)

10/14/2004

2502

MEMORANDUM IN SUPPORT of 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents by Defendant Sprint/United Management Company (Attachments: # 1 List of Exhibits# 2 Exhibit A − Certificate of Compliance# 3 Exhibit A−1 − September 29, 2004 "golden rule" letter# 4 Exhibit A−2 − October 6, 2004 "meet and confer" confirmation# 5 Exhibit A−3 − October 8, 2004 letter confirming agreement for extension# 6 Exhibit B−1 − Plaintiff Shirley Williams' Answers and Objections to Defendant's First Interrogatories (Part 1, pages 1−15)# 7 Exhibit B−2 − Plaintiff Shirley Williams' Answers and Objections to Defendant's First Interrogatories (Part 2, pages 16−30)# 8 Exhibit B−3 − Plaintiff Shirley Williams' Answers and Objections to Defendant's First Interrogatories (Part 3, pages 31−33)# 9 Exhibit C − Plaintiff Shirley Williams' Answers and Objections to Defendant's First Request for Production of Documents# 10 Exhibit D − Plaintiff Shirley Williams' Answers and Objections to Defendant's Second Request for Production of Documents# 11 Exhibit E − Plaintiff John Borel's Answers and Objections to Defendant's First Interrogatories# 12 Exhibit F − Plaintiff John Borel's Responses and Objections to Defendant's First Request for Production of Documents# 13 Exhibit G − Plaintiff Carolyn Selberg's Answers and Objections to Defendant's First Interrogatories# 14 Exhibit H − Plaintiff Carolyn Selberg's Responses and Objections to Defendant's First Request for Production of Documents# 15 Exhibit I − Plaintiff Terry Cocherl's Answers and Objections to Defendant's First Interrogatories# 16 Exhibit J − Plaintiff Terry Cocherl's Responses and Objections to Defendant's First Request for Production of Documents# 17 Exhibit K − Plaintiff Kenneth Prohanizak's Responses and Objections to Defendant's First Request for Production of Documents# 18 Exhibit L − Defendant's First Request for Production to Plaintiff Sharon Miller# 19 Exhibit M − Defendant's First Interrogatories to Plaintiff Sharon Miller# 20 Exhibit N − Defendant's Second Interrogatories to Plaintiff Shirley Williams)(Dupont, Philip) (Entered: 10/14/2004)

10/14/2004 2503 NOTICE of Consent of Rob Roy Benson, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2504 NOTICE of Consent of James P. Carroll by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2505 NOTICE of Consent of Christopher J. Dauten by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2506 NOTICE of Consent of Debra Ann Ferguson by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2507 NOTICE of Consent of Fannye Johnson Forester by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2508 NOTICE of Consent of David A. Harrington by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2509 NOTICE of Consent of Donald A. Hayes by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2510 NOTICE of Consent of Nancy B. Johnson by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2511 NOTICE of Consent of Charmaine L. Keller by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2512 NOTICE of Consent of Michael Kochevar by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2513 NOTICE of Consent of Steve A. Matalone II by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2514 NOTICE of Consent of Steven Edward McDonough by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2515 NOTICE of Consent of Michael S. Orenberg by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2516 NOTICE of Consent of Arjovik Ray by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2517 NOTICE of Consent of Rita A. Roberts by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2518 NOTICE of Consent of R. Alan Schindler by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2519 NOTICE of Consent of Debra H. Seidel by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2520 NOTICE of Consent of Davis Shikles by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2521 NOTICE of Consent of Noel Strong by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2522 NOTICE of Consent of Carol A. Sturm by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2523 NOTICE of Consent of John Scott Turik by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2524 NOTICE of Consent of Maria C. Walker−Magdaleno by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2525 NOTICE of Consent of Lowell Hal Wallace by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2526 NOTICE of Edward G. Wemlinger by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2527 NOTICE of Consent of Anthony Orin Young by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2528 NOTICE of Consent of Elizabeth Boggs by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2529 NOTICE of Consent of Marsha A. Burch by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2530 NOTICE of Consent of Christie B. Carrico by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2531 NOTICE of Consent of Renee J. Daniels by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2532 NOTICE of Consent of Al Krygeris by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2533 NOTICE of Consent of David Paul Markham by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2534 NOTICE of Consent of Debra Markham by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2535 NOTICE of Consent of Sue Anne McDonald by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2536 NOTICE of Consent of Carol E. Nelson by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2537 NOTICE of Consent of Phillip E. Norman by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)

10/14/2004 2538 NOTICE of Consent of Everline Primm by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2539 NOTICE of Consent of Charles Douglas Smith by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2540 NOTICE of Consent of Vicki S. Van Engen by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2541 NOTICE of Consent of Thomas P. Armstrong by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2542 NOTICE of Consent of Abigail Louise Davis by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2543 NOTICE of Consent of Robert Kent Hodgson by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2544 NOTICE of Consent of Carolyn De Ann Majd by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2545 NOTICE of Consent of Beulah Elaine Shields by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2546 NOTICE of Consent of E. Maria StrahanWheaton by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2547 NOTICE of Consent of Michael S. Ambre by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2548 NOTICE of Consent of Alan Cepeda by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2549 NOTICE of Consent of William W. Crockett by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2550 NOTICE of Consent of Barbara Dean by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2551 NOTICE of Consent of Cecile L. Dickson by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2552 NOTICE of Consent of Meredith Francis by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2553 NOTICE of Consent of LaDonna Kay Gazaway by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2554 NOTICE of Consent of Jack E. McConnell by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2555 NOTICE of Consent of David L. Norton by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2556 NOTICE of Consent of William C. Phillips by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/14/2004 2557 NOTICE of Consent of Michael C. Royal by Shirley Williams (Dennis, Stephen) (Entered: 10/14/2004)
10/15/2004 2558 NOTICE of Consent of Jacqueline J. Webster by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2559 NOTICE of Consent of Vera Theresa Sledge by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2560 NOTICE of Consent of Dominic V. Orlando by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2561 NOTICE of Consent of Ronald Cook by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/15/2004 2562 NOTICE of Consent of Matthew J. Borkowski by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2563 CERTIFICATE OF SERVICE by Shirley Williams. (Graham, Gene) (Entered: 10/15/2004)
10/15/2004 2564 NOTICE of Consent of Michael P. Buxkemper by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2565 NOTICE of Consent of Debra E. Cohen by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2566 NOTICE of Consent of Frances Cooper by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2567 NOTICE of Consent of Cedric B. DeBolt, Jr. by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2568 NOTICE of Consent of Melanie Denis by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2569 NOTICE of Consent of Eric Scott Erhard by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2570 NOTICE of Consent of Jackie Flannery by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2571 NOTICE of Consent of Patricia A. Garber by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2572 NOTICE of Consent of Donald D. Hullinger by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2573 NOTICE of Consent of Denise M. Kotel by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2574 NOTICE of Consent of Diane R. Krizek by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2575 NOTICE of Consent of John David Mais by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2576 NOTICE of Consent of Michael A. Mierchuk by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2577 NOTICE of Consent of Ricky Morrison by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2578 NOTICE of Consent of Anita Y. Moxley by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2579 NOTICE of Consent of Theresa Muscat−Reynaud by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2580 NOTICE of Consent of Sandra Price by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2581 NOTICE of Consent of Abdul N. Rahim by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2582 NOTICE of Consent of Gary Scheib by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2583 NOTICE of Consent of Hilda Ashanti Turnage by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2584 NOTICE of Consent of Richard White by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)
10/15/2004 2585 NOTICE of Consent of Lorraine H. Woodard by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/15/2004 2586 NOTICE of Consent of Mary Jane Crotzer by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/15/2004 2587 NOTICE of Consent of Sharon K. Valasek by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/15/2004 2588 NOTICE of Consent of Joyce M. Hutchings by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/15/2004 2589 NOTICE of Consent of Michael J. Bumpers by Shirley Williams (Dennis, Stephen) (Entered: 10/15/2004)

10/20/2004 2590 AMENDED NOTICE by All Plaintiffs of taking deposition of Dan Fogelman on 10/21/2004. (Meyers, Martin) (Modified on 10/21/2004 to remove the names of all plaitniffs listed. (mg)) (Entered: 10/20/2004)

10/20/2004 2591 CERTIFICATE OF COMPLIANCE by All Plaintiffs.(Graham, Gene) (Modified on 10/21/2004 to remove list of plaintiffs' names. (mg)) (Entered: 10/20/2004)

10/20/2004 2592 MOTION to Compel by Plaintiff Shirley Williams (Graham, Gene) (Entered: 10/20/2004)

10/20/2004 2593 MEMORANDUM IN SUPPORT of 2592 MOTION to Compel Discovery by Plaintiff Shirley Williams (Graham, Gene) (Entered: 10/20/2004)

10/20/2004 2594 MOTION FOR LEAVE to File Exhibits Conventionally by Plaintiff Shirley Williams (Graham, Gene) (Entered: 10/20/2004)

10/21/2004 2595 ORDER denying 2594 Plaintiff's Motion for Leave to File Exhibits Conventionally. (See Order for detail.) Signed by Magistrate Judge David J. Waxse on 10/21/2004.(jm) (Entered: 10/21/2004)

10/22/2004 2596 EXHIBIT(S) IN SUPPORT of 2592 MOTION to Compel and 2593 Memorandum in Support, by Plaintiff Shirley Williams EXHIBIT A (Egan, Dennis) Modified on 10/22/2004 to create relationship link (ck). (Entered: 10/22/2004)

10/22/2004 2597 EXHIBIT(S) IN SUPPORT of 2592 MOTION to Compel and 2593 Memorandum in Support, by Plaintiff Shirley Williams EXHIBIT B (Egan, Dennis) Modified on 10/22/2004 to create relationship link (ck). (Entered: 10/22/2004)

10/22/2004 2598 EXHIBIT(S) IN SUPPORT of 2592 MOTION to Compel and 2593 Memorandum in Support, by Plaintiff Shirley Williams EXHIBIT C (Egan, Dennis) Modified on 10/22/2004 to create relationship link (ck). (Entered: 10/22/2004)

10/22/2004 2599 EXHIBIT(S) IN SUPPORT of 2592 MOTION to Compel and 2593 Memorandum in Support, by Plaintiff Shirley Williams EXHIBIT D (Egan, Dennis) Modified on 10/22/2004 to create relationship link (ck). (Entered: 10/22/2004)

10/22/2004 2600 EXHIBIT(S) IN SUPPORT of 2592 MOTION to Compel and 2593 Memorandum in Support by Plaintiff Shirley Williams EXHIBIT E (Egan, Dennis) Modified on 10/22/2004 to create relationship link (ck). (Entered: 10/22/2004)

10/22/2004

NOTICE of docket text modification by Deputy Clerk regarding Exhibits 2596 , 2597 , 2598 , 2599 and 2600 in Support of 2593 Motion to Compel. Relationship links also created to the Memorandum in Support 2593 . (ck) (Entered: 10/22/2004)

10/27/2004 2601 CERTIFICATE OF SERVICE by Wayne Kuzmich, William E. Pitts, Robert O. Smith (Dennis, Stephen) (Entered: 10/27/2004)

10/28/2004 2602 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Louk on November 5, 2004 (Hulla, Patrick) (Entered: 10/28/2004)

10/28/2004 2603 MOTION for Extension of Time to File Response as to 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents by Plaintiff Shirley Williams (Dennis, Stephen) (Entered: 10/28/2004)

10/29/2004 2604 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 10/29/2004)

10/29/2004 2605 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Shirley Williams on November 16, 2004 (Hulla, Patrick) (Entered: 10/29/2004)

10/29/2004 2606 RESPONSE by Defendant Sprint/United Management Company re 2603 MOTION for Extension of Time to File Response as to 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Hulla, Patrick) (Entered: 10/29/2004)

11/01/2004 2607 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Answers to Defendant's Third Interrogatories to Plaintiff. (Braud, Bert) (Entered: 11/01/2004)

11/01/2004

2608

CERTIFICATE OF SERVICE by Alan Boyer, Kenneth E. Donnelly, John L. Eller, Jim Fagan, Barbara R. Frans, Thomas M. Gerrity, Les Goodwin, Bonnie L. Hoopes, Wayne Kuzmich, Ralph J. Kwapiszeski, Robert D. McManus, Cathy McNally, Michael McVicker, William E. Pitts, Kenneth Mark Prohoniak, Robert O. Smith, Karen S. Staley (Dennis, Stephen) (Entered: 11/01/2004)

11/01/2004

2609

MOTION to Compel Responses to Questionnaires by Defendant Sprint/United Management Company (Attachments: # 1 List of Exhibits# 2 Exhibit 1 − Sample copy of the questionnaire from opt−in plaintiff Joe Norton# 3 Exhibit 2 − Certificate of Compliance with Local Rule# 4 Exhibit 2A − October 26, 2004 "golden rule" letter)(Dupont, Philip) (Entered: 11/01/2004)

11/01/2004

2610

MEMORANDUM IN SUPPORT of 2609 MOTION to Compel Responses to Questionnaires by Defendant Sprint/United Management Company (Attachments: # 1 List of Exhibits# 2 Exhibit 1 − Sample copy of the questionnaire from opt−in plaintiff Joe Norton# 3 Exhibit 2 − Certificate of Compliance with Local Rule# 4 Exhibit 2A − October 26, 2004 "golden rule" letter)(Dupont, Philip) (Entered: 11/01/2004)

11/01/2004

2611

ORDER granting 2603 Plaintiff's Motion for Extension of Time to File Response re 2496 Defendant's MOTION to Compel. Plaintiff is hereby granted an extension of time, up to November 2, 2004, to file her memorandum in opposition to Sprint's Motion to Compel Answers to Interrogatories and Requests for Production of Documents. Entered by Magistrate Judge David J. Waxse on 11/1/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(jm) (Entered: 11/01/2004)

11/01/2004 2612 Joint MOTION to Amend Scheduling Order for One Week Extension to File Further Report on Opt−In Discovery by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 11/01/2004)

11/01/2004 2613 MOTION for Order granting Plaintiffs' Request to Permit Additional Individuals to Opt−In by Plaintiff Shirley Williams (Egan, Dennis) (Entered: 11/01/2004)

11/02/2004

2614

MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2592 MOTION to Compel (Attachments: # 1 Index to Attachments# 2 Exhibit Attachment A# 3 Exhibit Attachment B# 4 Exhibit Attachment C# 5 Exhibit Attachment D# 6 Exhibit Attachment E# 7 Exhibit Attachment F−1# 8 Exhibit Attachment F−2)(Hulla, Patrick) (Entered: 11/02/2004)

11/02/2004 2615 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint (Accounting Dept) (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2616 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint ( Re Exhibit 51 and Bell Curve) (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2617 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint (H.R. Operations) (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2618 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Responses to Defendant's Third Request for Production of Documents Directed to Plaintiffs. (Braud, Bert) (Entered: 11/02/2004)

11/02/2004 2619 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint (Budgeting and Planning) (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2620 NOTICE by Plaintiff Shirley Williams of taking deposition of Ben Watson (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2621 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint (Re Qualifications as it appears in Depo Exhibit 7 (Klamann, John) (Entered: 11/02/2004)

11/02/2004 2622 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents (Dennis, Stephen) (Entered: 11/02/2004)

11/03/2004 2623 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 11/03/2004)

11/08/2004

2624

ORDER granting 2612 Joint Motion for One (1) Week Extension to File Further Report on Opt−in Discovery. The parties are hereby granted an extension of time, to November 9, 2004, to file their Report on Further Individualized Opt−In Discovery. Entered by Magistrate Judge David J. Waxse on 11/8/2004.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(jm) (Entered: 11/08/2004)

11/09/2004 2625 STATUS REPORT Plaintiffs' Interim Report Regarding Further Opt−In Discovery by Shirley Williams. (Attachments: # 1 Exhibit A)(Egan, Dennis) (Entered: 11/09/2004)

11/09/2004

2626

STATUS REPORT Recommendation of Defendant for Continued Interim Discovery of Opt−In Class Members by Sprint/United Management Company. (Attachments: # 1 Exhibit A − Questionnaire# 2 Exhibit B − Consent Burch# 3 Exhibit C − Consent Forster# 4 Exhibit D − Number of Opt−Ins by Date Consent Filed)(Yates, John) (Entered: 11/09/2004)

11/10/2004

2627

STATUS REPORT Amended Recommendation of Defendant for Continued Interim Discovery of Opt−in Class Members by Sprint/United Management Company. (Attachments: # 1 Exhibit Ex. A − Questionnaire# 2 Exhibit Ex, B − Burch Consent# 3 Exhibit Ex. C − Forster Consent# 4 Exhibit Ex D − # of Opt−ins by Date Consent Filed)(Yates, John) (Entered: 11/10/2004)

11/13/2004 2628 RESPONSE by Defendant Sprint/United Management Company re 2613 MOTION for Order granting Plaintiffs' Request to Permit Additional Individuals to Opt−In (Yates, John) (Entered: 11/13/2004)

11/16/2004 2629 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 2496 MOTION to Compel Answers to Interrogatories and Request for Production of Documents (Dupont, Philip) (Entered: 11/16/2004)

11/24/2004 2630 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 11/24/2004)

12/01/2004 2631 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 12/01/2004)

12/01/2004 2632 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 12/01/2004)

12/01/2004 2633 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bonnie Hoopes on December 13, 2004 (Hulla, Patrick) (Entered: 12/01/2004)

12/01/2004 2634 NOTICE by Plaintiff Shirley Williams of taking deposition of Deb Aubuchon (Graham, Gene) (Entered: 12/01/2004)

12/01/2004 2635 MOTION to Compel for Sanctions Pursuant to Rule 37(a)(2)(A) by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 12/01/2004)

12/01/2004 2636 MEMORANDUM IN SUPPORT of 2635 MOTION to Compel for Sanctions Pursuant to Rule 37(a)(2)(A) by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Hulla, Patrick) (Entered: 12/01/2004)

12/02/2004 2637 ORDER SETTING STATUS CONFERENCE AND MOTION HEARING: A Status Conference and Motion Hearing on 12/17/2004 at 3:00 PM before Magistrate Judge David J. Waxse in Courtroom 223, U.S. Courthouse, 500 State Avenue, Kansas City, Kansas. On its own motion, the Court hereby sets an in−person Status Conference

regarding discovery of opt−in plaintiffs and a Motion Hearing regarding the pending Motions to Compel (docs. 2496, 2592, 2609). Entered by Magistrate Judge David J. Waxse on 12/2/2004.(jm) (Entered: 12/02/2004)
12/03/2004 2638 ORDER granting 2613 Motion for Order to permit additional individuals to opt−in. The twenty−three individuals identified in plaintiff's motion shall file their Consent to Join forms no later than 12/10/2004.. Signed by Judge John W. Lungstrum on 12/03/2004. (ses) (Entered: 12/03/2004)
12/03/2004 2639 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 12/03/2004)
12/07/2004 2640 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1). (Egan, Dennis) (Entered: 12/07/2004)
12/07/2004 2641 NOTICE of Consent of John C. Carlisle by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2642 NOTICE of Consent of Ronald J. Cooley by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2643 NOTICE of Consent of Joe F. Cooper by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2644 NOTICE of Consent of Steven Earl Davidson by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2645 NOTICE of Consent of Myriam Diaz de Jesus by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2646 NOTICE of Consent of Daniel J. Gastelum by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2647 NOTICE of Consent of Mary H. Gillispie by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2648 NOTICE of Consent of Donna Hartman by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2649 NOTICE of Consent of Juan Manuel Hernandez by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2650 NOTICE of Consent of Janis B. Jacks by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2651 NOTICE of Consent of Diane Jo Luzadder by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2652 NOTICE of Consent of Karen Lynn by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2653 NOTICE of Consent of Ebenezer Oloyede by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2654 NOTICE of Consent of Dwaine Leland Palmer by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2655 NOTICE of Consent of Ada Samoilovich by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2656 NOTICE of Consent of Robert C. Singleton, Sr. by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2657 NOTICE of Consent of Stephanie M. Singleton by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)
12/07/2004 2658 NOTICE of Consent of Charles E. Sorenson by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/07/2004 2659 NOTICE of Consent of Brian K. Spomer by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/07/2004 2660 NOTICE of Consent of Thea Straite by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/07/2004 2661 NOTICE of Consent of James H. Swartz by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/07/2004 2662 NOTICE of Consent of Beverly Ann Taylor by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/07/2004 2663 NOTICE of Consent of Margot L. Woolf by Shirley Williams (Dennis, Stephen) (Entered: 12/07/2004)

12/10/2004 2664 MOTION to Compel Responsive Answers to Defendant's Second Interrogatories by Defendant Sprint/United Management Company (Hulla, Patrick) (Entered: 12/10/2004)

12/10/2004 2665 MEMORANDUM IN SUPPORT of 2664 MOTION to Compel Responsive Answers to Defendant's Second Interrogatories by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit B# 2 Exhibit C# 3 Exhibit D# 4 # 5 Exhibit E)(Hulla, Patrick) (Entered: 12/10/2004)

12/15/2004 2666 MOTION to Compel by Plaintiff Shirley Williams (Graham, Gene) (Entered: 12/15/2004)

12/15/2004 2667 MEMORANDUM IN SUPPORT of 2666 MOTION to Compel by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit A# 3 Exhibit A# 4 Exhibit A# 5 Exhibit A# 6 Appendix A# 7 Exhibit B# 8 Appendix C)(Graham, Gene) (Entered: 12/15/2004)

12/15/2004 2668 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams. (Graham, Gene) (Entered: 12/15/2004)

12/17/2004 2669 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2666 MOTION to Compel and re 2667 (Attachments: # 1 Attachment "1"# 2 Attachment "2"# 3 Attachment "3"# 4 Attachment "4")(Hulla, Patrick) (Entered: 12/17/2004)

12/17/2004

2670

Minute Entry for Proceeding held on 12/17/2004 before Magistrate Judge David J. Waxse: Status Conference and Motion Hearing re 2609 Defendant's MOTION to Compel Responses to Questionnaires, 2592 Plaintiffs' MOTION to Compel, 2496 Defendant's MOTION to Compel Answers to Interrogatories and Request for Production of Documents. Order to follow. (CD# 2004DJW01) (byk) (Entered: 12/17/2004)

12/17/2004 2671 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiff's Seventh Request for Production of Documents and Things; and Plaintiff's Sixth Interrogatories Directed to Sprint. (Egan, Dennis) (Entered: 12/17/2004)

12/20/2004

2672

ORDER taking under advisement 2496 Defendant's Motion to Compel; and taking under advisement 2592 Plaintiff's Motion to Compel; and finding as moot 2609 Defendant's Motion to Compel Responses to Opt−in Plaintiffs' Questionnaires; and counsel for Defendant has advised the Court that Defendant's Motion to Compel (doc. 2635), with the exception of its request for sanctions, is now moot. (SEE ORDER FOR FURTHER DEADLINES AND RULINGS.) Signed by Magistrate Judge David J. Waxse on 12/20/2004.(jm) (Entered: 12/20/2004)

12/20/2004 2673 ORDER vacating 307 Second Phase Scheduling Order. Signed by Judge John W. Lungstrum on 12/20/2004. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses, ) (Entered: 12/20/2004)

12/20/2004 2674 ORDER TO SHOW CAUSE. Plaintiffs' Show Cause Response due to Magistrate Judge David J. Waxse by 1/31/2004. Signed by Magistrate Judge David J. Waxse on 12/20/2004.(jm) (Entered: 12/20/2004)

01/03/2005 2675 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Di Wuthnow on January 7, 2005 (Klamann, John) (Entered: 01/03/2005)

01/06/2005 2676 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Bonnie Hoopes on 02/21/05 (Hulla, Patrick) (Entered: 01/06/2005)

01/11/2005 2677 NOTICE by Plaintiff Shirley Williams of taking deposition of Lynn Badaracco on January 14, 2005 (Klamann, John) (Entered: 01/11/2005)

01/17/2005 2678 NOTICE of Change of Address by Gene P. Graham, Jr (Graham, Gene) (Entered: 01/17/2005)

01/17/2005 2679 Joint MOTION for extension of time for Parties to Meet and Confer and Memorandum in Support by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 01/17/2005)

01/17/2005 2680 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Bonnie Hoopes on February 28, 2005 (Hulla, Patrick) (Entered: 01/17/2005)

01/18/2005 2681 NOTICE by Plaintiff Shirley Williams of taking deposition of Custodian of Records−Watson Wyatt on February 25, 2005 (Attachments: # 1 Subpoena and Ex. A)(Braud, Bert) (Entered: 01/18/2005)

01/18/2005 2682 NOTICE by Plaintiff Shirley Williams of taking deposition of Custodian of Records, Moody's Investors on February 24, 2005 (Attachments: # 1 Subpoena and Ex. A)(Braud, Bert) (Entered: 01/18/2005)

01/18/2005 2683 Unopposed MOTION for extension of time to Respond to Plaintiff's 7th Request for Production and 6th Interrogatories by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 01/18/2005)

01/19/2005

2684

ORDER granting 2679 Joint Motion to Extend Deadline for Parties to Meet and Confer and Memorandum in Support. Parties to meet and confer by 1/20/2005 regarding various, pending discovery issues as set forth in Paragraph (3) of the Court's 12/20/2004 Order 2672 . Signed by Magistrate Judge David J. Waxse on 1/18/05. (ll) (Entered: 01/19/2005)

01/19/2005

2685

ORDER granting 2683 Unopposed Motion to Extend Deadline for Sprint to Respond to Plaintiff's Seventh Request for Production of Docments and Things and Plaintiff's Sixth Interrogatories Directed to Sprint/United Management Company. Defendant granted to 2/3/2005 to answer or otherwise respond thereto. Signed by Magistrate Judge David J. Waxse on 1/19/05. (ll) (Entered: 01/19/2005)

01/24/2005 2686 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Supplemental Responses to Defendant's Second Interrogatories and Plaintiffs' Supplemental Response to Certain of Defendant's Second Request for Production of Documents on 12−17−04. (Meyers, Martin) (Entered: 01/24/2005)

01/25/2005 2687 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative on January 26, 2005 (Egan, Dennis) (Entered: 01/25/2005)

01/27/2005 2688 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams unexecuted upon Watson Wyatt & Company on January 18, 2005 by Personal Service. (Braud, Bert) (Modified on 1/27/2005 to reflect this was unexecuted. See document #2690. (mg)) (Entered: 01/27/2005)

01/27/2005 2689 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Moody's Investors Service on January 18, 2005 by Personal (Braud, Bert) (Entered: 01/27/2005)

01/27/2005 2690 AMENDED RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Watson Wyatt & Company on January 19, 2005 by Personal Service. (Braud, Bert) (Modified on 1/27/2005 to clarify text. (mg)) (Entered: 01/27/2005)

01/31/2005 2691 RESPONSE by Plaintiff Shirley Williams re 2674 Order to Show Cause (Attachments: # 1 Exhibit A)(Egan, Dennis) (Entered: 01/31/2005)

02/02/2005 2692 NOTICE by Plaintiff Shirley Williams of taking deposition of Senior−most non−HR Oprations person affected by RIF announced 2−15−02 (Klamann, John) (Entered: 02/02/2005)

02/02/2005 2693 NOTICE by Plaintiff Shirley Williams of taking deposition of Senior−Most non−HR Operations person affected by RIF announced 12−11−02 (Klamann, John) (Entered: 02/02/2005)

02/02/2005 2694 NOTICE by Plaintiff Shirley Williams of taking deposition of Senior−most non−HR Operations person directly affected by the RIF announced 7−12−02 (Klamann, John) (Entered: 02/02/2005)

02/02/2005 2695 NOTICE by Plaintiff Shirley Williams of taking deposition of Senior−Most non−HR Operations person directly affected by the RIF announced 10−17−01 (Klamann, John) (Entered: 02/02/2005)

02/02/2005 2696 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized representative of Sprint regarding validation of numeric and alpha systems and audits of alpha system (Klamann, John) (Entered: 02/02/2005)

02/10/2005 2697 NOTICE by Defendant Sprint/United Management Company of taking deposition of Yvonne Wood on February 24, 2005 (Hulla, Patrick) (Entered: 02/10/2005)

02/10/2005

2698

NOTICE OF SERVICE by Gerald P. Keith, Jo Belle Crain, John L. Eller, Cheryl Bolton, Carol L. Kippes, Daniel R. Honeycutt, Kimberly Yvonne Carlson of Requests for Admissions, Second Interrogatories and Requests for Production of Documents and Things (also Plaintiffs Karen Abolt, Wilfredo Aleman, Joyce Bixler, Mark Browne, Theresa Cassity, Kiertichai Chevasin, Dave Compton, Eva Crane, Larry Davis, Merrill Detweiler, Dianne Hamdan, Therese Hearl, Keith Jamour and Carol Kippes) (Hubbard, Dirk) (Entered: 02/10/2005)

02/11/2005 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 02/11/2005)

02/11/2005

2700

MEMORANDUM IN SUPPORT of 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit Index# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D# 6 Exhibit E# 7 Exhibit F# 8 Exhibit G# 9 Exhibit H# 10 Exhibit I# 11 Exhibit J−1# 12 Exhibit J−2# 13 Exhibit K)(Hulla, Patrick) (Modified on 2/14/2005 to remove duplicate text. (mg)) (Entered: 02/11/2005)

02/11/2005

2701

NOTICE OF SERVICE by Louis G. Rocha, Peggy Sturgess, Stephen C. Rood, John Wesley Persaud, Leslie H. Kreger of Requests for Admissions, Second Interrogatories and Request for Production of Documents and Things (also Plaintiffs Paul Lamoree, William Lewis, Jeffrey Martin, Ronals Mears, Laura Mixon, David Molinaro, Terri Morrow−Tansey, Brenda Newman, Robert Nielsen, Sunny Onwuzuruike, Louis Rocha, Anthony Scelza, Russell Simmons, David Stevens, Michael Tekampe, and Edwin Terry) (Hubbard, Dirk) (Entered: 02/11/2005)

02/14/2005

2702

NOTICE OF SERVICE by Judith P. Cobb, Deborah A. Ehr, Douglas L. Curts, Dale Aaron Dupuis, Mike Dougherty, Lana Sue Coleman, Rebecca G. Ferrell, Steven Dale Colton, Cynthia Gail Crews, Donald Richard Darden, Sandra J. Eastin, Patricia A. Cahoon, Kenneth P. Cromley, Sharon T. Carmody, Carmen M. Chandler, Charles David Curtis, Robert D. Eicher of Requests for Admissions and Second Interroragories to Defendant Sprint and Requests for Production of Documents and Things (also Plaintiffs Valerie J. Byrd, Arnita L. Davis, Barbara B. Davis, Eldon J. Elliott, Debora K. Evans−Guillen, Donald A. Fedge, Debra Ann Ferguson) (Hubbard, Dirk) (Entered: 02/14/2005)

02/16/2005 2703 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Second Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1). (Egan, Dennis) (Entered: 02/16/2005)

02/17/2005 2704 NOTICE by Plaintiff Shirley Williams of taking deposition of Thornton Mason (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2705 NOTICE by Plaintiff Shirley Williams of taking deposition of Janet Taylor (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2706 NOTICE by Plaintiff Shirley Williams of taking deposition of Person who operated the videotaping equipment for the videotape marked SBR−W041081 (Klamann, John)

(Entered: 02/17/2005)

02/17/2005 2707 NOTICE by Plaintiff Shirley Williams of taking deposition of Person who made any edits and/or deletions to original videotape SBR−W041081 (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2708 NOTICE by Plaintiff Shirley Williams of taking deposition of Person responsible for content of 2−15−02 News Release (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2709 NOTICE by Plaintiff Shirley Williams of taking deposition of Person responsible for content of 7−12−02 news release (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2710 NOTICE by Plaintiff Shirley Williams of taking deposition of Person responsible for the content of the 12−11−02 news release (Klamann, John) (Entered: 02/17/2005)

02/17/2005 2711 NOTICE by Plaintiff Shirley Williams of taking deposition of Person responsible for the content of the 10−17−01 news release (Klamann, John) (Entered: 02/17/2005)

02/18/2005 2712 NOTICE by Plaintiff Shirley Williams of taking deposition of Lisa Lieb on March 22, 2005 (Braud, Bert) (Entered: 02/18/2005)

02/21/2005 2713 NOTICE by Plaintiff Shirley Williams of taking deposition of Ric Walter on February 25, 2005 (Graham, Gene) (Entered: 02/21/2005)

02/21/2005 2714 NOTICE by Plaintiff Shirley Williams of taking deposition of Sandy Price on March 14, 2005 (Graham, Gene) (Entered: 02/21/2005)

02/21/2005 2715 NOTICE by Plaintiff Shirley Williams of taking deposition of Janet Larsen on March 8, 2005 (Graham, Gene) (Entered: 02/21/2005)

02/21/2005 2716 NOTICE by Plaintiff Shirley Williams of taking deposition of Will Prout on 02−06−05 (Meyers, Martin) (Entered: 02/21/2005)

02/21/2005 2717 NOTICE by Plaintiff Shirley Williams of taking deposition of Mike Fuller on 04−12−05 (Meyers, Martin) (Entered: 02/21/2005)

02/21/2005 2718 Unopposed MOTION for Extension of Time to File response as to 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 02/21/2005)

02/22/2005

2719

ORDER granting 2718 Motion for Extension of Time to File Responsere 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery.Response deadline extended to 02/28/2005 . Signed by Judge John W. Lungstrum on 02/22/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 02/22/2005)

02/23/2005 2720 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Miller on March 2, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2721 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Kippes on June 1, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2722 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kimberly Carlson on April 2, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2723 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerald Keith on April 18, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2724 NOTICE by Defendant Sprint/United Management Company of taking deposition of Daniel Honeycutt on April 14, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2725 NOTICE by Defendant Sprint/United Management Company of taking deposition of Theresa Cassity on April 13, 2005 (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2726 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 02/23/2005)

02/23/2005 2727 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 02/23/2005)

02/28/2005 2728 MOTION to Dismiss Party (See Exhibit to Motion) by Plaintiff Shirley Williams (Attachments: # 1 Exhibit)(Hubbard, Dirk) (Entered: 02/28/2005)

02/28/2005

2729

MEMORANDUM in Opposition by Plaintiff Shirley Williams re 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery (Attachments: # 1 Exhibit List# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8)(Hubbard, Dirk) (Entered: 02/28/2005)

02/28/2005 2730 STATUS REPORT and Recommendations for Second Phase Discovery Scheduling by Sprint/United Management Company. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Yates, John) (Entered: 02/28/2005)

02/28/2005 2731 STATUS REPORT Plaintiffs' 2/28/05 Status Report With Proposed Second Phase Case Deadlines by Shirley Williams. (Egan, Dennis) (Entered: 02/28/2005)

03/01/2005 2732 NOTICE by Plaintiff Shirley Williams of taking deposition of Meg Yearout on March 15, 2005 (Graham, Gene) (Entered: 03/01/2005)

03/01/2005 2733 MOTION to Dismiss Party Madelyn Velasquez−Almansa by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 03/01/2005)

03/02/2005 2734 MOTION to Withdraw Consent and for Dismissal Without Prejudice of Claims of Cheryl Bolton by Plaintiff Shirley Williams(Graham, Gene) (Entered: 03/02/2005)

03/02/2005

2735

ORDER − Court Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum re 2733 MOTION to Dismiss Party Madelyn Velasquez−Almansa filed by Shirley Williams, 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery filed by Sprint/United Management Company,and 2728 MOTION to Dismiss Party (See Exhibit to Motion) filed by Shirley Williams. Response/reply deadlines shortened as to these motions − SEE ORDER FOR DETAILS. . Signed by Judge John W. Lungstrum on 03/02/2005. (ses, ) (Entered: 03/02/2005)

03/02/2005 2736 NOTICE of Hearing on Motion 2734 MOTION to Withdraw Consent and for Dismissal Without Prejudice of Claims of Cheryl Bolton: Motion Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 03/02/2005)

03/04/2005 2737 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Seventh Interrogatories and Eighth Request for Production of Documents. (Egan, Dennis) (Modified on 3/7/2005 to correct document text. (mg)) (Entered: 03/04/2005)

03/07/2005 2738 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerald Keith on April 18, 2005 (Hulla, Patrick) (Entered: 03/07/2005)

03/07/2005 2739 NOTICE by Plaintiff Shirley Williams of taking deposition of Person(s) to testify concerning PCS implementation of alpha rating system in 2002 (Klamann, John) (Entered: 03/07/2005)

03/07/2005 2740 MOTION to Dismiss Party Leonard Fus, Sharon Goldring, Deborah Lee, Virginia Nooner, Judy Novosel, Douglas S. Maclean, Karen M. Rider, and John Wansing by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 03/07/2005)

03/08/2005 2741 NOTICE of Hearing on Motion 2740 MOTION to Dismiss Party Leonard Fus, Sharon Goldring, Deborah Lee, Virginia Nooner, Judy Novosel, Douglas S. Maclean, Karen M. Rider, and John Wansing: Motion Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 03/08/2005)

03/11/2005 2742 MOTION to Dismiss Party Margret L. Adams by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 03/11/2005)

03/11/2005 2743 NOTICE of Hearing on Motion 2742 MOTION to Dismiss Party Margret L. Adams: Motion Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 03/11/2005)

03/13/2005 2744 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 03/13/2005)

03/14/2005 2745 MOTION to Dismiss Party Richard Danjou, Scott Erhard, Sheila Farris, David Jungert, Mark Linde, Willie Miles, Sara Nelson, Jeanette Norwood, Barbara Snowden, and Lynette Tolar by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 03/14/2005)

03/14/2005 2746 MOTION for Protective Order Regarding Individual Discovery from Opt−In Plaintiffs by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 03/14/2005)

03/14/2005 2747 MEMORANDUM IN SUPPORT of 2746 MOTION for Protective Order Regarding Individual Discovery from Opt−In Plaintiffs by Defendant Sprint/United Management Company (Attachments: #(1) Exhibit A #(2)Exhibit B)(Hulla, Patrick) (Modified on 3/15/2005 to remove duplicate text. (mg)) (Entered: 03/14/2005)

03/14/2005

2748

NOTICE of Hearing on Motion 2745 MOTION to Dismiss Party Richard Danjou, Scott Erhard, Sheila Farris, David Jungert, Mark Linde, Willie Miles, Sara Nelson, Jeanette Norwood, Barbara Snowden, and Lynette Tolar: Motion Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 03/14/2005)

03/14/2005 2749 MOTION for Protective Order Regarding Plaintiff's Deposition Notices Under Rule 30(b)(6) by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 03/14/2005)

03/14/2005

2750

MEMORANDUM IN SUPPORT of 2749 MOTION for Protective Order Regarding Plaintiff's Deposition Notices Under Rule 30(b)(6) by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P# 17 Exhibit Q# 18 Exhibit R# 19 Exhibit S# 20 Exhibit T# 21 Exhibit U# 22 Exhibit V)(Hulla, Patrick) (Entered: 03/14/2005)

03/15/2005 2751 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Request for Production of Documents Regarding the Employment of Greg Barnes and Bob Leatherman. (Graham, Gene) (Entered: 03/15/2005)

03/15/2005 2752 NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Lampe on May 3, 2005 (Graham, Gene) (Entered: 03/15/2005)

03/15/2005

2753

ORDER granting in part 2496 Defendant Sprint's Motion to Compel Answers to Interrogatories and Request for Production of Documents. No later than March 30, 2005, the twenty−three Plaintiffs who were served with Defendant's interrogatories and requests for production shall serve Defendant with their amended discovery responses withdrawing the assertion of privilege and stating that there are no documents and/or information responsive to the requests other than information provided by Sprint. See Order for further details. Signed by Magistrate Judge David J. Waxse on 3/15/2005. (byk) (Entered: 03/15/2005)

03/15/2005 2754 ORDER denying 2592 Plaintiffs' Motion to Compel Discovery. See Order for details. Signed by Magistrate Judge David J. Waxse on 3/15/2005.(byk) (Entered: 03/15/2005)

03/15/2005

2755

ORDER entered shortening response/reply time for 2746 Defendant's Motion for Protective Order Regarding Individual Discovery from Opt−in Plaintiffs and 2749 Defendant's Motion for Protective Order Regarding Plaintiffs' Deposition Notices Under Rule 30(b)(6) to enable the Court to take up the motions at the conference scheduled for March 23,2005. Plaintiffs' deadlines to file response briefs in opposition to Defendant's Motions for Protective Order are hereby shortened to March 18, 2005. Defendant's reply briefs shall be filed by March 22, 2005. Signed by Magistrate Judge David J. Waxse on 3/15/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 03/15/2005)

03/15/2005

2756

ORDER denying 2635 Defendant Sprint/United Management Company's Motion to Compel for Sanctions Pursuant to Rule 37(a)(2)(A). The Court determines that the circumstances of this motion make an award of expenses unjust. Signed by Magistrate Judge David J. Waxse on 3/15/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 03/15/2005)

03/16/2005

2757

ORDER finding as moot 2664 Defendant Sprint/United Management Company's Motion to Compel Responsive Answers to Defendant's Second Interrogatories. Counsel for Defendant has advised the Court that Defendant's Motion to Compel is moot in light of 2686 Plaintiffs' Supplemental Responses to Defendant's Second Interrogatories. Signed by Magistrate Judge David J. Waxse on 3/16/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 03/16/2005)

03/17/2005 2758 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Will Prout on May 19, 2005 (Meyers, Martin) (Entered: 03/17/2005)

03/17/2005 2759 NOTICE by Plaintiff Shirley Williams of taking deposition of Vickie Smith on April 8, 2005 (Meyers, Martin) (Entered: 03/17/2005)

03/18/2005 2760 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 2699 MOTION to Dismiss Party Opt−Ins Who Have Failed to Respond to Agreed−Upon Discovery (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Hulla, Patrick) (Entered: 03/18/2005)

03/18/2005

2761

MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2728 MOTION to Dismiss Party (See Exhibit to Motion), 2740 MOTION to Dismiss Party Leonard Fus, Sharon Goldring, Deborah Lee, Virginia Nooner, Judy Novosel, Douglas S. Maclean, Karen M. Rider, and John Wansing, 2742 MOTION to Dismiss Party Margret L. Adams, 2733 MOTION to Dismiss Party Madelyn Velasquez−Almansa, 2734 MOTION to Withdraw Consent and for Dismissal Without Prejudice of Claims of Cheryl Bolton, 2745 MOTION to Dismiss Party Richard Danjou, Scott Erhard, Sheila Farris, David Jungert, Mark Linde, Willie Miles, Sara Nelson, Jeanette Norwood, Barbara Snowden, and Lynette Tolar (Attachments: # 1 Exhibit A)(Hulla, Patrick) (Entered: 03/18/2005)

03/18/2005 2762 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 2746 MOTION for Protective Order Regarding Individual Discovery from Opt−In Plaintiffs (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Blakely, Deborah) (Entered: 03/18/2005)

03/18/2005 2763 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 2749 MOTION for Protective Order Regarding Plaintiff's Deposition Notices Under Rule 30(b)(6) (Attachments: # 1 Exhibit Exhibit 1# 2 Exhibit Exhibit 2# 3 Exhibit Exhibit 3# 4 Exhibit Exhibit 4)(Martin, Jennifer) (Entered: 03/18/2005)

03/21/2005 2764 MOTION to Dismiss Party 60 Opt−In Plaintiffs −− See Attachment by Plaintiff Shirley Williams (Attachments: # 1 Exhibit 1)(Hubbard, Dirk) (Entered: 03/21/2005)

03/21/2005 2765 MOTION to Dismiss Party Ron Sieve by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 03/21/2005)

03/21/2005 2766 NOTICE of Hearing on Motion 2764 MOTION to Dismiss Party 60 Opt−In Plaintiffs −− See Attachment, 2765 MOTION to Dismiss Party Ron Sieve: Motion Hearing set for 3/23/2005 at 10:00 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 03/21/2005)

03/22/2005

2767

REPLY to Response to Motion by Defendant Sprint/United Management Company re: 2749 MOTION for Protective Order Regarding Plaintiff's Deposition Notices Under Rule 30(b)(6) Defendant's Reply to Plaintiff's Memorandum in Opposition to Defendant's Motion for Protective Order Regarding Rule 30(b)(6) Deposition Notices (Attachments: # 1 Exhibit Ltr from Jack Yates to Messrs. Egan and Klamann# 2 Exhibit Ltr from Gene Graham to Jack Yates)(Hulla, Patrick) (Entered: 03/22/2005)

03/22/2005

2768

REPLY to Response to Motion by Defendant Sprint/United Management Company re: 2746 MOTION for Protective Order Regarding Individual Discovery from Opt−In Plaintiffs Defendant's Reply to Plaintiff's Memorandum in Opposition to Defendant's Motion for Protective Order Regarding Individual Discovery from Opt−Ins (Attachments: # 1 Exhibit Email from Court to Counsel# 2 Exhibit Ltr from Bert Braud to Jack Yates)(Hulla, Patrick) (Entered: 03/22/2005)

03/22/2005 2769 ORDER granting in part and denying in part 2666 Plaintiffs' Motion to Compel Discovery. (See Order for detail.) Signed by Magistrate Judge David J. Waxse on 3/22/2005.(jm) (Entered: 03/22/2005)

03/23/2005

2770

Minute Entry and ORDER for proceedings held before Magistrate Judge David J. Waxse: A Status Conference was held on 3/23/2005: A motion hearing/discovery conference is set for March 30, 2005 at 2:00 p.m. before Magistrate Judge Waxse in Courtroom 223. By March 25, 2005, each party shall provide a list of items to be taken up at the March 30, 2005 conference. Additionally, regular discovery conferences are set for the first and third Thursdays of each month at 3:00 p.m. in Courtroom 223 until further order of the Court. The parties are ordered to meet at 2:00 p.m. in Courtroom 223 before each discovery conference to attempt to resolve any pending discovery or scheduling issues.(jm) (Entered: 03/23/2005)

03/23/2005 2771 ENTRY OF APPEARANCE by Sarah A. Brown on behalf of Bernard W. Mayse (Brown, Sarah) (Entered: 03/23/2005)

03/23/2005 2792 Minute Entry for proceedings held before Judge John W. Lungstrum : Status Conference held on 3/23/2005 (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 04/01/2005)

03/24/2005 2772 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianne Hamden on 05/19/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2773 NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Abolt on 05/13/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2774 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ken (Kiertichai) Chevasin on 05/10/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2775 NOTICE by Defendant Sprint/United Management Company of taking deposition of Therese Ann Hearl on 05/26/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2776 NOTICE by Defendant Sprint/United Management Company of taking deposition of Merrill Detweiler on 05/16/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2777 NOTICE by Defendant Sprint/United Management Company of taking deposition of Keith Jamour on 06/29/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/24/2005 2778 NOTICE by Defendant Sprint/United Management Company of taking deposition of Larry Davis on 05/06/05 (Hulla, Patrick) (Entered: 03/24/2005)

03/25/2005 2779 MOTION for Review , and Objections to, Magistrate's Order by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 03/25/2005)

03/25/2005 2780 INDEX OF EXHIBITS by Plaintiff Shirley Williams re 2779 MOTION for Review , and Objections to, Magistrate's Order (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13 # 14 # 15)(Egan, Dennis) (Entered: 03/25/2005)

03/25/2005 2781 MEMORANDUM IN SUPPORT of 2779 MOTION for Review , and Objections to, Magistrate's Order by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 03/25/2005)

03/28/2005

2782

ORDER re 2779 MOTION for Review and Objections to, Magistrate's Order filed by Shirley Williams. The court orders that the defendant's response to plaintiff's motion to review shall be filed no later that noon on 03/30/2005 and this motion is set for hearing on 03/31/2005 at 2:00 p.m. in Courtroom #427. Signed by Judge John W. Lungstrum on 03/28/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Entered: 03/28/2005)

03/28/2005 2783 NOTICE by Plaintiff Shirley Williams of taking deposition of Meg Yearout on April 14, 2005 (Graham, Gene) (Entered: 03/28/2005)

03/28/2005

2784

ORDER granting Defendant's request to limit the issues taken up at 3/30/05 Motion Hearing/Status Conference to: Sprint's Motions for Protective Orders regarding the inappropriateness of Plaintiff's individualized discovery and Plaintiff's 30(b)(6) notices (i.e., Docs. 2746, 2747, 2749, and 2750). The remainder of the issues set forth by Plaintiffs will be taken up at the 4/7/2005 discovery conference. Entered by Magistrate Judge David J. Waxse on 3/28/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(byk) (Entered: 03/28/2005)

03/29/2005

2785

ORDER GRANTING OPT−IN PLAINTIFFS' MOTIONS TO DISMISS AND SETTING SCHEDULE FOR MOTIONS TO DISMISS OTHER OPT−IN PLAINTIFFS: granting 2728 Motion to Dismiss Party, granting 2733 Motion to Dismiss Party, granting 2734 Motion to Withdraw, granting 2740 Motion to Dismiss Party, granting 2742 Motion to Dismiss Party, granting 2745 Motion to Dismiss Party, granting 2764 Motion to Dismiss Party, granting 2765 Motion to Dismiss Party. (SEE ORDER FOR DETAILS). Signed by Judge John W. Lungstrum on 03/29/2005. (Attachments: # 1 Exhibit 1) (ses, ) (Entered: 03/29/2005)

03/29/2005 2786 ORDER denying without prejudice the 2699 Motion to Dismiss opt−ins who have failed to respond to agreed upon discovery. Signed by Judge John W. Lungstrum on 03/29/2005. (ses) (Entered: 03/29/2005)

03/30/2005 2787 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2779 MOTION for Review , and Objections to, Magistrate's Order (Attachments: # 1 Exhibit Index# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D−1# 6 Exhibit D−2# 7 Exhibit E# 8 Exhibit F)(Hulla, Patrick) (Entered: 03/30/2005)

03/30/2005

2788

Minute Entry for Motion Hearing held on 3/30/05 before Magistrate Judge David J. Waxse re 2749 Defendant's MOTION for Protective Order Regarding Plaintiff's Deposition Notices Under Rule 30(b)(6) and 2746 Defendant's MOTION for Protective Order Regarding Individual Discovery from Opt−In Plaintiffs. Order to follow. (byk) (Entered: 03/30/2005)

03/30/2005

2789

MEMORANDUM AND ORDER granting 2779 Motion for Review and objections to the magistrate judge's March 15, 2005 order. The court will address the merits of defendant's objections to Interrogatory No. 12 at the motion hearing set for Thursday, March 31, 2005 at 2:00 p.m. Signed by Judge John W. Lungstrum on 03/30/2005. (ses) (Entered: 03/30/2005)

03/30/2005

2790

CERTIFICATE OF SERVICE by Robert O. Smith, Thomas M. Gerrity, Les Goodwin, Michael McVicker, William E. Pitts, John L. Eller, Jim Fagan, Cathy McNally, Alan Boyer, Karen S. Staley, Kenneth E. Donnelly, Barbara R. Frans, Bonnie L. Hoopes, Wayne Kuzmich, Ralph J. Kwapiszeski, Kenneth Mark Prohoniak, Robert D. McManus (Dennis, Stephen) (Entered: 03/30/2005)

03/31/2005

2791

ORDER granting 2746 Defendant's Motion for Protective Order Regarding Individualized Discovery, and denying 2749 Defendant's Motion for Protective Order Regarding Rule 30(b)(6) Notices. By 3:00 p.m. on April 6, 2005, the parties shall e−mail a revised list of the issues to be taken up by the Court at the April 7, 2005 discovery conference. (See Order for further deatail.) Signed by Magistrate Judge David J. Waxse on 3/31/2005.(jm) (Entered: 03/31/2005)

03/31/2005 2793 Minute Entry for proceedings held before Judge John W. Lungstrum : Status Conference held on 3/31/2005 (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 04/01/2005)

04/01/2005 2794 MOTION to Dismiss Party Michael Ambre, Walter Bennett, Richard Freni, Diane L. Johnson, Patricia Pauscher, Russell C. Simmons, Ann G. Stephens, and Rose Woolfrey by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 04/01/2005)

04/01/2005

2795

ORDER GRANTING WITHDRAWAL OF CONSENT AND DISMISSAL WITHOUT PREJUDICE OF CLAIMS OF EIGHT OPT−IN PLAINTIFFS − granting 2794 Motion to Dismiss Party . Opt−In plaintiffs Michael Ambre, Walter Bennett, Richard Freni, Diane L. Johnson, Patricia Pauscher, Russell G. Simmons, Ann G. Stephens and Rose Woolfrey claims are withdrawn and their claims are dismissed, without prejudice, each party to bear its own costs. Signed by Judge John W. Lungstrum on 04/01/2005. (ses, ) (Entered: 04/01/2005)

04/05/2005 2796 MOTION for Reconsideration of Magistrate's Order of March 22, 2005 (Doc. # 2769) by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 04/05/2005)

04/06/2005 2797 Unopposed MOTION for extension of time to respond to Plaintiff's 8th Request for Production and 7th Interrogatories by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 04/06/2005)

04/07/2005

2798

ORDER granting 2797 Unopposed Motion for Extension of Time to File Response. Defendant Sprint/United Management Company shall have until April 21, 2005 to answer, and otherwise respond to, Plaintiff's Eighth Request for Production of Documents and Things and Plaintiff's Seventh Interrogatories Directed to Sprint/United Management Company, including any objections thereto. Signed by Magistrate Judge David J. Waxse on 4/7/2005.(jm) (Entered: 04/07/2005)

04/08/2005 2799 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ruth Stratton (Hulla, Patrick) (Entered: 04/08/2005)

04/08/2005 2800 NOTICE by Plaintiff Shirley Williams of taking deposition of Terry York on 04/21/05 (Meyers, Martin) (Entered: 04/08/2005)

04/11/2005

2801

Minute Entry for Discovery/Status Conference held on 4/07/2005 before Magistrate Judge David J. Waxse. Plaintiffs' deadline to serve their expert disclosures is extended to July 15, 2005. Defendant's deadline is extended to forty−five days thereafter, to September 1, 2005. The deadline for disclosure of any rebuttal experts is September 15, 2005. Next discovery conference set for 4/21/2005 at 3:00 p.m. (See attached Minute Sheet) (byk) (Entered: 04/11/2005)

04/11/2005 2802 NOTICE by Plaintiff Shirley Williams of taking deposition of Marvin Motley on April 15, 2005 (Graham, Gene) (Entered: 04/11/2005)

04/12/2005 2803 NOTICE by Plaintiff Shirley Williams of taking deposition of Ron Focht on April 13, 2005 (Graham, Gene) (Entered: 04/12/2005)

04/13/2005 2804 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cheryl Bolton on May 6, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2805 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jo Belle Crain on May 19, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2806 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eve Crane on May 20, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2807 NOTICE by Defendant Sprint/United Management Company of taking deposition of Laura Mixon on June 16, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2808 NOTICE by Defendant Sprint/United Management Company of taking deposition of Edwin Terry on May 13, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2809 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianne Hamden on May 19, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2810 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Persaud on April 29, 2005 (Hulla, Patrick) (Entered: 04/13/2005)

04/13/2005 2812 Minute Sheet for Telephone Status Conference held before Magistrate Judge David J. Waxse on 4/13/2005 re Defendant's oral motion for protective order in deposition being taken. (See Minute Sheet for further details.) (ll) (Entered: 04/14/2005)

04/14/2005 2811 MOTION for Review and Objections to Magistrate's Orders of March 31, 2005, 2792 and April 7, 2005, 2798 , with Supporting Memorandum in Support of Motion by Plaintiff Shirley Williams(Hubbard, Dirk) Title of Entry modified on 4/15/2005 (ck ). (Entered: 04/14/2005)

04/14/2005 2813 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re voluntary turnover by alpha rating and/or voluntary turnover by numeric rating (Klamann, John) (Entered: 04/14/2005)

04/15/2005 2814 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Will Prout on 06−03−05 (Meyers, Martin) (Entered: 04/15/2005)

04/15/2005

2815

NOTICE of Hearing on Motion 2811 MOTION for Review and Objections to Magistrate's Orders of March 31, 2005, 2792 and April 7, 2005, 2798 , with Supporting Memorandum in Support of Motion: Motion Hearing (Telephone Conference) set for 4/20/2005 at 01:30 PM before Chief Judge John W. Lungstrum. (This is a TEXT ENTRY ONLY. There is no .pdf document associated with the entry. (mm) (Entered: 04/15/2005)

04/18/2005 2816 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2796 MOTION for Reconsideration of Magistrate's Order of March 22, 2005 (Doc. # 2769) (Attachments: # 1 Exhibit Index to Exhibits# 2 Exhibit A# 3 Exhibit B# 4 Exhibit B1# 5 Exhibit B2)(Hulla, Patrick) (Entered: 04/18/2005)

04/19/2005

2817

ORDER − The telephone conference previously scheduled for April 20, 2005 regarding 2811 MOTION for Review and Objections to Magistrate's Orders of March 31, 2005, 2792 and April 7, 2005, 2798 , with Supporting Memorandum in Support of Motion. filed by Shirley Williams is cancelled. In the event counsel are unable to resolve this matter at the conference before Magistrate Judge Waxse on April 21, 2005, counsel shall contact the court to reset this matter. Signed by Judge John W. Lungstrum on 04/19/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Entered: 04/19/2005)

04/19/2005 2818 MOTION to Withdraw Consents and for Dismissal Without Prejudice of Claims of 53 OPT−IN Plaintiffs Whose Terminations Occurred Outside of the Class Period in This Case by Plaintiffs. (Hubbard, Dirk) (Modified on 4/20/2005 to clarify document title in docket text and to clarify document filers as plaintiffs. (mg)) (Entered: 04/19/2005)

04/19/2005

2819

EXHIBIT(S) IN SUPPORT of 2818 MOTION to Withdraw Consents and for Dismissal Without Prejudice of Claims of 53 OPT−IN Plaintiffs Whose Terminations Occurred Outside of the Class Period in This Case by Plaintiffs. (Hubbard, Dirk) (Modified on 4/20/2005 to clarify document title in docket text. (mg)) (Entered: 04/19/2005)

04/20/2005 2820 AMENDED SECOND PHASE SCHEDULING ORDER − SEE ORDER FOR DEADLINES.Trial on plaintiff's pattern−and−practice claims is set for 4/11/2006 at 09:30 AM before Chief Judge John W. Lungstrum. Signed by Judge John W. Lungstrum on 04/20/2005. (ses) (Entered: 04/20/2005)

04/21/2005 2821 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Kimberly Carlson on April 27, 2005 (Hulla, Patrick) (Entered: 04/21/2005)

04/21/2005 2822 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 04/21/2005)

04/21/2005 2823 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2824 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2825 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2826 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2827 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2828 NOTICE by Plaintiff Shirley Williams of taking deposition of Shelley Wagner (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2829 NOTICE by Plaintiff Shirley Williams of taking deposition of Jari Newsome (Klamann, John) (Entered: 04/21/2005)

04/21/2005 2830 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Brill (Klamann, John) (Entered: 04/21/2005)

04/22/2005 2831 NOTICE by Plaintiff Shirley Williams of taking deposition of William T. Esrey (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2832 NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Peterson on 06−07−05 (Meyers, Martin) (Entered: 04/22/2005)

04/22/2005 2833 NOTICE by Plaintiff Shirley Williams of taking deposition of Arthur B. Krause (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2834 NOTICE by Plaintiff Shirley Williams of taking deposition of Kathleen McBee on 06−01−05 (Meyers, Martin) (Entered: 04/22/2005)

04/22/2005 2835 Minute Entry for Discovery/Status Conference held on 4/21/2005 before Magistrate Judge David J. Waxse. Next discovery conference set for 5/5/2005 at 3:00 p.m. (See attached Minute Sheet) (byk) (Modified on 4/27/2005 to reflect the next discovery conference is to be held on 05/05/05. (mg)) (Entered: 04/22/2005)

04/22/2005 2836 NOTICE by Plaintiff Shirley Williams of taking deposition of Charles "Chuck" Levine (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2837 NOTICE by Plaintiff Shirley Williams of taking deposition of Jo Renda (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2838 NOTICE by Plaintiff Shirley Williams of taking deposition of Carolyn Curtis (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2839 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Waldron (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2840 NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Meyer (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2841 NOTICE by Plaintiff Shirley Williams of taking deposition of Rick McRae (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2842 NOTICE by Plaintiff Shirley Williams of taking deposition of Liane J. Pelletier (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2843 NOTICE by Plaintiff Shirley Williams of taking deposition of Ed Mattix (Klamann, John) (Entered: 04/22/2005)

04/22/2005 2844 NOTICE by Plaintiff Shirley Williams of taking deposition of Dan Falvey (Klamann, John) (Entered: 04/22/2005)

04/22/2005

2845

NOTICE of Hearing on Motion 2811 MOTION for Review and Objections to Magistrate's Orders of March 31, 2005, 2792 and April 7, 2005, 2798 , with Supporting Memorandum in Support of Motion. Motion Hearing (in person) set for 4/26/2005 at 01:30 PM before Chief Judge John W. Lungstrum in courtroom #427. The parties shall provide to the court no later than 5:00 p.m. on 04/25/2005 a one page submission setting forth issues that have been narrowed since the filing of the motion. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Modified on 4/25/2005 to reflect this is a text entry only. (mg)) (Entered: 04/22/2005)

04/22/2005 2846 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mark Browne on May 23, 2005 (Hulla, Patrick) (Entered: 04/22/2005)

04/26/2005 2847 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of John Persaud on May 13, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2848 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Edwin Terry on May 4, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2849 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Therese Ann Hearl on July 25, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2850 NOTICE by Defendant Sprint/United Management Company of taking deposition of Leslie Kreger on May 26, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2851 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ron Mears on May 10, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2852 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steve Rood on June 7, 2005 (Hulla, Patrick) (Entered: 04/26/2005)

04/26/2005 2853 ENTRY OF APPEARANCE by David A. Schatz on behalf of all defendants. (Schatz, David) (Entered: 04/26/2005)

04/26/2005

2854

Minute Entry for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 4/26/2005 re 2811 MOTION for Review and Objections to Magistrate's Orders of March 31, 2005, 2792 and April 7, 2005, 2798 , with Supporting Memorandum in Support of Motion filed by Shirley Williams. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 04/27/2005)

04/27/2005

NOTICE of docket text modification by Deputy Clerk regarding Discovery/Status Conference 2835 : the docket text has been modified to reflect the next discovery conference set for 5/5/2005 at 3:00 p.m.. (mg) (Entered: 04/27/2005)

04/27/2005 2855 ORDER granting in part the 2811 Motion for Review and objections to magistrate's orders of March 31, 2005 and April 7, 2005. Signed by Judge John W. Lungstrum on 04/27/2005. (ses) (Entered: 04/27/2005)

04/28/2005 2856 CERTIFICATE OF SERVICE by Shirley Williams Kenneth P. Cromley's First Revised Requests for Production of Documents and Things (Hubbard, Dirk) (Entered: 04/28/2005)

04/29/2005 2857 NOTICE by Plaintiff Shirley Williams of taking deposition of John Shannon on May 6, 2005 (Egan, Dennis) (Entered: 04/29/2005)

04/29/2005 2858 CERTIFICATE OF SERVICE by Shirley Williams Sharon T. Carmody, Daniel Honeycutt, Ronald Mears, Peggy Sturgess, John Borel, Steve Constance, Sharon Herren, Carol Kippes's First Revised Requests for Production of Documents and Things (Hubbard, Dirk) (Entered: 04/29/2005)

04/29/2005 2859 NOTICE by Plaintiff Shirley Williams of taking deposition of Peter Dillon on May 24, 2005 (Egan, Dennis) (Entered: 04/29/2005)

05/02/2005 2860 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Abolt on May 16, 2005 (Hulla, Patrick) (Entered: 05/02/2005)

05/02/2005 2861 CERTIFICATE OF SERVICE by Shirley Williams (Plaintiffs Yvonne Wood−Olson, Terry Cocherl, David Molz, and Carolyn Selberg's First Revised Requests for Production of Documents and Things). (Hubbard, Dirk) (Entered: 05/02/2005)

05/04/2005 2862 NOTICE by Plaintiff Shirley Williams of taking deposition of Cindy Novak on May 26, 2005 (Graham, Gene) (Entered: 05/04/2005)

05/04/2005 2863 NOTICE by Defendant Sprint/United Management Company of taking deposition of Edward Rawlings on June 6, 2005 (Hulla, Patrick) (Entered: 05/04/2005)

05/04/2005 2864 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Oakes on June 7, 2005 (Hulla, Patrick) (Entered: 05/04/2005)

05/04/2005 2865 NOTICE by Defendant Sprint/United Management Company of taking deposition of Douglas Meng on June 8, 2005 (Hulla, Patrick) (Entered: 05/04/2005)

05/04/2005 2866 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Ben Watson on May 18, 2005 (Klamann, John) (Entered: 05/04/2005)

05/04/2005 3301 STATEMENT: Plaintiffs'List of Issues for 2871 Discovery Conference. (mg) (Entered: 09/27/2005)

05/05/2005 2867 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lenore Meng on June 8, 2005 (Hulla, Patrick) (Entered: 05/05/2005)

05/05/2005 2868 NOTICE by Defendant Sprint/United Management Company of taking deposition of Julia Hicks on June 9, 2005 (Hulla, Patrick) (Entered: 05/05/2005)

05/05/2005 2869 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerald Portillo on June 9, 2005 (Hulla, Patrick) (Entered: 05/05/2005)

05/05/2005 2870 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/05/2005)

05/05/2005 2871 Minute Entry for Discovery/Status Conference held on 5/5/2005 before Magistrate Judge David J. Waxse. Next discovery conference set for 5/19/2005 at 3:00 p.m. (See attached Minute Sheet)(byk) (Entered: 05/05/2005)

05/06/2005 2872 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rochelle Hughes Walker on June 13, 2005 (Hulla, Patrick) (Entered: 05/06/2005)
05/06/2005 2873 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffrey Garland on June 14, 2005 (Hulla, Patrick) (Entered: 05/06/2005)
05/06/2005 2874 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lawrence Matt on June 15, 2005 (Hulla, Patrick) (Entered: 05/06/2005)
05/06/2005 2875 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bruce Salisbury on June 16, 2005 (Hulla, Patrick) (Entered: 05/06/2005)
05/09/2005 2876 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/09/2005)
05/09/2005 2877 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Will Prout on 06−10−05 (Meyers, Martin) (Entered: 05/09/2005)
05/09/2005 2878 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Lenore Meng on June 8, 2005 (Hulla, Patrick) (Entered: 05/09/2005)
05/09/2005 2879 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerald Portillo on June 9, 2005 (Hulla, Patrick) (Entered: 05/09/2005)
05/09/2005 2880 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jesse W. Ballard on June 1, 2005 (Hulla, Patrick) (Entered: 05/09/2005)
05/09/2005 2881 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Ballew on June 2, 2005 (Hulla, Patrick) (Entered: 05/09/2005)
05/09/2005 2882 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronald John Haefner on June 8, 2005 (Hulla, Patrick) (Entered: 05/09/2005)
05/11/2005 2883 NOTICE by Plaintiff Shirley Williams of taking deposition of Pat Campbell on May 26, 2005 (Graham, Gene) (Entered: 05/11/2005)
05/11/2005 2884 NOTICE by Plaintiff Shirley Williams of taking deposition of Cindy Novak on May 26, 2005 (Graham, Gene) (Entered: 05/11/2005)
05/11/2005 2885 NOTICE by Plaintiff Shirley Williams of taking deposition of Mona Stewart on 05−17−05 (Meyers, Martin) (Entered: 05/11/2005)
05/13/2005 2886 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Kathleen McBee on 06−01−05 (Meyers, Martin) (Entered: 05/13/2005)
05/13/2005 2887 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Peterson on 06−07−05 (Meyers, Martin) (Entered: 05/13/2005)
05/16/2005 2888 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/16/2005)
05/16/2005 2889 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Third Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1): May 16, 2005. (Egan, Dennis) (Entered: 05/16/2005)
05/17/2005 2890 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Carmody on June 20, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2891 NOTICE by Defendant Sprint/United Management Company of taking deposition of Clifford Deal on June 15, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2892 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Clinton Hicks on June 17, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2893 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rasiah Jey on June 20, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2894 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Merchant on June 16, 2005 (Hulla, Patrick) (Entered: 05/17/2005)

05/17/2005 2895 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Thompson on 05−23−05 (Meyers, Martin) (Entered: 05/17/2005)
05/17/2005 2896 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Noah on June 15, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2897 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Norwood−Browne on June 23, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2898 NOTICE by Defendant Sprint/United Management Company of taking deposition of Janet Poletis on June 22, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2899 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joseph A. Ritt, Jr. on June 21, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/17/2005 2900 NOTICE by Defendant Sprint/United Management Company of taking deposition of Clarence Wildes on June 14, 2005 (Hulla, Patrick) (Entered: 05/17/2005)
05/18/2005 2901 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Kippes on June 1, 2005 (Hulla, Patrick) (Entered: 05/18/2005)
05/18/2005 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint by Plaintiff Shirley Williams (Attachments: # 1 Second Amended Complaint)(Hubbard, Dirk) (Entered: 05/18/2005)
05/18/2005 2903 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Eighth Interrogatories to Defendant, and Plaintiffs' Ninth Request for Production of Documents. (Egan, Dennis) (Entered: 05/18/2005)
05/18/2005 2904 ORDER granting 2818 Motion to Withdraw and Dismiss Fifty−Three (53) Opt−In Plaintiffs. Signed by Judge John W. Lungstrum on 05/18/05. (Attachments: #(1) Exhibit 1 −− List of Withdrawn Opt−In Plaintiffs) (mg) (Entered: 05/18/2005)
05/18/2005 2905 TRANSCRIPT of proceedings held 5/5/05 before Magistrate David J. Waxse
NOTICE RE: REDACTION OF TRANSCRIPTS: Within 5 business days of this filing, each party shall inform the Court, by filing a Notice of Redaction, of the parties intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ksd.uscourts.gov. Please read this policy carefully. If no Notice of Intent to Redact is filed within the allotted time, the transcript will be made electronically available after 5 business days.
NOTICE: For access to this document only (unlike other documents) via the Notice of Electronic Filing, click on the CASE NUMBER (not the Document Number) hyperlink; at the login screen enter your ECF login and password; click on Run Report; enter your PACER login and password; and click on the DOCUMENT NUMBER hyperlink.
. (mm) (Transcript made electronically available on 5/31/2005. (mg)) (Entered: 05/19/2005)
05/20/2005 2906 Minute Entry for Discovery/Status Conference held on 5/19/2005 before Magistrate Judge David J. Waxse. Next discovery conference set for 6/02/2005 at 3:00 p.m. (See attached Minute Sheet.)(byk) (Entered: 05/20/2005)
05/20/2005 2907 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Thompson on 05−23−05 (Meyers, Martin) (Entered: 05/20/2005)
05/20/2005 2908 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/20/2005)
05/23/2005 2909 ORDER withdrawing referral to Magistrate of the 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint filed by Shirley Williams. Signed by Judge John W. Lungstrum on 05/23/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(ses) (Entered: 05/23/2005)
05/23/2005 2910 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/23/2005)

05/25/2005 2911 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeff Martin on June 24, 2005 (Hulla, Patrick) (Entered: 05/25/2005)
05/25/2005 2912 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Nielsen on June 27, 2005 (Hulla, Patrick) (Entered: 05/25/2005)
05/25/2005 2915 TRANSCRIPT of proceedings on 5/19/05 held before Magistrate Judge David J. Waxse. (mm) (Modified on 5/31/2005. (mg)) (Entered: 05/27/2005)
05/26/2005 2913 Unopposed MOTION for Extension of Time to File Response as to 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 05/26/2005)
05/26/2005 2914 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/26/2005)
05/27/2005 2916 ORDER granting 2913 Motion for Extension of Time to File Response re 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint. Response deadline extended to 6/13/2005. Signed by Judge John W. Lungstrum on 05/27/2005. (ses) (Entered: 05/27/2005)
05/27/2005 2917 NOTICE by Plaintiff Shirley Williams of taking deposition of John Naylor on 6/30/2005 (Egan, Dennis) (Entered: 05/27/2005)
05/27/2005 2918 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John Naylor on 6/30/2005 (Egan, Dennis) (Entered: 05/27/2005)
05/31/2005 2919 MOTION to Withdraw Consent of Opt−In Plaintiff Tony (Anthony) Scelza and for Dismissal of Claims by Plaintiff Anthony F. Scelza(Hubbard, Dirk) Title of entry modified on 6/1/2005 (ck ). (Entered: 05/31/2005)
05/31/2005 2920 MOTION to Accept Two Consents to Join Out of Time by Plaintiff Shirley Williams. (Hubbard, Dirk) (Document Title Modified on 6/3/2005. (mg)) (Entered: 05/31/2005)
05/31/2005 2921 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 05/31/2005)
05/31/2005 2922 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 05/31/2005)
05/31/2005 2923 CERTIFICATE OF SERVICE by Shirley Williams (Amended) (Dennis, Stephen) (Entered: 05/31/2005)
06/01/2005 2924 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2920 MOTION to Accept Two Consents to Join Out of Time. (Hulla, Patrick) (Motion Title Modified on 6/3/2005. (mg)) (Entered: 06/01/2005)
06/01/2005 2925 ENTRY OF APPEARANCE by Kara Marie Dorssom on behalf of Sprint/United Management Company. (Dorssom, Kara) (Entered: 06/01/2005)
06/01/2005 2926 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on June 1, 2005 (Egan, Dennis) (Entered: 06/01/2005)
06/01/2005 2927 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on June 1, 2005 (Egan, Dennis) (Entered: 06/01/2005)
06/01/2005 2928 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 06/01/2005)
06/02/2005 2929 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Fourth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1): June 2, 2005. (Egan, Dennis) (Entered: 06/02/2005)
06/03/2005 2930 Minute Entry for Discovery/Status Conference held on 6/02/2005 before Magistrate Judge David J. Waxse. Next discovery conference set for 6/09/2005 at 2:00 p.m. (byk) (Entered: 06/03/2005)
06/03/2005 2931 ORDER denying as moot 2796 Plaintiffs' Motion for Reconsideration. As discussed at the 6/2/2005 Discovery Conference, Plaintiffs' Motion for Reconsideration is denied as moot. Entered by Magistrate Judge David J. Waxse on 6/03/2005. (This is a

TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 06/03/2005)

06/06/2005 2932 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 06/06/2005)

06/08/2005 2933 MOTION to Withdraw as Attorney by Plaintiff Shirley Williams(Martin, Jennifer) (Entered: 06/08/2005)

06/08/2005 2934 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianne Hamden on June 21, 2005 (Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2935 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Ruth Straton on June 30, 2005 (Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2936 NOTICE by Defendant Sprint/United Management Company of taking deposition of Noel Strong on July 26, 2005 (Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2937 NOTICE by Defendant Sprint/United Management Company of taking deposition of Claude Powell on August 3, 2005 (Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2938 MOTION for Protective Order Regarding Advertising and Marketing Discovery by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2939 MEMORANDUM IN SUPPORT of 2938 MOTION for Protective Order Regarding Advertising and Marketing Discovery by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B)(Hulla, Patrick) (Entered: 06/08/2005)

06/08/2005 2940 TRANSCRIPT of proceedings (Status Conference) on 6/2/05 held before Magistrate Judge David J. Waxse. (mm) (Judge title modified on 06/10/05. (mg)) (Entered: 06/09/2005)

06/09/2005 2941 ORDER granting 2933 Motion to Withdraw as Attorney. Attorney Jennifer L. Martin withdrawn as counsel for plaintiffs. Signed by Magistrate Judge David J. Waxse on 06/09/05. (mg) (Entered: 06/09/2005)

06/10/2005 2942 Minute Entry for Discovery/Status Conference held on 6/09/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 6/16/2005 at 3:00 p.m. (byk) (Entered: 06/10/2005)

06/10/2005 2943 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Julia Hicks on Jun 23, 2005 (Hulla, Patrick) (Entered: 06/10/2005)

06/10/2005 2944 ENTRY OF APPEARANCE by Kenneth B McClain on behalf of all plaintiffs (McClain, Kenneth) (Entered: 06/10/2005)

06/10/2005 2945 AMENDED NOTICE by Plaintiffs of taking deposition of William Esrey on June 14, 2005. (McClain, Kenneth) (Text removed on 6/10/2005. (mg)) (Entered: 06/10/2005)

06/13/2005

2946

MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint (Attachments: # 1 Exhibit A−Shirley Williams' EEOC Charge of Discrimination# 2 Exhibit B−Pages 36−42 from Transcript of Deposition of Shirley Williams# 3 Exhibit C−John Borel's EEOC Charge of Discrimination# 4 Exhibit D−Pages 23−24; 47−48; and 50 from Transcript of Deposition of John Borel# 5 Exhibit E−Declaration of Terri Stanton# 6 Exhibit F−EEOC Questionnaire filed by Steve Constance# 7 Exhibit G−Terry Lee Cocherl's EEOC Charge of Discrimination# 8 Exhibit H−Sharon Herren's EEOC Charge of Discrimination# 9 Exhibit I−Sharon S. Miller's EEOC Charge of Discrimination# 10 Exhibit J−Pages 4−5 of Transcript from Deposition of Sharon Miller# 11 Exhibit K−Pages 19; 60−61; 66; and 70 from Transcript of Deposition of Sharon Miller# 12 Exhibit L−David Molz's EEOC Charge of Discrimination# 13 Exhibit M−Carolyn Selberg's EEOC Charge of Discrimination# 14 Exhibit N−Peggy Sturgess' EEOC Charge of Discrimination# 15 Exhibit O−EEOC Questionnaire filed by Yvonne Wood# 16 Exhibit P−Pages 3−4; and 9 from Transcript of Deposition of Yvonne Wood# 17 Exhibit Pages 22, 27 and 31 from

Transcript of Deposition of Yvonne Wood# 18 Exhibit R−Pages 11, 18 and 60 from the Transcript of Proceedings before the Honorable John W. Lungstrum on April 26, 2005)(Hulla, Patrick) (Duplicate text removed on 6/14/2005. (mg)) (Entered: 06/13/2005)

06/13/2005 2947 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Cromley on July 21, 2005 (Hulla, Patrick) (Entered: 06/13/2005)

06/14/2005 2948 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of William Clinton Hicks on June 22, 2005 (Hulla, Patrick) (Entered: 06/14/2005)

06/15/2005 2949 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Tekampe on June 27, 2005 (Hulla, Patrick) (Entered: 06/15/2005)

06/15/2005 2950 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianne Hamden on June 28, 2005 (Hulla, Patrick) (Entered: 06/15/2005)

06/15/2005 2951 MOTION for attorney Joseph H. Guffey to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Joseph H. Guffey)(Hulla, Patrick) (Entered: 06/15/2005)

06/15/2005 2952 MOTION for attorney Michael F. Jones to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Michael F. Jones)(Hulla, Patrick) (Entered: 06/15/2005)

06/15/2005

PRO HAC VICE FEE PAID: on 6/15/05 re: 2951 MOTION for attorney Joseph H. Guffey to appear pro hac vice in the amount of $50.00. Receipt Number 108660. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 06/15/2005)

06/15/2005

PRO HAC VICE FEE PAID: on 6/15/05 re: 2952 MOTION for attorney Michael F. Jones to appear pro hac vice in the amount of $50.00. Receipt Number 108661. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 06/15/2005)

06/16/2005 2953 ORDER memorializing the Court's rulings at the 3/30/2005 discovery conference held before Magistrate Judge David J. Waxse. (SEE ORDER FOR DETAIL.) Signed by Magistrate Judge David J. Waxse on 6/16/2005. (jm) (Entered: 06/16/2005)

06/16/2005

2954

ORDER granting 2951 and 2952 Motions to Appear Pro Hac Vice. Joseph H. Guffey and Michael F. Jones are granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a registration form at www.ksd.uscourts.gov/features/forms/pdfforms/efilereg.pdf. Signed by Magistrate Judge David J. Waxse on 06/16/05. (mg) (Entered: 06/16/2005)

06/17/2005 2955 Minute Entry for Discovery/Status Conference held on 6/16/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 7/07/2005 at 3:00 p.m.. (byk) (Conference date corrected in text on 6/17/2005. (mg)) (Entered: 06/17/2005)

06/17/2005

NOTICE of docket text modification by Deputy Clerk regarding Minute Entry of Status Conference 2955 : Note that the date of the next discovery conference has been corrected in the docket text to reflect the date as 07/07/05. (mg) (Entered: 06/17/2005)

06/17/2005 2956 MOTION for extension of time (Opposed) to Respond to Plaintiff's Ninth Request for Production of Documents and Things and Plaintiff's Eight Interrogatories by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit Exhibit A E−mail Correspondence)(Hulla, Patrick) (Entered: 06/17/2005)

06/17/2005

2957

ORDER NUNC PRO TUNC re 2953 Order. The Court hereby corrects the first sentence of this Order to read: "On June 9, 2005, the Court conducted a discovery conference in this case." Entered by Magistrate Judge David J. Waxse on 6/17/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 06/17/2005)

06/20/2005 2958 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 2938 MOTION for Protective Order Regarding Advertising and Marketing Discovery (Graham, Gene) (Entered: 06/20/2005)

06/20/2005 2959 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Fifth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1). (Egan, Dennis) (Entered: 06/20/2005)

06/21/2005 2960 REPLY to Response to Motion by Plaintiff Shirley Williams re: 2920 MOTION to Accept Two Consents to Join Out of Time (Attachments: # 1)(Braud, Bert) (Entered: 06/21/2005)

06/21/2005 2961 NOTICE of Non−Compliance by Sprint/United Management Company and Plaintiff Shirley Williams (Attachments: # 1 Exhibit A to Notice of Non−Compliance)(Yates, John) (Entered: 06/21/2005)

06/22/2005 2962 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeff Martin on June 24, 2005 (Hulla, Patrick) (Entered: 06/22/2005)

06/22/2005 2963 SUPPLEMENT to Plaintiff's Reply to Defendant's Memorandum in Opposition to Plaintiff's Motion to Accept Two Consents to Join Out of Time by Plaintiff Shirley Williams. (Attachments: # 1)(Egan, Dennis) (Document Title Modified on 6/23/2005. (mg)) (Entered: 06/22/2005)

06/22/2005

2964

(INCOMPLETE DOCUMENT; See document #2968.) ORDER memorializing the Court's rulings at the discovery conference held before Magistrate Judge David J. Waxse on 6/16/2005. (See Order for detail.) Signed by Magistrate Judge David J. Waxse on 6/22/2005.(jm) (Modified on 6/24/2005 to reflect document incomplete. (mg)) (Entered: 06/22/2005)

06/22/2005 2965 ORDER regarding 2961 Notice of non−compliance filed by Sprint/United Management Company. The court dismisses with prejudice the claims of the individuals identified in Exhibit A. Signed by Judge John W. Lungstrum on 06/28/2005. (Attachments: # 1 Exhibit A)(ses) (Entered: 06/22/2005)

06/23/2005 2966 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Julia Hicks on June 29, 2005 (Hulla, Patrick) (Entered: 06/23/2005)

06/23/2005 2967 RESPONSE by Defendant Sprint/United Management Company re 2964 Order Response to Show Cause Order (Yates, John) (Entered: 06/23/2005)

06/23/2005 2968 RESPONSE re 2674 Order to Show Cause by Defendant Sprint/United Management Company (Yates, John) (Entered: 06/23/2005)

06/24/2005 2969 CERTIFICATE OF SERVICE by Sprint/United Management Company for Supplemental Discovery Responses. (Hulla, Patrick) (Entered: 06/24/2005)

06/27/2005 2970 ORDER setting a Motion Hearing for 7/26/2005 at 04:00 PM before Chief Judge John W. Lungstrum.. This hearing will be held in Courtroom #427. Signed by Judge John W. Lungstrum on 06/27/2005. (ses) (Entered: 06/27/2005)

06/27/2005 2971 ORDER granting 2919 Motion to Withdraw Opt−in Plaintiff Tony Scelza. Signed by Judge John W. Lungstrum on 06/27/05. (mg) (Entered: 06/27/2005)

06/27/2005 2972 UNOPPOSED MOTION for Extension of Time to File reply as to 2946 Memorandum in Opposition to Motion, (Motion for Leave to Consolidate Actions and to File Second Amended Complaint) by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 06/27/2005)

06/27/2005 2973 CERTIFICATE OF SERVICE by Sprint/United Management Company regarding Sprint Response to Plaintiff's 9th Request for Production and Sprint Answers to Plaintiffs' 8th Interrogatories. (Hulla, Patrick) (Entered: 06/27/2005)

06/28/2005 2974 ORDER granting 2972 unopposed Motion for Extension of Time to File Reply re 2902 MOTION for Leave to Consolidate Actions and to file Second Amended complaint. Reply deadline extended to 7/1/2005 . Signed by Judge John W. Lungstrum on 06/28/2005. (ses) (Entered: 06/28/2005)

06/29/2005 2975 MOTION for Order to Accept the Late Consent of Michael Witt by Plaintiff Shirley Williams (Attachments: # 1 Affidavit Attachment)(Egan, Dennis) (Entered: 06/29/2005)
06/30/2005 2976 CERTIFICATE OF SERVICE by Sprint/United Management Company regarding 4th Interrogatories to Plaintiff and 4th Request for Production of Documents to Plaintiff. (Hulla, Patrick) (Entered: 06/30/2005)
06/30/2005 2977 Supplement to Plaintiffs' Motion to Accept the Late Consent of Michael Witt by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 06/30/2005)
07/01/2005 2978 REPLY MEMORANDUM IN SUPPORT of 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint by Plaintiff Shirley Williams.(Hubbard, Dirk) (Document Title Modified on 7/5/2005. (mg)) (Entered: 07/01/2005)
07/01/2005 2979 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steven D. Colton on July 18, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/01/2005 2980 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Bauman on July 18, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/01/2005 2981 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mindy Cleary on July 19, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/01/2005 2982 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mark Cragin on July 19, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/01/2005 2983 NOTICE by Defendant Sprint/United Management Company of taking deposition of Harold Taylor on July 19, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/01/2005 2984 NOTICE by Defendant Sprint/United Management Company of taking deposition of Judy Budihas on July 18, 2005 (Hulla, Patrick) (Entered: 07/01/2005)
07/05/2005 2985 NOTICE by Defendant Sprint/United Management Company of taking deposition of Andrew Justesen on July 20, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2986 NOTICE by Defendant Sprint/United Management Company of taking deposition of Doug Curts on July 20, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2987 NOTICE by Defendant Sprint/United Management Company of taking deposition of Pamela Emler on July 20, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2988 NOTICE by Defendant Sprint/United Management Company of taking deposition of Suzanne North on July 20, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2989 NOTICE by Defendant Sprint/United Management Company of taking deposition of Melanie Richards on July 20, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2990 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeff Martin on August 30, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2991 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nancy Johnson on July 21, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2992 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rebecca Haaven on July 21, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2993 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dale A. Dupuis on July 21, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2994 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Kay Russo on July 21, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2995 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eleanor Gorton on August 1, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2996 NOTICE by Defendant Sprint/United Management Company of taking deposition of Teresa Warnick on August 1, 2005 (Hulla, Patrick) (Entered: 07/05/2005)
07/05/2005 2997 NOTICE by Plaintiff Shirley Williams of taking deposition of Linda Gamso (Klamann, John) (Entered: 07/05/2005)

07/05/2005 2998 NOTICE by Plaintiff Shirley Williams of taking deposition of Shawn Kinkade (Klamann, John) (Entered: 07/05/2005)

07/05/2005 2999 NOTICE by Plaintiff Shirley Williams of taking deposition of Matt Goettsch (Klamann, John) (Entered: 07/05/2005)

07/05/2005 3000 NOTICE by Plaintiff Shirley Williams of taking deposition of Donna Morrison (Klamann, John) (Entered: 07/05/2005)

07/05/2005 3001 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative for Sprint re selection of Shirley Williams for a RIF termination (Klamann, John) (Entered: 07/05/2005)

07/05/2005 3002 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 2938 MOTION for Protective Order Regarding Advertising and Marketing Discovery (Hulla, Patrick) (Entered: 07/05/2005)

07/06/2005 3003 NOTICE by Defendant Sprint/United Management Company of taking deposition of Georgia Milliren on August 2, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3004 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Loetel on August 2, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3005 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steve Constance on August 3, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3006 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nancy Tweedy on August 4, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3007 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Haskins on August 4, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3008 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bert Allen on August 8, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3009 NOTICE by Defendant Sprint/United Management Company of taking deposition of Constance Bonovich on August 8, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3010 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Gartin on August 8, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3011 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rex Hull on August 9, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3012 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kathy Nicol on August 9, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3013 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Boyer on August 9, 2005 (Hulla, Patrick) (Entered: 07/06/2005)

07/06/2005 3014 SUPPLEMENTAL RESPONSE by Defendant Sprint/United Management Company re 2953 Order to Show Cause. (Yates, John) (Document Title Modified on 7/7/2005. (mg)) (Entered: 07/06/2005)

07/06/2005 3015 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Sixth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1). (Egan, Dennis) (Entered: 07/06/2005)

07/07/2005 3016 MOTION to Set Aside and/or Modify and Objections to Magistrate Judge's Order (Doc. 2964) by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 07/07/2005)

07/07/2005

3017

MEMORANDUM IN SUPPORT of 3016 MOTION to Set Aside and/or Modify and Objections to Magistrate Judge's Order (Doc. 2964) by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A−Excerpts from Responses and Objections to Plaintiff's 1st Request for Production of Documents# 2 Exhibit B−Letter from Plaintiff's Counsel to Madgistrate Judge Waxse of 5/4/05# 3 Exhibit C−Excerpts of May 5, 2005 Status Conference# 4 Exhibit D−Excerpts from May 19, 2005 Status Conference# 5 Exhibit E−excerpt of transcript of June 2, 2005 Status Conference# 6 Exhibit F−Letter from Plaintiff's counsel to Defendant's counsel# 7 Exhibit

G−excerpted transcript of February 6, 2004 Hearing# 8 Exhibit H−excerpts from Defendant's Response to Plaintiff's 7th Request for Production of Documents# 9 Exhibit I−excerpt of Defendant's Responses to Plaintiff's 8th Request for Production# 10 Exhibit J−excerpts of Defendant's Responses to Plaintiff's Sixth Request for Production of Documents# 11 Exhibit K−excerpt of transcript from June 16, 2005 Hearing)(Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3018 NOTICE by Defendant Sprint/United Management Company of taking deposition of Delores Packer on August 10, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3019 NOTICE by Defendant Sprint/United Management Company of taking deposition of Barry Pascal on August 10, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3020 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rosemary Milton on August 10, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3021 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jerry Hipp on August 11, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3022 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Dawson on August 11, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/07/2005 3023 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dan Dietz on August 11, 2005 (Hulla, Patrick) (Entered: 07/07/2005)
07/08/2005 3024 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Digirlarmo on August 22, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3025 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marilyn Lankard on August 23, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3026 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donald Wright on August 23, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3027 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patricia Decker on August 24, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3028 NOTICE by Defendant Sprint/United Management Company of taking deposition of Travis French on August 24, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3029 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Hollingsworth on August 24, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3030 NOTICE by Defendant Sprint/United Management Company of taking deposition of Charles Bell on August 25, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3031 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Ragan on August 25, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3032 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeri Swafford on August 25, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3033 NOTICE by Defendant Sprint/United Management Company of taking deposition of Alissa Ross on September 26, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3034 NOTICE by Defendant Sprint/United Management Company of taking deposition of Janiece A. Cline on September 27, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/08/2005 3035 NOTICE by Defendant Sprint/United Management Company of taking deposition of Scott Farley on September 28, 2005 (Hulla, Patrick) (Entered: 07/08/2005)
07/11/2005 3036 Minute Entry for Discovery/Status Conference held on 7/07/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 7/21/2005 at 3:00 p.m. (byk) (Entered: 07/11/2005)
07/12/2005 3037 ORDER granting 2938 Defendant's Motion for Protective Order Regarding Advertising and Marketing Discovery, granting 2956 Defendant's Opposed Motion to Extend Deadline to Respond to Plaintiff's Ninth Request for Production of Documents and Things and Plaintiff's Eighth Interrogatories. This Order further memorializes the

Court's rulings at the July 7, 2005 discovery conference. (See Order for detail.) Signed by Magistrate Judge David J. Waxse on 7/12/2005.(jm) (Entered: 07/12/2005)
07/12/2005 3038 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)6 Notice re 2003 AAR (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3039 NOTICE by Plaintiff Shirley Williams of taking deposition of Al Kurtze (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3040 NOTICE by Plaintiff Shirley Williams of taking deposition of Alan Sykes (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3041 NOTICE by Plaintiff Shirley Williams of taking deposition of Ana Jensen (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3042 NOTICE by Plaintiff Shirley Williams of taking deposition of Bob Thompson (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3043 NOTICE by Plaintiff Shirley Williams of taking deposition of Carol Bussing (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3044 NOTICE by Plaintiff Shirley Williams of taking deposition of Chris Hines (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3045 NOTICE by Plaintiff Shirley Williams of taking deposition of Cody Krause (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3046 NOTICE by Plaintiff Shirley Williams of taking deposition of Craig Childs (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3047 NOTICE by Plaintiff Shirley Williams of taking deposition of Deborah Simpson (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3048 NOTICE by Plaintiff Shirley Williams of taking deposition of Dick Green (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3049 NOTICE by Plaintiff Shirley Williams of taking deposition of Don Hallacy (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3050 NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Lampe (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3051 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative re: Governance Reviews (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3052 NOTICE by Plaintiff Shirley Williams of taking deposition of Harry Campbell (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3053 NOTICE by Plaintiff Shirley Williams of taking deposition of Jackie McQuery (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3054 NOTICE by Plaintiff Shirley Williams of taking deposition of James Stilley (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3055 NOTICE by Plaintiff Shirley Williams of taking deposition of Jeanine Strandjord (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3056 NOTICE by Plaintiff Shirley Williams of taking deposition of Jim Hansen (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3057 NOTICE by Plaintiff Shirley Williams of taking deposition of Joane Wlaker (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3058 NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Rose (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3059 NOTICE by Plaintiff Shirley Williams of taking deposition of Karin Miller (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3060 NOTICE by Plaintiff Shirley Williams of taking deposition of Kathy Walker (Klamann, John) (Entered: 07/12/2005)

07/12/2005 3061 NOTICE by Plaintiff Shirley Williams of taking deposition of Kurt Fawkes (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3062 NOTICE by Plaintiff Shirley Williams of taking deposition of Leon Lang (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3063 NOTICE by Plaintiff Shirley Williams of taking deposition of Mark Ryan (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3064 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Homola (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3065 NOTICE by Plaintiff Shirley Williams of taking deposition of Mike Upchurch (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3066 NOTICE by Plaintiff Shirley Williams of taking deposition of Mitch Gold (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3067 NOTICE by Plaintiff Shirley Williams of taking deposition of Nick Sweers (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3068 NOTICE by Plaintiff Shirley Williams of taking deposition of Pam Winterman (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3069 NOTICE by Plaintiff Shirley Williams of taking deposition of Paul Scheiber (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3070 NOTICE by Plaintiff Shirley Williams of taking deposition of Ralph Hodge (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3071 NOTICE by Plaintiff Shirley Williams of taking deposition of Rick McCrae (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3072 NOTICE by Plaintiff Shirley Williams of taking deposition of Rick Walter (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3073 NOTICE by Plaintiff Shirley Williams of taking deposition of Robin O'Conner (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3074 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Caruthers (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3075 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Winkler (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3076 NOTICE by Plaintiff Shirley Williams of taking deposition of Sheryl Cooper (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3077 NOTICE by Plaintiff Shirley Williams of taking deposition of Tammy Kenney (Klamann, John) (Entered: 07/12/2005)
07/12/2005 3078 NOTICE by Plaintiff Shirley Williams of taking deposition of Tim Kelley (Klamann, John) (Entered: 07/12/2005)
07/13/2005 3079 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re the Catalyst meeting (Klamann, John) (Entered: 07/13/2005)
07/13/2005 3080 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re merit increases, etc. (Klamann, John) (Entered: 07/13/2005)
07/13/2005 3081 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re Exhibit 1011, etc. (Klamann, John) (Entered: 07/13/2005)
07/13/2005 3082 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 2975 MOTION for Order to Accept the Late Consent of Michael Witt and Motion to Supplement Plaintiff's Motion to Accept the Late Consent of Michael Witt (Doc. 2977) (Hulla, Patrick) (Entered: 07/13/2005)
07/13/2005 3083 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Seventh Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1): July 13, 2005. (Egan, Dennis) (Entered: 07/13/2005)

07/14/2005 3084 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sally Juhn on July 18, 2005 (Hulla, Patrick) (Entered: 07/14/2005)

07/14/2005 3085 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dawne Adams on July 19, 2005 (Hulla, Patrick) (Entered: 07/14/2005)

07/14/2005 3086 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eugene Laessig on July 20, 2005 (Hulla, Patrick) (Entered: 07/14/2005)

07/14/2005

3087

RESPONSE by Defendant Sprint/United Management Company re 3037 Order on Motion for Protective Order, Order on Motion for Extension of Time, dated July 12, 2005, Paragraph 6. (Attachments: # 1 Exhibit A−Excerpt from 5/2/04 Hearing Transcript# 2 Exhibit B−excerpt from 3/31/05 Status Conference Transcript# 3 Exhibit C−Excerpt from 2/27/04 Status Conference Transcript# 4 Exhibit D−Excerpt from 5/19/05 Status Conference Transcript# 5 Exhibit E−Correspondence from Mr. Hubbard to Judge Waxse of 5/4/05# 6 Exhibit F−Excerpt from 5/5/05 Status Conference Transcript# 7 Exhibit G−Excerpt of 6/2/05 Status Conference Transcript# 8 Exhibit H−Correspondence from Mr. Egan to Mr. Yates dated 5/11/05# 9 Exhibit I−Correspondence to Messrs. Yates, Dupont, Hulla from Mr. Braud dated 6/27/05# 10 Exhibit J−Correspondence to Mr. Braud from Mr. Yates dated 7/6/05)(Hulla, Patrick) (Entered: 07/14/2005)

07/15/2005 3088 NOTICE by Defendant Sprint/United Management Company of taking deposition of Larry Brice on August 1, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3089 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Cezar on August 1, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3090 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donald Darden on August 2, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3091 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Hoopes on August 2, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3092 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Molz on August 3, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3093 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gary Owens on August 3, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/15/2005 3094 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Wissman on August 3, 2005 (Hulla, Patrick) (Entered: 07/15/2005)

07/18/2005 3095 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Right Management Consultants, Inc. on August 1, 2005 (Attachments: # 1 Subpoena)(Klamann, John) (Entered: 07/18/2005)

07/18/2005

3096

ORDER re 3087 RESPONSE by Defendant Sprint/United Management Company re 3037 Order on Motion for Protective Order, Order on Motion for Extension of Time, dated July 12, 2005, Paragraph 6. Plaintiffs shall file and serve their pleading in reply to Defendant's Response (doc. 3087) no later than 9:00 a.m. on July 21, 2005 unless they can show cause why they need additional time to file their reply. Entered by Magistrate Judge David J. Waxse on 7/18/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 07/18/2005)

07/18/2005 3097 NOTICE by Defendant Sprint/United Management Company of taking deposition of Darrell Denton on August 8, 2005 (Hulla, Patrick) (Entered: 07/18/2005)

07/18/2005 3098 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Grahovac on August 9, 2005 (Hulla, Patrick) (Entered: 07/18/2005)

07/18/2005 3099 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert James on August 11, 2005 (Hulla, Patrick) (Entered: 07/18/2005)

07/20/2005 3100 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Supplemental Requests for Production of Documents and Plaintiffs' Ninth Interrogatories (Klamann, John) Modified on 7/21/2005 (mg, ). (Entered: 07/20/2005)

07/20/2005 3101 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Chuck Levine on July 22, 2005 (Klamann, John) (Entered: 07/20/2005)

07/20/2005 3102 MEMORANDUM in Opposition by Plaintiff Shirley Williams regarding 3016 MOTION to Set Aside and/or Modify and Objections to Magistrate Judge's Order (Doc. 2964) (Hubbard, Dirk) (Duplicate text removed on 7/21/2005. (mg)) (Entered: 07/20/2005)

07/20/2005 3103 CERTIFICATE OF SERVICE by Shirley Williams of Plaintiffs' Eighth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1), 7/20/05. (Egan, Dennis) (Entered: 07/20/2005)

07/21/2005 3104 RESPONSE by Plaintiff Shirley Williams re 3037 Order on Motion for Protective Order and Order on Motion for Extension of Time, (Order for Defendant to Show Cause) (Hubbard, Dirk) Modified on 7/22/2005 (yh, ). (Entered: 07/21/2005)

07/21/2005 3105 RESPONSE by Defendant Sprint/United Management Company re 2953 Order of Court dated June 16, 2005 (Hulla, Patrick) (Entered: 07/21/2005)

07/21/2005 3106 MOTION for Review and Objections to Magistrate Judge's Order (Doc. 3037) by Plaintiff Shirley Williams(Graham, Gene) (Entered: 07/21/2005)

07/21/2005 3107 MEMORANDUM IN SUPPORT of 3106 MOTION for Review and Objections to Magistrate Judge's Order (Doc. 3037) by Plaintiff Shirley Williams(Graham, Gene) (Entered: 07/21/2005)

07/21/2005 3108 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Right Management Consultants, Inc. on 07/20/05 by Personal (Klamann, John) (Entered: 07/21/2005)

07/22/2005 3109 Minute Entry for Discovery/Status Conference held on 7/21/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for Wednesday 8/03/2005 at 3:00 p.m. (byk) (Entered: 07/22/2005)

07/25/2005

3110

ORDER memorializing the Court's rulings at the July 21, 2005 status conference held before Magistrate Judge David J. Waxse. The next Discovery/Status Conference is hereby set for 8/3/2005 at 03:00 PM before Magistrate Judge David J. Waxse. (See Order for further deadlines.) Signed by Magistrate Judge David J. Waxse on 7/25/2005.(jm) (Entered: 07/25/2005)

07/26/2005 3111 NOTICE by Plaintiff Shirley Williams of taking deposition of Elaine Bishop (Klamann, John) (Entered: 07/26/2005)

07/26/2005 3112 NOTICE by Plaintiff Shirley Williams of taking deposition of Mitzi Miller (Klamann, John) (Entered: 07/26/2005)

07/26/2005

3113

Minute Entry for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 7/26/2005 re 2920 MOTION to Accept Two Consents to Join Out of Time filed by Shirley Williams, 2902 MOTION for Leave to Amend Complaint re 286 Amended Complaint filed by Shirley Williams, 2975 MOTION for Order to Accept the Late Consent of Michael Witt filed by Shirley Williams. (SEE MINUTE SHEET FOR DETAILS) (Court Reporter Becky Ryder.) (ses) (Entered: 07/27/2005)

07/26/2005

3115

ORDER vacating 2820 Amended Second Phase Scheduling Order but any deadlines set by Judge Waxse regarding the presentation or resolution of discovery disputes remain intact. Signed by Judge John W. Lungstrum on 07/26/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 07/27/2005)

07/27/2005

3114

ORDER taking under advisement 2902 Motion for Leave to Amend Complaint; granting 2920 Motion for Joinder; and granting 2975 Motion for Order. The individuals listed in the motions must file their consent to join forms no later than Friday, August 5, 2005 and must provide to defendant completed questionnaires no later than Friday, August 12, 2005. Signed by Judge John W. Lungstrum on 07/26/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 07/27/2005)

07/28/2005

3116

ORDER: The Discovery/Status Conference set for 8/3/2005 at 3:00 PM is hereby rescheduled for 2:00 PM on the same date before Magistrate Judge David J. Waxse in Courtroom 223. Entered by Magistrate Judge David J. Waxse on 7/28/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 07/28/2005)

07/28/2005 3117 NOTICE by Defendant Sprint/United Management Company of taking deposition of Neil Sieber on August 1, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3118 NOTICE by Defendant Sprint/United Management Company of taking deposition of Tammy Darling on August 2, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3119 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Herren on August 2, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3120 NOTICE by Defendant Sprint/United Management Company of taking deposition of Harold Fesmire on August 3, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3121 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mary J. Jackson on August 4, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3122 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Boehm on August 4, 2005 (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3123 RESPONSE Reply of Defendant to Plaintiff's Memorandum in Opposition to Defendant's Response to July 12, 2005 Order Paragraph Six (6) (Doc. 3037) by Defendant Sprint/United Management Company. (Hulla, Patrick) (Entered: 07/28/2005)

07/28/2005 3124 NOTICE of Consent of Michael H. Witt by Shirley Williams (Dennis, Stephen) (Entered: 07/28/2005)

07/29/2005

3125

MEMORANDUM AND ORDER granting in part and denying in part 2902 Motion for Leave to Consolidate Actions and to File Second Amended Complaint. Plaintiffs shall file their second amended complaint, consistent with this order, no later than 08/12/2005. Terry Lee Cocherl, Carolyn Selberg, John Borel, Steve Constance, and Peggy Sturgess shall file their consent to join forms no later than 08/12/2005 if they desire to opt in to this collective action and they must provide defendant completed questionnaires no later than 08/26/2005. Signed by Judge John W. Lungstrum on 07/29/2005. (ses) (Entered: 07/29/2005)

08/01/2005 3126 NOTICE of Conset to Join by Sandra M. Cuskaden by Shirley Williams (Hubbard, Dirk) (Entered: 08/01/2005)

08/01/2005 3127 Unopposed MOTION for extension of time to Serve Responses to Defendant's Fourth Interrogatories and Fourth Request for Production of Documents by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 08/01/2005)

08/02/2005

3128

ORDER granting 3127 Plaintiffs' Unopposed MOTION for Extension of Time. Plaintiffs are hereby granted an extention of time, up to and including September 8, 2005, to serve their responses to Defendant's Fourth Interrogatories and Defendant's Fourth Request for Production of Documents. Entered by Magistrate Judge David J. Waxse on 8/2/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 08/02/2005)

08/02/2005 3129 NOTICE of Consent to Join by Maxine Coffey by Shirley Williams (Egan, Dennis) (Entered: 08/02/2005)

08/03/2005 3130 Minute Entry for Discovery/Status Conference held on 8/3/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 8/18/2005 at 2:00 p.m. (byk) (Entered: 08/03/2005)

08/03/2005 3131 ORDER memorializing the Court's rulings at the 8/3/2005 Discovery Conference. Signed by Magistrate Judge David J. Waxse on 8/3/2005. (byk) (Entered: 08/03/2005)

08/03/2005 3132 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3016 MOTION to Set Aside and/or Modify and Objections to Magistrate Judge's Order (Doc. 2964) (Attachments: # 1 Exhibit A−Transcript Excerpt# 2 Exhibit

B−Transcript Excerpt# 3 Exhibit C−EEOC Correspondence# 4 Exhibit D−Transcript Excerpt)(Hulla, Patrick) (Entered: 08/03/2005)
08/04/2005 3133 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffrey Moore on August 8, 2005 (Hulla, Patrick) (Entered: 08/04/2005)
08/04/2005 3134 NOTICE by Defendant Sprint/United Management Company of taking deposition of Tony Schroeder on August 9, 2005 (Hulla, Patrick) (Entered: 08/04/2005)
08/04/2005 3135 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patricia Barbe on August 9, 2005 (Hulla, Patrick) (Entered: 08/04/2005)
08/04/2005 3136 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kathy Bell on August 10, 2005 (Hulla, Patrick) (Entered: 08/04/2005)
08/04/2005 3137 SUR−REPLY by Plaintiff Shirley Williams to Defendant's Reply to Plaintiffs' Memorandum in Opposition to Defendant's Response to 3037 Order on Motion for Protective Order, Order on Motion for Extension of Time Paragraph Six. (Hubbard, Dirk) (Document Title Modified on 8/5/2005. (mg)) (Entered: 08/04/2005)
08/04/2005 3138 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3106 MOTION for Review and Objections to Magistrate Judge's Order (Doc. 3037) (Hulla, Patrick) (Entered: 08/04/2005)
08/05/2005 3139 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joel Blumenthal on August 12, 2005 (Hulla, Patrick) (Entered: 08/05/2005)
08/05/2005 3140 NOTICE by Defendant Sprint/United Management Company of taking deposition of Agus Budiardjo on August 12, 2005 (Hulla, Patrick) (Entered: 08/05/2005)
08/08/2005 3141 CERTIFICATE OF SERVICE by Sprint/United Management Company re 2999 Notice to Take Deposition, 3001 Notice to Take Deposition Responses and Objections. (Hulla, Patrick) (Entered: 08/08/2005)
08/09/2005 3142 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Brown on August 15, 2005 (Hulla, Patrick) (Entered: 08/09/2005)
08/09/2005 3143 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cheryl Hurst on August 15, 2005 (Hulla, Patrick) (Entered: 08/09/2005)
08/09/2005 3144 NOTICE by Defendant Sprint/United Management Company of taking deposition of Anita Reeves on August 18, 2005 (Hulla, Patrick) (Entered: 08/09/2005)
08/09/2005 3145 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Digirlarmo on August 18, 2005 (Hulla, Patrick) (Entered: 08/09/2005)
08/09/2005 3146 TRANSCRIPT (pages 1−30) of proceedings on 06/09/05 held before Magistrate Judge David J. Waxse. (Attachments: #(1) Part 2 −− pages 31−69)(mg) (Entered: 08/09/2005)
08/09/2005 3147 TRANSCRIPT (pages 1−74) of proceedings on 07/07/05 held before Magistrate Judge David J. Waxse. (mg) (Entered: 08/09/2005)
08/09/2005 3148 TRANSCRIPT (pages 1−25) of proceedings on 07/21/05 held before Magistrate Judge David J. Waxse. (Attachments: # 1 Part 2 −− pages 26−55)(mg) (Entered: 08/09/2005)
08/10/2005 3149 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jon Gallion on August 22, 2005 (Hulla, Patrick) (Entered: 08/10/2005)
08/10/2005 3150 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Westbrook on August 22, 2005 (Hulla, Patrick) (Entered: 08/10/2005)
08/11/2005 3151 RESPONSE by Plaintiff Shirley Williams re 3125 Order on Motion for Leave to Amend Complaint,, and Order to file by August 12, 2005, Consents to Join for Terry Lee Cocherl; Carolyn Selberg; John Borel; Steve Constance; and Peggy Sturgess (Attachments: # 1 # 2 # 3)(Egan, Dennis) (Entered: 08/11/2005)

08/11/2005 3152 NOTICE by Defendant Sprint/United Management Company of taking deposition of Judith Gaffney on August 23, 2005 (Hulla, Patrick) (Entered: 08/11/2005)

08/11/2005 3153 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eldon Elliot on August 23, 2005 (Hulla, Patrick) (Entered: 08/11/2005)

08/11/2005 3154 NOTICE by Defendant Sprint/United Management Company of taking deposition of Edward Blinco on August 23, 2005 (Hulla, Patrick) (Entered: 08/11/2005)

08/11/2005 3155 NOTICE OF SERVICE by Shirley Williams of Questionnaires for Michael Witt, Sandra Cuskaden and Maxine Coffey (Egan, Dennis) (Entered: 08/11/2005)

08/12/2005

3156

(THIS DOCUMENT HAS BEEN STRICKEN IN IT'S ENTIRETY FROM THE RECORD. See 3410 Memorandum and Order.) SECOND AMENDED COMPLAINT filed by Shirley Williams and all Opt−In Plaintiffs against all defendants, filed by Shirley Williams.(Egan, Dennis) (Document title modified on 8/15/2005. (mg)) (Document stricken on 11/1/2005. (mg)) (Entered: 08/12/2005)

08/12/2005

3157

MEMORANDUM AND ORDER granting in part and denying in part 3016 Motion to Set Aside and/or modify and objections to the magistrate judge's June 22, 2005 order. Defendant shall produce documents responsive to the requests within 30 days of the date of this order. If defendant cannot in good faith meet this deadline, it shall notify the court within 14 days of the date of this order that it needs additional time to fulfill its discovery obligations, when it anticipates it will be able to fulfill its obligations, and the reasons that the obligations cannot be met within the 30 day time frame. Signed by Judge John W. Lungstrum on 08/12/2005. (ses) (Entered: 08/12/2005)

08/12/2005 3158 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative (Klamann, John) (Entered: 08/12/2005)

08/12/2005 3159 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Meinhardt on August 24, 2005 (Hulla, Patrick) (Entered: 08/12/2005)

08/12/2005 3160 NOTICE by Defendant Sprint/United Management Company of taking deposition of Janice Wheeler on August 24, 2005 (Hulla, Patrick) (Entered: 08/12/2005)

08/12/2005 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint, and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01 by Plaintiff Shirley Williams. (Egan, Dennis) (Entered: 08/12/2005)

08/12/2005

3162

EXHIBIT(S) IN SUPPORT of 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint, and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01 by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit Letter of 4/1/05; #(2) Exhibit Letter of 4/1/05; #(3) Exhibit Letter of 5/5/05; #(4) Exhibit Letter of 9/24/04)(Egan, Dennis) (Entered: 08/12/2005)

08/12/2005

3163

MEMORANDUM IN SUPPORT of 3161 MOTION for Reconsideration re 3125 Order on Motion for Leave to Amend Complaint,, and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees; and Opt−Ins Terminated Between 7/23/01 and 10/1/01 by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 08/12/2005)

08/15/2005 3164 NOTICE by Defendant Sprint/United Management Company of taking deposition of Alecia Cripps on August 25, 2005 (Hulla, Patrick) (Entered: 08/15/2005)

08/15/2005 3165 NOTICE by Defendant Sprint/United Management Company of taking deposition of Anthony Young on August 25, 2005 (Hulla, Patrick) (Entered: 08/15/2005)

08/15/2005 3166 CERTIFICATE OF SERVICE by Sprint/United Management Company. (Hulla, Patrick) (Entered: 08/15/2005)

08/16/2005 3167 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Representative concerning Bates 149908−14 (Klamann, John) (Entered: 08/16/2005)

08/16/2005 3168 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Representative to testify regarding page 21 of Exhibit 29 (Klamann, John) (Entered: 08/16/2005)

08/18/2005 3169 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3106 MOTION for Review and Objections to Magistrate Judge's Order (Doc. 3037) (Attachments: # 1 Exhibit 1)(Graham, Gene) (Entered: 08/18/2005)

08/18/2005 3170 Minute Entry for Discovery/Status Conference held on 8/18/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 9/1/2005 at 2:00 p.m. (byk) (Entered: 08/18/2005)

08/18/2005 3171 MOTION to Vacate 127 Order Regarding Treatment of Social Security Numbers in Discovery Responses by Plaintiff Shirley Williams. (Meyers, Martin) (Text modified on 8/19/2005. (mg)) (Entered: 08/18/2005)

08/18/2005 3172 MEMORANDUM IN SUPPORT of 3171 MOTION to Vacate 127 Order Regarding Treatment of Social Security Numbers in Discovery Responses by Plaintiff Shirley Williams. (Meyers, Martin) (Text modified on 8/19/2005. (mg)) (Entered: 08/18/2005)

08/19/2005 3173 ENTRY OF APPEARANCE by Kenneth B. McClain on behalf of Shirley Williams. (McClain, Kenneth) (Entered: 08/19/2005)

08/19/2005 3174 ORDER from 8/18/2005 Discovery Conference before Magistrate Judge Waxse. See Order for details. Signed by Magistrate Judge David J. Waxse on 8/19/2005. (byk) (Entered: 08/19/2005)

08/22/2005 3175 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Bauman on August 26, 2005 (Hulla, Patrick) (Entered: 08/22/2005)

08/22/2005 3176 AMENDED DOCUMENT by Shirley Williams. Amendment to 3169 Reply to Response to Motion. (Graham, Gene) (Entered: 08/22/2005)

08/22/2005 3177 Unopposed MOTION for extension of time to Respond to Plaintiff's Ninth Interrogatories to Defendant Sprint by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 08/22/2005)

08/22/2005 3178 CERTIFICATE OF SERVICE by Sprint/United Management Company re Defendant's Response to Plaintiff's Supplemental (i.e., Tenth) Request for Production of Documents. (Hulla, Patrick) (Entered: 08/22/2005)

08/23/2005

3179

ORDER granting 3177 Unopposed Motion to Extend Deadline for Sprint to Respond to Plaintiff's Ninth Interrogatories to Defendant Sprint. Defendant Sprint/United Management Company shall have until September 6, 2005 to answer, and otherwise respond to, Plaintiff's Ninth Interrogatories to Defendant Sprint, including any objections thereto. Entered by Magistrate Judge David J. Waxse on 8/23/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/23/2005)

08/26/2005 3180 NOTICE by Plaintiff Shirley Williams of taking deposition of Twila Skelton on September 20, 2005 (Graham, Gene) (Entered: 08/26/2005)

08/26/2005 3181 NOTICE of Additional Time to Comply with the Court's August 12, 2005 Order and Motion and Suggestions for the Court's Order Granting Additional Time by Sprint/United Management Company (Hulla, Patrick) (Entered: 08/26/2005)

08/26/2005

3182

MEMORANDUM in Opposition by Defendant Sprint/United Management Company regarding 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint,and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01. (Attachments: #(1) Exhibit A; #(2) Exhibit B; #(3) Exhibit C; #(4) Exhibit D; #(5) Exhibit E; #(6) Exhibit F; #(7) Exhibit G)(Hulla, Patrick) (Entered: 08/26/2005)

08/26/2005 3183 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 08/26/2005)

08/29/2005 3184 MOTION to Strike 3156 Portions of Second Amended Complaint by Defendant Sprint/United Management Company. (Hulla, Patrick) (Document title modified on 8/30/2005. (mg) (Entered: 08/29/2005)

08/29/2005 3185 MEMORANDUM IN SUPPORT of 3184 MOTION to Strike 3156 Portions of Second Amended Complaint by Defendant Sprint/United Management Company. (Hulla, Patrick) (Motion title modified on 8/30/2005. (mg)) (Entered: 08/29/2005)

08/29/2005 3186 ANSWER to Amended Complaint (Second) and Affirmative Defenses by Sprint/United Management Company.(Yates, John) (Entered: 08/29/2005)

08/30/2005 3187 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management Consultants, Inc. on 09/20/2005. (Klamann, John) (Entered: 08/30/2005)

08/30/2005 3188 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: "HR Assessment Process". (Klamann, John) (Entered: 08/30/2005)

08/30/2005 3189 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael W. Stout. (Klamann, John) (Entered: 08/30/2005)

08/30/2005 3190 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: Common Merit Review Process. (Klamann, John) (Entered: 08/30/2005)

08/31/2005 3191 TRANSCRIPT (pages 1−41) of proceedings held on 08/18/05 held before Magistrate Judge David J. Waxse. (mg) (Entered: 08/31/2005)

08/31/2005 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets by Plaintiff Shirley Williams. (Hubbard, Dirk) (Document Title Modified on 9/1/2005. (mg)) (Entered: 08/31/2005)

08/31/2005 3193 ORDER − The defendant shall comply with the Court's August 12, 2005 Discovery 3157 Order by October 12, 2005. Signed by Judge John W. Lungstrum on 08/31/2005. (ses) (Entered: 08/31/2005)

08/31/2005 3194 MEMORANDUM AND ORDER denying 3106 Motion for Review and Objections to Magistrate Judge's July 12, 2005 order. Signed by Judge John W. Lungstrum on 08/31/2005. (ses) (Entered: 08/31/2005)

09/01/2005 3195 MOTION for attorney Matthew C. Billips to appear pro hac vice by Plaintiff Shirley Williams (Attachments: #(1) Affidavit; #(2) Certificate)(Egan, Dennis) (Duplicate text removed on 9/2/2005. (mg)) (Entered: 09/01/2005)

09/01/2005

PRO HAC VICE FEE PAID: on 9/1/05 re: 3195 MOTION for attorney Matthew C. Billips to appear pro hac vice in the amount of $50.00 Receipt Number 109745 (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (jb) (Entered: 09/01/2005)

09/01/2005 3196 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patricia Barbe on September 6, 2005 (Hulla, Patrick) (Entered: 09/01/2005)

09/01/2005 3197 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3171 MOTION to Vacate 127 Order Regarding Treatment of Social Security Numbers in Discovery Responses. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Hulla, Patrick) (Entered: 09/01/2005)

09/01/2005 3198 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative re: SPR−W015187−97 (Attachments: # 1 Exhibit)(Klamann, John) (Entered: 09/01/2005)

09/01/2005 3261 TRANSCRIPT (Pages 1−44) of proceedings held on 09/01/05 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 45−88)(mg) (Entered: 09/14/2005)

09/02/2005 3199 Minute Entry for Discovery/Status Conference held on 9/01/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 9/19/2005 at 2:00 p.m (byk) (Entered: 09/02/2005)

09/02/2005 3200 MEMORANDUM IN SUPPORT of 3195 MOTION for attorney Matthew C. Billips to appear pro hac vice by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 09/02/2005)

09/06/2005 3201 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Agus Budijaro on September 24, 2005. (Hulla, Patrick) (Entered:

09/06/2005)

09/06/2005 3202 Unopposed MOTION for extension of time (Second) for Sprint to Respond to Plaintiff's Ninth Interrogatories by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 09/06/2005)

09/06/2005 3203 ORDER from 9/1/2005 discovery status conference. See attached Order. Signed by Magistrate Judge David J. Waxse on 9/6/2005. (Attachments: # 1 Exhibit)(byk) (Entered: 09/06/2005)

09/07/2005

3204

ORDER granting 3202 Defendant's Motion for Extension of Time to File Response. Defendant Sprint/United Management Company shall have until September 23, 2005 to answer, and otherwise respond to, Plaintiff's Ninth Interrogatories to Defendant Sprint, including any objections thereto. Signed by Magistrate Judge David J. Waxse on 9/7/2005.(jm) (Entered: 09/07/2005)

09/07/2005 3205 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of RIGHT MANAGEMENT CONSULTANTS, INC. on October 13, 2005 (Klamann, John) (Entered: 09/07/2005)

09/07/2005 3206 Second MOTION for extension of time for Plaintiffs to Respond to Defendant's 4th Interrogatories and 4th Document Requests by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 09/07/2005)

09/08/2005 3207 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jack Villieux on 9/15/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3208 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Borresdon on 9/15/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3209 NOTICE by Defendant Sprint/United Management Company of taking deposition of Betty Ryder on 9/14/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3210 NOTICE by Defendant Sprint/United Management Company of taking deposition of Arthur Williams on 9/14/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3211 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jerome Kacheroski on 9/14/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3212 NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Campbell on 9/14/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3213 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nancy Budd on 9/13/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3214 NOTICE by Defendant Sprint/United Management Company of taking deposition of Phillip Williamson on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3215 NOTICE by Defendant Sprint/United Management Company of taking deposition of Brian O'Conner on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3216 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lana Coleman on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3217 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patricia Plantenberg on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3218 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Eastin on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3219 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard McPheeters on 9/26/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3220 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Boyer on 9/26/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3221 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Steele on 9/27/05 (Hulla, Patrick) (Entered: 09/08/2005)

09/08/2005 3222 NOTICE by Defendant Sprint/United Management Company of taking deposition of Roosevelt Draine on 9/12/05 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3223 NOTICE by Defendant Sprint/United Management Company of taking deposition of Stephen L. Brown on 9/15/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3224 NOTICE by Defendant Sprint/United Management Company of taking deposition of Virginia Johnson on 9/15/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3225 NOTICE by Defendant Sprint/United Management Company of taking deposition of Billie F. Smith on 9/15/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3226 NOTICE by Defendant Sprint/United Management Company of taking deposition of Javier Fernandez on 9/16/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3227 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Eicher on 9/19/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3228 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donald Fedge on 9/22/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3229 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sherrie Bartlett on 9/26/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3230 NOTICE by Defendant Sprint/United Management Company of taking deposition of Judith Cobb on 9/26/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3231 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeanette Bass on 9/27/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3232 NOTICE by Defendant Sprint/United Management Company of taking deposition of Deborah Ehr on 9/27/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3233 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Roberson on 9/27/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3234 NOTICE by Defendant Sprint/United Management Company of taking deposition of Myron Rittenhouse on 9/27/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3235 NOTICE by Defendant Sprint/United Management Company of taking deposition of Debra Ferguson on 9/28/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3236 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Rhudy on 9/28/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3237 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cheryl Johnson on 9/28/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3238 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jean Robinson on 9/28/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3239 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dave Compton on 9/29/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3240 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Lanter on 9/29/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3241 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gary Schauperl on 9/29/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3242 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donna Kofsky on 9/29/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3243 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Ridings on 9/29/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3244 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffery Huffman on 9/30/2005 (Hulla, Patrick) (Entered: 09/08/2005)
09/08/2005 3245 NOTICE by Plaintiff Shirley Williams of taking deposition of Stacey Saladin on a date to be set. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3246 NOTICE by Plaintiff Shirley Williams of taking deposition of Beth Omer on a date to be set. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3247 NOTICE by Plaintiff Shirley Williams of taking deposition of Pam Winterman on 11/23/2005. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3248 NOTICE by Plaintiff Shirley Williams of taking deposition of Deanne Bohannon on a date to be set. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3249 NOTICE by Plaintiff Shirley Williams of taking deposition of Ralph Veazey on a date to be set. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3250 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: University Relations (Doc Bates #130455) on a date to be set. (Klamann, John) (Entered: 09/08/2005)

09/08/2005 3251 NOTICE by Plaintiff Shirley Williams of taking deposition of Person(s) Who Prepared Document Bates #14990−149914 on a date to be set.(Klamann, John) (Entered: 09/08/2005)

09/08/2005

3252

ORDER granting 3206 Plaintiffs' Request for a Second Extension of Deadline for Plaintiffs to Respond to Defendant's 4th Interrogatories and 4th Document Requests. Plaintiffs shall have an extension of time, up through and including September 23, 2005, to file their response, including any objections thereto, to the 4th Interrogatories and 4th Request for Production of Documents served by Defendant. Signed by Magistrate Judge David J. Waxse on 9/8/2005. (byk) (Entered: 09/08/2005)

09/08/2005 3253 TRANSCRIPT of Status Conference held September 1, 2005 before Judge Waxse. Court Reporter: Lisa Allmon. Volume: One.

NOTICE RE: REDACTION OF TRANSCRIPTS: Within 5 business days of this filing, each party shall inform the Court, by filing a Notice of Redaction, of the parties intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ksd.uscourts.gov. Please read this policy carefully. If no Notice of Intent to Redact is filed within the allotted time, the transcript will be made electronically available after 5 business days.

NOTICE: For access to this document only (unlike other documents) via the Notice of Electronic Filing, click on the CASE NUMBER (not the Document Number) hyperlink; at the login screen enter your ECF login and password; click on Run Report; enter your PACER login and password; and click on the DOCUMENT NUMBER hyperlink.

(kao) (Transcript made electronically available on 9/16/2005. (mg)) (Entered: 09/08/2005)

09/08/2005

3254

Unopposed MOTION for Extension of Time to File Reply as to 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint, and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01 by Plaintiff Shirley Williams. (Egan, Dennis) (Entered: 09/08/2005)

09/09/2005

3255

ORDER granting 3254 Motion for Extension of Time to File Reply regarding 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint, and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01. Reply deadline extended to 9/13/2005. Signed by Judge John W. Lungstrum on 09/09/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 09/09/2005)

09/09/2005 3256 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Conrad on 9/13/2005 (Hulla, Patrick) (Entered: 09/09/2005)

09/12/2005 3257 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3184 MOTION to Strike 3156 Portions of Second Amended Complaint (Hubbard, Dirk) (Entered: 09/12/2005)

09/12/2005 3258 RESPONSE by Defendant Sprint/United Management Company re 3195 MOTION for attorney Matthew C. Billips to appear pro hac vice (Hulla, Patrick) (Entered: 09/12/2005)

09/13/2005 3259 NOTICE by Plaintiff Shirley Williams of taking deposition of Ron Gier on 09/26/2005 at 7:00 AM. (Klamann, John) . (Entered: 09/13/2005)

09/13/2005

3260

REPLY to Response to Motion by Plaintiff Shirley Williams re: 3161 MOTION for Reconsideration regarding 3125 Order on Motion for Leave to Amend Complaint and Court's Order Relating to Opt−Ins Who Are Former E−Grade Employees, and Opt−Ins Terminated Between 7/23/01 and 10/1/01 (Attachments: #(1))(Egan, Dennis) (Entered: 09/13/2005)

09/14/2005 3262 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Hulla, Patrick) (Entered: 09/14/2005)

09/15/2005 3263 MOTION for extension of time for Sprint's Compliance with Paragraph 6 of the Court's Order Dated September 6, 2005 (Doc. 3203) by Defendant Sprint/United Management Company(Hulla, Patrick) (Entered: 09/15/2005)

09/16/2005 3264 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Brian O'Conner on 09/19/2005 (Hulla, Patrick) (Entered: 09/16/2005)

09/16/2005

3265

INDEX OF EXHIBITS by Plaintiff Shirley Williams re 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D−1# 5 Exhibit D−2# 6 Exhibit D−3# 7 Exhibit D−4# 8 Exhibit E−1# 9 Exhibit E−2# 10 Exhibit E−3# 11 Exhibit E−4# 12 Exhibit F−1# 13 Exhibit F−2# 14 Exhibit F−3# 15 Exhibit F−4# 16 Exhibit F−5)(Hubbard, Dirk) (Entered: 09/16/2005)

09/16/2005 3266 MOTION for Leave To Appear Pro Hac Vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit N. Hininger)(Hulla, Patrick) (Entered: 09/16/2005)

09/16/2005 3267 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3171 MOTION to Vacate 127 Order Regarding Treatment of Social Security Numbers in Discovery Responses. (Attachments: #(1) Exhibit A; #(2) Exhibit B)(Meyers, Martin) (Duplicate text removed on 9/19/2005. (mg)) (Entered: 09/16/2005)

09/19/2005

PRO HAC VICE FEE PAID: On 9/19/2005 in the amount of $50.00 for attorney Greta Nicole Hininger re: 3266 Motion for Leave to Appear Pro Hac Vice. Receipt Number 109958. (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (kao) (Entered: 09/19/2005)

09/19/2005 3268 Minute Entry for Discovery/Status Conference held on 9/19/2005 before Magistrate Judge David J. Waxse. See forthcoming Order and Transcript of the conference for further details. Next discovery conference set for 10/6/2005 at 2:00 p.m. (byk) (Entered: 09/19/2005)

09/20/2005

3269

ORDER memorializing the Court's rulings at the 09/19/05 Discovery Conference: Granting 3266 and 3195 Motions to Appear Pro Hac Vice. Greta N. Hininger is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. Matthew C. Billips is granted leave to appear pro hac vice on behalf of Plaintiffs, subject to the conditions set forth in this order. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a registration form at www.ksd.uscourts.gov/features/forms/pdfforms/efilereg.pdf. Further, granting 3263 Motion for Extension of Time. Defendant is granted an extension of time, until 10/03/05, to comply with paragraph 6 of the Court's September 6, 2005 Order (document 3203). Discovery Conference set for 10/06/05 before Magistrate Judge David J. Waxse. See this order for all deadlines and hearings. Signed by Magistrate Judge David J. Waxse on 09/20/05. (mg) (Attorney Billips modified on 9/20/2005. (mg)) (Entered: 09/20/2005)

09/20/2005

NOTICE TO COUNSEL of docket text modification by Deputy Clerk regarding 3269 Order. Note that the docket text of this order has been modified to correctly state that

attorney Matthew Billips is granted leave to appear pro hac vice on behalf of Plaintiffs, not Defendant. (mg) (Entered: 09/20/2005)
09/20/2005 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Egan, Dennis) (Duplicate text removed on 10/20/2005. (mg)) (Entered: 09/20/2005)
09/22/2005 3271 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: Exhibits 1150 − 1156 on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3272 NOTICE by Plaintiff Shirley Williams of taking deposition of Amy L. Canton on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3273 NOTICE by Plaintiff Shirley Williams of taking deposition of Ann Rhodes on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3274 NOTICE by Plaintiff Shirley Williams of taking deposition of Bill Gunter on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3275 NOTICE by Plaintiff Shirley Williams of taking deposition of Cynthia Taylor Wright on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3276 NOTICE by Plaintiff Shirley Williams of taking deposition of Dannette Norris on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3277 NOTICE by Plaintiff Shirley Williams of taking deposition of David Sapinoff on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3278 NOTICE by Plaintiff Shirley Williams of taking deposition of Jana Lathrop on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3279 NOTICE by Plaintiff Shirley Williams of taking deposition of Janice Schonwetter on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3280 NOTICE by Plaintiff Shirley Williams of taking deposition of Jennifer Baughman on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3281 NOTICE by Plaintiff Shirley Williams of taking deposition of Joanie Dubiak on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3282 NOTICE by Plaintiff Shirley Williams of taking deposition of John Garcia on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3283 NOTICE by Plaintiff Shirley Williams of taking deposition of Kelsey P. Peterson on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3284 NOTICE by Plaintiff Shirley Williams of taking deposition of Luisa Lancetti on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)
09/22/2005 3285 NOTICE by Plaintiff Shirley Williams of taking deposition of Lynn Simpson on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3286 NOTICE by Plaintiff Shirley Williams of taking deposition of Julie Moylan on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3287 NOTICE by Plaintiff Shirley Williams of taking deposition of Rebecca Ortega on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3288 NOTICE by Plaintiff Shirley Williams of taking deposition of Sara Donnelly on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3289 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Relf on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3290 NOTICE by Plaintiff Shirley Williams of taking deposition of Sharon Davis on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3291 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan L. Thompson on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3292 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Ott on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3293 NOTICE by Plaintiff Shirley Williams of taking deposition of Tom Murphy on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3294 NOTICE by Plaintiff Shirley Williams of taking deposition of Tony Castanon on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3295 NOTICE by Plaintiff Shirley Williams of taking deposition of Tonya Johnston on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/22/2005 3296 NOTICE by Plaintiff Shirley Williams of taking deposition of Vicki Koch on on date to be determined. (Klamann, John) (Text modified on 9/23/2005. (mg)) (Entered: 09/22/2005)

09/23/2005 3297 ENTRY OF APPEARANCE by Robert C. Johnson on behalf of Sprint/United Management Company (Johnson, Robert) (Entered: 09/23/2005)

09/23/2005 3298 CERTIFICATE OF SERVICE by Sprint/United Management Company (Hulla, Patrick) (Entered: 09/23/2005)

09/23/2005 3299 CERTIFICATE OF SERVICE by Shirley Williams (Dennis, Stephen) (Entered: 09/23/2005)

09/26/2005 3300 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3184 MOTION to Strike 3156 Portions of Second Amended Complaint (Hulla, Patrick) (Entered: 09/26/2005)

09/27/2005

3302

ORDER REFERRING MOTION TO THE HONORABLE DAVID J. WAXSE, MAGISTRATE JUDGE: 3171 MOTION to Vacate 127 Order Regarding Treatment of Social Security Numbers in Discovery Responses filed by Shirley Williams. Signed by Judge John W. Lungstrum on 09/27/2005. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 09/27/2005)

09/28/2005 3303 REPLY MEMORANDUM IN SUPPORT of 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets by Plaintiff Shirley Williams (Attachments: # 1 Exhibit G)(Hubbard, Dirk) (Entered: 09/28/2005)

09/29/2005 3304 NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Wilson on 11/03/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3305 NOTICE by Defendant Sprint/United Management Company of taking deposition of Catherine Bartholow on 11/03/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3306 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joy Saxton on 11/03/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3307 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mary Devore on 11/02/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3308 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerry L. Scott on 10/31/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3309 NOTICE by Defendant Sprint/United Management Company of taking deposition of Miguel Arredondo on 10/27/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3310 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gary Graber on 10/27/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3311 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kim Siewert on 10/27/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3312 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cynthia Lackner on 10/27/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3313 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eric Thomsen on 10/26/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3314 NOTICE by Defendant Sprint/United Management Company of taking deposition of Antonio Flaquer on 10/26/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3315 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mike Barbour on 10/26/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3316 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bruce Hogan on 10/25/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3317 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Scott on 10/25/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3318 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mary Ellen Jaeger on 10/24/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3319 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronald Schutte on 10/03/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3320 NOTICE by Defendant Sprint/United Management Company of taking deposition of James "Pat" Beard on 10/03/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3321 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bernard Bland on 10/10/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3322 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joanne Foster on 10/10/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3323 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sherrie Bartlett on 10/10/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3324 NOTICE by Defendant Sprint/United Management Company of taking deposition of Brayton White on 10/11/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3325 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dayna White on 10/11/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3326 NOTICE by Defendant Sprint/United Management Company of taking deposition of Phyllis Drake on 10/12/2005 (Hulla, Patrick) (Entered: 09/29/2005)
09/29/2005 3327 NOTICE by Defendant Sprint/United Management Company of taking deposition of Edna (Darrell) Davis on 10/13/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005 3328 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Finley on 10/17/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005 3329 NOTICE by Defendant Sprint/United Management Company of taking deposition of Morris Smith on 10/19/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005 3330 NOTICE by Defendant Sprint/United Management Company of taking deposition of Augustine Cotton on 10/20/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005 3331 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sherri Fasse on 10/20/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005 3332 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffrey Dunbar on 10/24/2005 (Hulla, Patrick) (Entered: 09/29/2005)

09/29/2005

3333

MEMORANDUM AND ORDER re [doc. 3037] Defendant's Response to the Court's July 12, 2005 Order to Show Cause. Defendant has failed to show cause why it should not produce the electronic spreadsheets in the manner in which they were maintained, which includes the metadata. Defendant has shown sufficient cause why it should not be sanctioned. See Memorandum and Order for further rulings. Signed by Magistrate Judge David J. Waxse on 9/29/2005. (byk) (Entered: 09/29/2005)

10/03/2005 3334 NOTICE by Plaintiff Shirley Williams of taking deposition of Suzanne Williams on a date to be determined. (Klamann, John) (Entered: 10/03/2005)

10/03/2005

3335

RESPONSE by Defendant Sprint/United Management Company re 3203 Order , Paragraph (6) (Doc. 3203) and Memorandum in Opposition to Plaintiff's Motion to Compel Documents (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit F, Part 1# 5 Exhibit F, Part 2# 6 Exhibit F, Part 3# 7 Exhibit F, Part 4# 8 Exhibit F, Part 5# 9 Exhibit F, Part 6# 10 Exhibit F, Part 7# 11 Exhibit F, Part 8# 12 Exhibit F, Part 9# 13 Exhibit F, Part 10# 14 Exhibit F, Part 11# 15 Exhibit F, Part 12# 16 Exhibit F, Part 13# 17 Exhibit F, Part 14# 18 Exhibit F, Part 15# 19 Exhibit F, Part 16# 20 Exhibit G# 21 Exhibit H)(Hulla, Patrick) (Entered: 10/03/2005)

10/03/2005 3336 RESPONSE and Objections to Plaintiff's Amended Notice Duces Tecum for the Deposition of Sprint (Document #3198) by Defendant Sprint/United Management Company. (Hulla, Patrick) (Document number added on 10/5/2005. (mg)) (Entered: 10/03/2005)

10/03/2005 3337 RESPONSE and Objections to Plaintiff's Amended Notice Duces Teum for the Deposition of Sprint (Document #3188) by Defendant Sprint/United Management Company. (Hulla, Patrick) (Document number added on 10/5/2005. (mg)) (Entered: 10/03/2005)

10/04/2005 3338 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order. (Hulla, Patrick) (Docket text modified on 10/5/2005. (mg)) (Entered: 10/04/2005)

10/05/2005

3339

AMENDED MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order. Motion to Modify Protective Order and Memorandum of Law in Support (Attachments: # 1 Exhibit A)(Hulla, Patrick) (Entered: 10/05/2005)

10/05/2005 3340 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of SHELLEY PRYOR on 10/06/2005 @ 9:00 a.m. (Klamann, John) (Entered: 10/05/2005)

10/06/2005 3341 DISREGARD FILING − DOCUMENT FILED IN INCORRECT CASE (see 05−2289): NOTICE OF SERVICE by Sprint/United Management Company of Certificate of Service (Hulla, Patrick) Modified on 10/6/2005 to block public viewing (kao). (Entered: 10/06/2005)

10/06/2005

DOCKET ANNOTATION: Disregard Document 3341 Notice of Service; it was filed in the wrong case. Document re−filed in correct case (05−2289, DE #7). (kao) (Entered: 10/06/2005)

10/06/2005 3342 Minute Entry for Status/Discovery Conference held on 10/6/2005 before Magistrate Judge David J. Waxse. Next Status/Discovery Conference set for 10/20/2005 at 1:00 p.m. (See attached Minute Sheet.) (byk) (Entered: 10/06/2005)

10/07/2005

3343

ORDER setting Discovery Conference for 11/17/2005 at 02:00 PM before Magistrate Judge David J. Waxse. The October 20, 2005 discovery conference is changed to 1:00 p.m. Defendant is granted an extension of time to produce unscrubbed spreadsheets. Attorney Patrick F. Hulla is allowed to withdraw as counsel for defendant. Signed by Magistrate Judge David J. Waxse on 10/7/05. (mm) (Entered: 10/07/2005)

10/11/2005 3344 DISREGARD THIS FILING/ENTRY MADE INCORRECTLY IN THIS CASE re ORDER RESETTING STATUS CONFERENCE. Entered by Magistrate Judge David J. Waxse on 10/11/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 10/11/2005)

10/11/2005

DOCKET ANNOTATION from the Clerk's Office re 3344 Order Setting Status Conference. Please disregard said filing. Entry made Incorrectly in this case. Re−entered in 03−2220. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (ck ) (Entered: 10/11/2005)

10/12/2005 3345 TRANSCRIPT (Pages 1−51) of proceedings held on 10/06/05 before Magistrate Judge David J. Waxse. (mg) (Entered: 10/12/2005)

10/12/2005 3346 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative of Right Management Consultants, Inc. on 10/13/2005 at 1:30PM. (Klamann, John) (Entered: 10/12/2005)

10/12/2005 3347 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative RE: Alpha Ranking on a date to be determined.(Attachments: # 1 Exhibit A)(Klamann, John) (Entered: 10/12/2005)

10/12/2005 3348 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management Consultants, Inc. on 10/13/05. (Klamann, John) (Entered: 10/12/2005)

10/12/2005 3349 TRANSCRIPT (Pages 1−47) of 3268 Status Conference proceedings held on 09/19/05 before Magistrate Judge David J. Waxse. (mg) (Entered: 10/12/2005)

10/12/2005 3350 MOTION for extension of time to Comply with 8/12/05 Court Order and Partial Certification of Compliance by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A)(Yates, John) (Entered: 10/12/2005)

10/13/2005 3351 RESPONSE by Plaintiff Shirley Williams re 3350 MOTION for extension of time to Comply with 8/12/05 Court Order and Partial Certification of Compliance (Egan, Dennis) (Entered: 10/13/2005)

10/14/2005

3352

ORDER granting 3350 Motion for Extension of Time to Comply with 8/12/05 Court Order and Partial Certification of Compliance. The defendant is granted additional time, up to an including November 4, 2005, within which to provide to Plaintiffs its certification that all responsive documents relating to the August 12, 2005 Order have been produced and that Sprint has fully and completely complied with its obligations under the Order. Signed by Judge John W. Lungstrum on 10/14/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 10/14/2005)

10/18/2005 3353 MOTION to Compel by Defendant Sprint/United Management Company(Yates, John) (Entered: 10/18/2005)

10/18/2005

3354

MEMORANDUM IN SUPPORT of 3353 MOTION to Compel by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A − Plaintiff's Answers and Objections to Defendant's First Interrogatories# 2 Exhibit B − Plaintiff's Responses and Objections to Defendant's First Request for Production)(Yates, John) (Entered: 10/18/2005)

10/18/2005 3355 CERTIFICATE OF COMPLIANCE by Defendant Sprint/United Management Company re 3353 MOTION to Compel. (Yates, John) (Entered: 10/18/2005)

10/19/2005 3356 MOTION for Extension of Time to File Reply as to 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order by Plaintiff Shirley Williams. (Egan, Dennis) (Duplicate text

removed on 10/20/2005. (mg)) (Entered: 10/19/2005)

10/20/2005 3357 Minute Entry for Discovery/Status Conference held on 10/20/05 before Magistrate Judge David J. Waxse. Minute Sheet attached. Next Discovery/Status Conference set for 11/17/05 at 2:00 p.m. (byk) (Entered: 10/20/2005)

10/21/2005 3358 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Egan, Dennis) (Entered: 10/21/2005)

10/21/2005 3361 SEALED EXHIBIT B IN SUPPORT of 3358 Reply to Response to 3270 Motion by Plaintiff Shirley Williams. (mg) (hw). (Entered: 10/24/2005)

10/21/2005 3362 SEALED EXHIBIT C IN SUPPORT of 3358 Reply to Response to 3270 Motion by Plaintiff Shirley Williams. (mg) (hw). (Entered: 10/24/2005)

10/24/2005 3359 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Joe Norton on October 26, 2005 (Dupont, Philip) (Entered: 10/24/2005)

10/24/2005 3360 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Bruce Hertzfield on October 27, 2005 (Dupont, Philip) (Entered: 10/24/2005)

10/24/2005 3363 MOTION for attorney Thomas McCarthy to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Thomas McCarthy)(Dorssom, Kara) (Entered: 10/24/2005)

10/24/2005

3364

ORDER memorializing the Court's rulings at the 10/20/05 Discovery Conference. Plaintiffs' Motion Requesting the Court to Vacate its Order of February 27, 2004 Regarding Treatment of Social Security Numbers in Discovery Responses 3171 is granted in part. The Motion to File out of Time Cavanaugh Plaintiffs' Reply Memorandum in Support of Their Motion to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order 3356 is granted. See attached Order for further rulings and details. Signed by Magistrate Judge David J. Waxse on 10/24/2005. (byk) (Entered: 10/24/2005)

10/24/2005

PRO HAC VICE FEE PAID: On 10/24/2005 in the amount of $50.00 for attorney Thomas McCarthy re: 3363 MOTION for attorney Thomas McCarthy to appear pro hac vice. Receipt Number 110591. (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (kao) (Entered: 10/24/2005)

10/25/2005

3365

ORDER granting 3363 Motion to Appear Pro Hac Vice. Thomas A. McCarthy is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a registration form at www.ksd.uscourts.gov/features/forms/pdfforms/efilereg.pdf. Signed by MagistrateJudge David J. Waxse on 10/24/05. (mg) (Entered: 10/25/2005)

10/26/2005 3366 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Julie Moylan (Klamann, John) (Entered: 10/26/2005)

10/26/2005 3367 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Defendant Sprint (Klamann, John) (Entered: 10/26/2005)

10/26/2005 3368 NOTICE by Plaintiff Shirley Williams of taking deposition of Dan Chojnacki on October 31, 2005 (Klamann, John) (Entered: 10/26/2005)

10/26/2005 3369 NOTICE by Plaintiff Shirley Williams of taking deposition of The Records Custodian of Right Management Consultants, Inc. on October 31, 2005 (Klamann, John) (Entered: 10/26/2005)

10/26/2005 3370 NOTICE by Plaintiff Shirley Williams of taking deposition of Karla McClary on October 31, 2005 (Klamann, John) (Entered: 10/26/2005)

10/26/2005 3371 NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management Consultants, Inc. Authorized Representative on October 31, 2005 (Klamann, John)

(Entered: 10/26/2005)
10/26/2005 3372 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Defendant Sprint (Klamann, John) (Entered: 10/26/2005)
10/27/2005 3373 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: "Managing the Separation Interview" and/or Exhibit 1081 on 10/31/2005. (Attachments: # 1 Attachment Exhibit 1081)(Klamann, John) (Entered: 10/27/2005)
10/27/2005 3374 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: "Project Hemingway−Process Guide" on a date to be determined. (Klamann, John) (Entered: 10/27/2005)
10/27/2005 3375 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Julie Moylan on a date to be determined. (Klamann, John) (Entered: 10/27/2005)
10/27/2005 3376 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative Re: "total turnover" and "involuntary turnover" aspects of Exhibit 29(b) on a date to be determined. (Klamann, John) (Entered: 10/27/2005)
10/28/2005 3377 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sherree Sammons on October 31, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3378 NOTICE by Defendant Sprint/United Management Company of taking deposition of Stephen Gallup on November 1, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3379 NOTICE by Defendant Sprint/United Management Company of taking deposition of Anita Lock on November 1, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3380 NOTICE by Defendant Sprint/United Management Company of taking deposition of Duane Porter on November 1, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3381 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Albers on November 2, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3382 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mary Devore on November 2, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3383 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mike Perkins on November 2, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3384 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Orenberg on November 3, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3385 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Bernskoetter on November 7, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3386 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Wright on November 7, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3387 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Thomas on November 8, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3388 NOTICE by Defendant Sprint/United Management Company of taking deposition of Flora Grayson on November 8, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3389 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gloria Hevener on November 8, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3390 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rita Miller on November 9, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3391 NOTICE by Defendant Sprint/United Management Company of taking deposition of Charles Fisher on November 9, 2005 (Dupont, Philip) (Entered: 10/28/2005)
10/28/2005 3392 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Harper on November 9, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3393 NOTICE by Defendant Sprint/United Management Company of taking deposition of Glenn Gillihan on November 10, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3394 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffrey Starbuck on November 10, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3395 NOTICE by Defendant Sprint/United Management Company of taking deposition of Helena Young on November 14, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3396 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Rollins on November 14, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3397 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cinda Wittman on November 14, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3398 NOTICE by Defendant Sprint/United Management Company of taking deposition of Barbara Kuklenski on November 15, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3399 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joyce Savage on November 15, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3400 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronald Frampton on November 15, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3401 NOTICE by Defendant Sprint/United Management Company of taking deposition of Larry Wayne Allen on November 16, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3402 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronald Havens on November 16, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3403 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Harrington on November 16, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3404 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Laundy on November 17, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3405 NOTICE by Defendant Sprint/United Management Company of taking deposition of Reta Juiliano on November 17, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3406 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mavis Tuttle on November 17, 2005 (Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3407 MOTION to Clarify and/or Modify the Court's Order of October 24, 2005 Regarding the Redaction of Social Security Numbers by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 10/28/2005)

10/28/2005 3408 MEMORANDUM IN SUPPORT of 3407 MOTION to Clarify and/or Modify the Court's Order of October 24, 2005 Regarding the Redaction of Social Security Numbers by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 10/28/2005)

10/31/2005 3409 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Matt Goettsch on November 1, 2005 (Meyers, Martin) (Entered: 10/31/2005)

11/01/2005

3410

MEMORANDUM AND ORDER granting 3161 Motion for Reconsideration and granting 3184 Motion to Strike 3156 Plaintiffs' Second Amended Complaint. Plaintiffs' Second Amended Complaint is stricken in its entirety and plaintiffs shall file a revised second amended complaint reflecting the rulings set forth herein, no later than November 15, 2005. Signed by Judge John W. Lungstrum on 11/01/2005. (ses) (Entered: 11/01/2005)

11/01/2005 3411 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Joy Saxton on November 4, 2005 (Dupont, Philip) (Entered: 11/01/2005)

11/01/2005 3412 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nancy Fretwell on November 8, 2005 (Dupont, Philip) (Entered: 11/01/2005)

11/01/2005 3413 NOTICE by Defendant Sprint/United Management Company of taking deposition of Stephen Homan on November 9, 2005 (Dupont, Philip) (Entered: 11/01/2005)

11/01/2005 3414 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steven Ray Smith on November 10, 2005 (Dupont, Philip) (Entered: 11/01/2005)

11/01/2005 3415 Unopposed MOTION for Extension of Time to File Response as to 3353 MOTION to Compel by Plaintiff Shirley Williams(Dennis, Stephen) (Entered: 11/01/2005)

11/01/2005

3416

ORDER granting 3415 Plaintiffs' Motion for Extension of Time to File Response re 3353 Defendant's MOTION to Compel. Plaintiffs are hereby granted an extension of time, until November 14, 2005, to file their response to 3353 Defendant's MOTION to Compel. Entered by Magistrate Judge David J. Waxse on 11/1/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/01/2005)

11/04/2005 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 11/04/2005)

11/04/2005 3418 MEMORANDUM IN SUPPORT of 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 11/04/2005)

11/04/2005

3419

INDEX OF EXHIBITS by Defendant Sprint/United Management Company re 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses with attached Exhibits (Attachments: # 1 Exhibit A − transcript of 2/27/04 hearing# 2 Exhibit B − transcript of 3/2/04 hearing# 3 Exhibit C − transcript of 3/31/05 hearing# 4 Exhibit D − table of deponents# 5 Exhibit E − excerpts from Kissinger deposition# 6 Exhibit F − excerpts from Focht deposition# 7 Exhibit G − excerpts from Motley deposition# 8 Exhibit H − excerpts from Miller deposition# 9 Exhibit I − excerpts from Mason deposition# 10 Exhibit J − excerpts from Gier deposition# 11 Exhibit K − excerpts from Dillon deposition# 12 Exhibit L − excerpts from Skelton deposition# 13 Exhibit M − excerpts of Volume 2 of Mason deposition# 14 Exhibit N − excerpts from Stadler deposition# 15 Exhibit O − excerpts from Renda deposition# 16 Exhibit P − excerpts from Shannon deposition# 17 Exhibit Q − excerpts from Lampe deposition)(Dupont, Philip) (Entered: 11/04/2005)

11/04/2005 3420 Consent MOTION for extension of time to Comply with Court's 8/12/05 Order and Second Certification of Partial Compliance by Defendant Sprint/United Management Company(Yates, John) (Entered: 11/04/2005)

11/07/2005 3421 TRANSCRIPT (Pages 1−53) of proceedings held on 10/20/05 before Magistrate Judge David J. Waxse. (Entered: 11/07/2005)

11/08/2005

3422

ORDER granting 3420 Motion for Extension of Time to comply with Court's 8/12/05 order and second certification of partial compliance. Sprint is granted additional time, up to and including November 28, 2005, within which toprovide Plaintiffs its final certification that all responsive documents relating to theAugust 12, 2005 Order have been produced and that Sprint has fully and completelycomplied with its obligations under the Order. Signed by Judge John W. Lungstrum on 11/08/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses, ) (Entered: 11/08/2005)

11/11/2005 3423 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Dean Axford on November 16, 2005 (Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3424 MOTION to Expedite Briefing and Ruling by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3425 NOTICE by Defendant Sprint/United Management Company of taking deposition of Teryl Casey on November 28, 2005 (Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3426 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donald Cowick on November 28, 2005 (Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3427 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Votypka on November 28, 2005 (Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3428 NOTICE by Defendant Sprint/United Management Company of taking deposition of Harold Baumhardt on November 29, 2005 (Dupont, Philip) (Entered: 11/11/2005)

11/11/2005 3429 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Boldrey on November 29, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3430 NOTICE by Defendant Sprint/United Management Company of taking deposition of Isaac Lamm on November 29, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3431 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Curry on November 30, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3432 NOTICE by Defendant Sprint/United Management Company of taking deposition of Charles Appleby on November 30, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3433 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Steinmetz on November 30, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3434 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patti Whitaker on December 1, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3435 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joy Gregg on December 1, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3436 NOTICE by Defendant Sprint/United Management Company of taking deposition of Benjamin Tate on December 1, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3437 NOTICE by Defendant Sprint/United Management Company of taking deposition of Laurie Viles on December 5, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3438 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Brower on December 5, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3439 NOTICE by Defendant Sprint/United Management Company of taking deposition of Markus Merrill on December 6, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3440 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dennis Gill on December 7, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3441 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marsha Wilyard on December 7, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3442 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kathy Pine on December 8, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3443 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Richards on December 12, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3444 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rachel Coleman on December 12, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3445 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Stine on December 12, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3446 NOTICE by Defendant Sprint/United Management Company of taking deposition of Godfrey Archibong on December 13, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3447 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Lindzy on December 14, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3448 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ralph Sweatte on December 15, 2005 (Dupont, Philip) (Entered: 11/11/2005)
11/11/2005 3449 CERTIFICATE OF SERVICE by Sprint/United Management Company for Sprint's Objections to Plaintiffs' Deposition Notices Duces Tecum (Doc. #3347, #3367 and #3372). (Dupont, Philip) (Entered: 11/11/2005)
11/14/2005 3450 RESPONSE by Plaintiff Shirley Williams re 3424 MOTION to Expedite Briefing and Ruling (Egan, Dennis) (Entered: 11/14/2005)
11/14/2005 3451 AMENDED COMPLAINT (REVISED SECOND) against all defendants, filed by Shirley Williams.(Egan, Dennis) (Entered: 11/14/2005)

11/14/2005 3452 Second MOTION for Extension of Time to File Response as to 3353 MOTION to Compel by Plaintiff Shirley Williams(Dennis, Stephen) (Entered: 11/14/2005)

11/15/2005 3453 MEMORANDUM IN SUPPORT of 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Hubbard, Dirk) (Entered: 11/15/2005)

11/16/2005 3454 MOTION for Protective Order for the Return of Inadvertently Produced Privileged Documents by Defendant Sprint/United Management Company(Yates, John) (Entered: 11/16/2005)

11/16/2005

3455

MEMORANDUM IN SUPPORT of 3454 MOTION for Protective Order for the Return of Inadvertently Produced Privileged Documents by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit of Rodney Herbel (Exhibit C)# 2 Exhibit D − Declaration of Patrick Hulla# 3 Exhibit E − list of privileged documents# 4 Exhibit F − 10/27/05 letter from Monafo to Egan# 5 Exhibit H − Declaration of John J. Yates# 6 Exhibit I − 11/11/05 e−mail from Yates to Egan)(Yates, John) (Entered: 11/16/2005)

11/16/2005 3456 MOTION for Leave to file Privileged Exhibits Under Seal by Defendant Sprint/United Management Company(Yates, John) (Entered: 11/16/2005)

11/17/2005 3457 NOTICE of Submission of Privileged Exhibit for In Camera Inspection by Sprint/United Management Company re 3455 Memorandum in Support of Motion, (Yates, John) (Entered: 11/17/2005)

11/17/2005 3458 MOTION for Extension of Time to File Response as to 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses to 11/28/2005 by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 11/17/2005)

11/18/2005 3459 Minute Entry for Discovery/Status Conference held on 11/17/05 before Magistrate Judge David J. Waxse. Minute Sheet attached. See forthcoming Order for further rulings from the conference. Next Discovery/Status Conference set for 12/15/05 at 2:00 p.m. (byk) (Entered: 11/18/2005)

11/18/2005 3460 NOTICE by Defendant Sprint/United Management Company of taking deposition of W. Randy White on November 21, 2005 (Dupont, Philip) (Entered: 11/18/2005)

11/18/2005 3461 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard McCune on November 21, 2005 (Dupont, Philip) (Entered: 11/18/2005)

11/18/2005 3462 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Campbell on November 28, 2005 (Dupont, Philip) (Entered: 11/18/2005)

11/18/2005 3463 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steven Roland on November 30, 2005 (Dupont, Philip) (Entered: 11/18/2005)

11/18/2005 3464 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Employee Pursuant to Rule 30(B)(1) on To Be Determined (Klamann, John) (Entered: 11/18/2005)

11/18/2005 3465 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Employee Pursuant to Rule 30(B)(1) on To Be Determined (Klamann, John) (Entered: 11/18/2005)

11/18/2005

3466

ORDER from 11/17/2005 discovery/status conference before Magistrate Judge David J. Waxse denying 3424 Defendant's Motion for Expedited Briefing and Ruling, granting 3452 Plaintiffs' Second Motion for Extension of Time to File Response re 3417 , granting 3456 Defendant's Motion for Leave to File Exhibits Under Seal, and granting 3458 Plaintiffs' Motion for Extension of Time to File Response re 3417 . The parties shall submit a revised report of parties' planning conference to District Judge Lungstrum by 12/9/2005. See attached Order for further rulings. Signed by Magistrate Judge David J. Waxse on 11/18/2005. (byk) (Entered: 11/18/2005)

11/18/2005 3467 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3353 MOTION to Compel (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Dennis, Stephen) (Entered: 11/18/2005)

11/22/2005 3468 RESPONSE to 3277 Notice to Take Deposition by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 11/22/2005)

11/22/2005 3469 STIPULATION of Dismissal With Prejudice of Claims of Six Opt−In Plaintiffs by Shirley Williams. (Hubbard, Dirk) (Entered: 11/22/2005)

11/23/2005 3470 TRANSCRIPT (Pages 1−81) of proceedings held on 11/17/05 before Magistrate Judge David J. Waxse. (mg) (Entered: 11/23/2005)

11/28/2005 3471 MEMORANDUM IN SUPPORT of 3353 MOTION to Compel responsive answers to Defendant's fourth set of interrogatories and fourth request for production of documents by Defendant Sprint/United Management Company(Yates, John) (Entered: 11/28/2005)

11/28/2005 3472 MOTION for attorney Mark G. Arnold to appear pro hac vice by Defendant Sprint/United Management Company (Attachments: # 1 Affidavit Affidavit of Mark G. Arnold in Support of Motion for Leave to Appear Pro Hac Vice)(Yates, John) (Entered: 11/28/2005)

11/28/2005 3473 Unopposed MOTION for Extension of Time to File Response as to 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 11/28/2005)

11/28/2005 3474 Consent MOTION for extension of time of One Week to Certify Full and Complete Compliance with The Court's 8/12/05 Memorandum and Order by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 11/28/2005)

11/29/2005

PRO HAC VICE FEE PAID: on 11/29/05 re: 3472 MOTION for attorney Mark G. Arnold to appear pro hac vice in the amount of $50.00 Receipt Number 1000369 (THIS IS A TEXT ONLY ENTRY−NO DOCUMENT IS ASSOCIATED WITH THIS TRANSACTION) (jb) (Entered: 11/29/2005)

11/29/2005 3475 ORDER OF DISMISSIAL With Prejudice: Wilfredo Aleman, Joyce Ann Bixler, Melvyn Dunkerley, Keith Jamour, Sally A. Juhn, and Yanwen Xia are dismissed with prejudice. Each party to bear its own costs. Signed by Judge John W. Lungstrum on 11/29/05.(mg) (Entered: 11/29/2005)

11/29/2005 3476 MOTION to Quash Subpoena by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A)(Dupont, Philip) (Entered: 11/29/2005)

11/30/2005

3477

ORDER granting 3474 Motion for Extension of Time of an additional one (1) week, up to and including, December 6, 2005, in which to produce the remaining responsive documents and to certify to Plaintiffs that it has fulfilled all of its discovery obligations under the Order, and for such other and further relief as this Court deems just under the circumstances. Signed by Judge John W. Lungstrum on 11/30/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (ses) (Entered: 11/30/2005)

11/30/2005 3478 MOTION to Seal Plaintiff's Memorandum in Opposition to Defendant's Motion for a Protective Order for the Return of (Allegedly) Inadvertently Produced (Allegedly) Privileged Documents by Plaintiff Shirley Williams(Hubbard, Dirk) (Entered: 11/30/2005)

11/30/2005 3479 NOTICE by Plaintiff Shirley Williams of taking deposition of Nancy Fox on a date to be determined. (Klamann, John) (Entered: 11/30/2005)

11/30/2005 3480 ANSWER to Revised Second Amended Complaint by Sprint/United Management Company. (Dorssom, Kara) (Complaint title modified on 12/1/2005. (mg)) (Entered: 11/30/2005)

11/30/2005 3481 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13)(Egan, Dennis) (Entered: 11/30/2005)

12/02/2005 3482 NOTICE by Defendant Sprint/United Management Company of taking deposition of Leah Velasquez on December 5, 2005 (Dupont, Philip) (Entered: 12/02/2005)

12/02/2005 3483 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Benjamin Tate on December 5, 2005 (Dupont, Philip) (Entered: 12/02/2005)

12/02/2005 3484 NOTICE by Defendant Sprint/United Management Company of taking deposition of Douglas Neudeck on December 8, 2005 (Dupont, Philip) (Entered: 12/02/2005)

12/02/2005 3485 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michelle Washington on December 8, 2005 (Dupont, Philip) (Entered: 12/02/2005)

12/02/2005 3486 ORDER granting 3473 Plaintiffs' Unopposed Motion for Extension of Time to File Response re 3417 : Defendant's MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses. Signed by Magistrate Judge David J. Waxse on 12/2/2005. (byk) (Entered: 12/02/2005)

12/02/2005 3487 NOTICE by Defendant Sprint/United Management Company of taking deposition of Stephen McWilliams on December 6, 2005 (Dupont, Philip) (Entered: 12/02/2005)

12/05/2005

3488

ORDER granting 3478 Plaintiffs' unopposed Motion for Leave to File Under Seal Plaintiffs' Memorandum in Opposition to Defendant's Motion for Protective Order for the Return of Inadvertently Produced Privileged Documents. The Clerk of the Court is directed to file under seal Plaintiffs' Memorandum in Opposition to Defendant's Motion for Protective Order for the Return of Inadvertent Produced Privileged Documents, previously submitted to the Court in conjunction with the filing of the Plaintiffs' Motion for Leave. Signed by Magistrate Judge David J. Waxse on 12/05/05.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (mg) (Entered: 12/05/2005)

12/05/2005 3489 SEALED MEMORANDUM in Opposition by Plaintiffs regarding 3454 MOTION for Protective Order for the Return of Inadvertently Produced Privileged Documents. (See 3488 Order.) (mg) (hw). (Entered: 12/05/2005)

12/05/2005 3490 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Nancy Fox on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3491 NOTICE by Plaintiff Shirley Williams of taking deposition of Tami Keasling on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3492 NOTICE by Plaintiff Shirley Williams of taking deposition of Kelley Carlisle on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3493 NOTICE by Plaintiff Shirley Williams of taking deposition of Angela Koranda on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3494 NOTICE by Plaintiff Shirley Williams of taking deposition of Jan Price on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3495 NOTICE by Plaintiff Shirley Williams of taking deposition of Sheryl Bowlin on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3496 NOTICE by Plaintiff Shirley Williams of taking deposition of Kathi Kerste on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3497 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Machell on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3498 NOTICE by Plaintiff Shirley Williams of taking deposition of Kate Fisher on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3499 NOTICE by Plaintiff Shirley Williams of taking deposition of Angela Dwyer on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3500 NOTICE by Plaintiff Shirley Williams of taking deposition of Dana Potts on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3501 NOTICE by Plaintiff Shirley Williams of taking deposition of Jody Brann on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/05/2005 3502 NOTICE by Plaintiff Shirley Williams of taking deposition of Molly Rapp on a date to be determined. (Klamann, John) (Entered: 12/05/2005)

12/06/2005

3503

ORDER granting 3472 Motion to Appear Pro Hac Vice. Mark G. Arnold is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a registration form at www.ksd.uscourts.gov/features/forms/pdfforms/efilereg.pdf. Signed by Magistrate Judge David J. Waxse on 12/06/05. (mg) (Entered: 12/06/2005)

12/08/2005 3504 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3454 MOTION for Protective Order for the Return of Inadvertently Produced Privileged Documents (Yates, John) (Entered: 12/08/2005)

12/09/2005 3505 NOTICE by Defendant Sprint/United Management Company of taking deposition of Timothy Demorest on December 13, 2005 (Dupont, Philip) (Entered: 12/09/2005)

12/09/2005 3506 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Mavis Tuttle on December 15, 2005 (Dupont, Philip) (Entered: 12/09/2005)

12/09/2005 3507 Unopposed MOTION for extension of time to file a Revised Scheduling Order by Plaintiff Shirley Williams(Egan, Dennis) (Entered: 12/09/2005)

12/12/2005 3508 ORDER granting 3507 Plaintiffs' Motion for Extension of Time to File a Revised Scheduling Order proposal. The parties shall have up to and including December 13, 2005, within which to submit their Revised Scheduling Order proposal. Signed by Magistrate Judge David J. Waxse on 12/12/2005. (byk) (Entered: 12/12/2005)

12/13/2005 3509 Consent MOTION for Extension of Time to File Reply as to 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 12/13/2005)

12/13/2005

3510

RESPONSE by Defendant Sprint/United Management Company re 3466 The Magistrate's Order of November 18, 2005, and It's Request That Plaintiff's Produce a Discovery Plan and For Scheduling Conference With the District Judge. (Attachments: #(1) Exhibit Sprint's Discovery Plan; #(2) Exhibit Agreed Discovery Time Frames; #(3) Exhibit Anticipated Categories of Discovery and Timetables)(Yates, John) (Document title modified on 12/14/2005. (mg)) (Entered: 12/13/2005)

12/14/2005 3511 MOTION to Dismiss Party Opt−In Plaintiff Davis Shikles by Defendant Sprint/United Management Company. (Dorssom, Kara) (Document title modified on 12/15/2005. (mg)) (Entered: 12/14/2005)

12/14/2005 3512 MEMORANDUM IN SUPPORT of 3511 MOTION to Dismiss Party Opt−In Plaintiff Davis Shikles by Defendant Sprint/United Management Company(Dorssom, Kara) (Motion title modified on 12/15/2005. (mg)) (Entered: 12/14/2005)

12/14/2005

3513

ORDER granting 3509 Defendant's Consent MOTION for One Week Extension to File Reply in Support of Sprint's 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses. Defendant shall have up to and including December 21, 2005, within which to file its reply brief in support of its Motion for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses. Entered by Magistrate Judge David J. Waxse on 12/14/2005.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (byk) (Entered: 12/14/2005)

12/14/2005 3514 Consent MOTION for Extension of Time to File Sur−Reply as to 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 12/14/2005)

12/15/2005

3515

ORDER granting 3514 Defendant's Motion for Extension of Time to File Sur−Response re 3192 MOTION to Declare Defendant Has Waived Any Asserted Privilege With Regard to Certain Documents and Electronic Spreadsheets. Defendant shall have up to and including December 22, 2005, within which to file its sur−reply brief. Entered by Magistrate Judge David J. Waxse on 12/15/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered:

12/15/2005)

12/15/2005 3516 Minute Entry for SCHEDULING CONFERENCE and STATUS/DISCOVERY CONFERENCE held on 12/15/2005 before Magistrate Judge David J. Waxse. Next discovery conference is set for 1/5/2006 at 2:00 p.m.. (Minute Sheet attached.) (byk) (Entered: 12/15/2005)

12/16/2005

3517

ORDER memorializing the Court's rulings at the 12/15/05 Discovery/Status Conference. Defendant's 3407 Motion for Clarification and/or Modification of the Court's Order Regarding the Redaction of Social Security Numbers is moot. Plaintiffs' unopposed oral motion for leave to file a surreply to Defendant's Motion for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses (doc. 3417) is granted. Plaintiffs shall file their surreply no later than January 2, 2006. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 12/16/2005. (byk) (Entered: 12/16/2005)

12/19/2005 3518 CERTIFICATE OF SERVICE by Sprint/United Management Company for Objections to Plaintiffs' Notices Duces Tecum for Depositions. (Dupont, Philip) (Entered: 12/19/2005)

12/19/2005 3519 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Matthew C. Billips on 11/21/2005 by Personal (Egan, Dennis) (Entered: 12/19/2005)

12/21/2005 3520 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses (Yates, John) (Entered: 12/21/2005)

12/22/2005 3521 CERTIFICATE OF SERVICE by Sprint/United Management Company for Sprint's Objections to Plaintiffs' Notices of Depositions. (Dupont, Philip) (Entered: 12/22/2005)

12/22/2005 3522 SURREPLY in Opposition to Plaintiff's Motion to Declare Invalid Sprint's Assertion of Privilege Where Legal Counsel was (Allegedly) Not Involved by Defendant Sprint/United Management Company. (Yates, John) (Document title modified on 12/23/2005. (mg)) (Entered: 12/22/2005)

12/27/2005

3523

SCHEDULING ORDER from Scheduling Conference held before Magistrate Judge David J. Waxse on 12/15/2005. Discovery deadline 6/1/2006. Dispositive motion deadline set for 7/17/2006. Confidential settlement reports due 4/21/2006. Mediation deadline 5/31/2006. Proposed Pretrial Order on pattern and practice issues due by 6/22/2006. Final Pretrial Conference on pattern and practice issues set for 6/29/2006 at 02:00 PM before Magistrate Judge David J. Waxse. Status Conference set for 11/7/2006 at 01:00 PM in Courtroom #427, before Chief Judge John W. Lungstrum. Jury Trial on pattern and practice issues set for 1/9/2007 at 09:30 AM before Chief Judge John W. Lungstrum. (SEE SCHEDULING ORDER FOR FURTHER DEADLINES.) Signed by Magistrate Judge David J. Waxse on 12/27/2005.(jm) (Entered: 12/27/2005)

01/03/2006

3524

ORDER granting Plaintiffs' unopposed request for an one−day extension of time, until 1/3/2006, to file their sur−reply to Defendant's Motion for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses (doc. 3417).Entered by Magistrate Judge David J. Waxse on 1/3/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry)(byk) (Entered: 01/03/2006)

01/03/2006 3525 SURREPLY by Plaintiff Shirley Williams re: 3417 MOTION for Protective Order Prohibiting Discovery Relating to Adverse Impact Analyses (Hubbard, Dirk) (Entered: 01/03/2006)

01/03/2006 3526 ENTRY OF APPEARANCE by Claudio E. Molteni on behalf of Shirley Williams (Molteni, Claudio) (Entered: 01/03/2006)

01/03/2006 3527 MOTION to Withdraw as Attorney Kara Dorssom by Defendant Sprint/United Management Company(Dorssom, Kara) (Entered: 01/03/2006)

01/04/2006 3528 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Ott on January 31, 2006 (Graham, Gene) (Entered: 01/04/2006)

01/05/2006 3529 MOTION to Withdraw as Attorney Regarding Greta Nicole Hininger by Defendant Sprint/United Management Company. (Dupont, Philip) (Document title modified on 1/6/2006. (mg)) (Entered: 01/05/2006)

01/05/2006 3530 Minute Entry for Status/Discovery Conference held on 1/05/2006 before Magistrate Judge David J. Waxse. Next discovery conference is set for 1/19/2006 at 2:00 p.m.. (Minute Sheet attached.) (byk) (Entered: 01/05/2006)

01/06/2006 3531 TRANSCRIPT (Pages 1−72) of proceedings held on 12/15/05 before Magistrate Judge David J. Waxse. (mg) (Entered: 01/06/2006)

01/06/2006 3532 MEMORANDUM in Opposition by Plaintiffs Davis Shikles, Shirley Williams re 3511 MOTION to Dismiss Party Opt−In Plaintiff Davis Shikles (Dennis, Stephen) (Entered: 01/06/2006)

01/06/2006

3533

ORDER memorializing the Court's rulings at the 1/05/06 Discovery/Status Conference. The Motion to Withdraw filed by Kara M. Dorssom 3527 is granted. Kara M. Dorssom is hereby withdrawn as counsel for defendant Sprint/United Management Company. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 1/6/2006. (byk) (Entered: 01/06/2006)

01/09/2006 3534 ORDER granting 3529 MOTION to Withdraw as Attorney Regarding Greta Nicole Hininger. Signed by Magistrate Judge David J. Waxse on 01/09/06. (mg) (Entered: 01/09/2006)

01/13/2006 3535 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Ott on JANUARY 31, 2006 at 9:00AM. (Klamann, John) (Entered: 01/13/2006)

01/13/2006 3536 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Mike Upchurch on February 16, 2006 at 9:00AM. (Klamann, John) (Entered: 01/13/2006)

01/16/2006 3537 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Ott on January 31, 2006. (Graham, Gene) (Entered: 01/16/2006)

01/17/2006 3538 TRANSCRIPT (Pages 1−53) of proceedings held on 01/05/06 before Magistrate Judge David J. Waxse. (mg) (Entered: 01/17/2006)

01/18/2006

3539

ORDER regarding counsel's inquiry into whether the Court will entertain oral argument for pending motions at the 1/19/2006 Discovery Status Conference. The Magistrate Judge has determined oral argument would not materially assist the resolution of the pending motions until further consideration of the motions has been completed. If, however, written rulings are not issued at least one week prior to the Discovery Status Conference following the 1/19/2006 Conference, the Magistrate Judge will hear oral argument for any motions that remain pending at the next conference. Entered by Magistrate Judge David J. Waxse on 1/18/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 01/18/2006)

01/19/2006 3540 Minute Entry for Discovery/Status Conference held on 1/19/2006 before Magistrate Judge David J. Waxse. Next Discovery/Status Conference set for 2/2/2006 at 02:00 PM before Magistrate Judge David J. Waxse. Minute Sheet attached. (byk) (Entered: 01/19/2006)

01/24/2006 3541 ORDER memorializing the Court's rulings from the 1/19/2006 Discovery/Status Conference. Plaintiffs are granted an extension of time, up to and including February 28, 2006, to file any motions to compel. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 1/24/2006.(byk) (Entered: 01/24/2006)

01/24/2006 3542 SEALED MOTION for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged by Plaintiffs.(mg) (Entered: 01/24/2006)

01/24/2006

3543

ORDER denying Plaintiffs' request for an order compelling Defendant to provide an exact duplicate of the index referenced and shown to Plaintiffs at the 1/19/2006 discovery conference and for a telephone conference on the issue. Counsel are ordered to confer in person to attempt to resolve this issue. If they cannot, it will be taken up at the next discovery conference. Signed by Magistrate Judge David J. Waxse on 1/24/2006. (Attachments: # 1 Exhibit 1 − E−mail correspondence to the Court)(byk) (Entered: 01/24/2006)

01/24/2006 3552 SEALED RESPONSE by Defendant Sprint/United Management Company regarding 3542 SEALED MOTION for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged. (mg) (Entered: 02/03/2006)

01/25/2006 3544 ENTRY OF APPEARANCE by Robert A. Costello on behalf of Sprint/United Management Company. (Costello, Robert) (Entered: 01/25/2006)

01/26/2006

3545

ORDER REFERRING MOTION TO THE HONORABLE DAVID J. WAXSE, MAGISTRATE JUDGE: 3270 MOTION to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order filed by Shirley Williams. Signed by Judge John W. Lungstrum on 01/26/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 01/26/2006)

01/26/2006 3546 TRANSCRIPT (Pages 1−43, continued as attached) of proceedings held on 01/19/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 44−87)(mg) (Entered: 01/26/2006)

01/26/2006 3547 NOTICE by Plaintiff Shirley Williams of taking deposition of Denise Patterson on 2/3/06. (Egan, Dennis) (Entered: 01/26/2006)

01/30/2006 3548 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3511 MOTION to Dismiss Party Opt−In Plaintiff Davis Shikles. (Yates, John) (Entered: 01/30/2006)

01/31/2006 3553 SEALED REPLY to Response to Motion by Plaintiffs regarding 3542 SEALED MOTION for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged. (mg) (hw). (Entered: 02/03/2006)

02/01/2006

3549

MEMORANDUM AND ORDER granting in part and denying in part Plaintiffs' Motion to Compel Documents Withheld by Defendant Despite No Involvement of Legal Department or Counsel (doc. 3203). See Memorandum and Order for further detail. Signed by Magistrate Judge David J. Waxse on 02/01/2006 (mts). (Entered: 02/01/2006)

02/02/2006 3550 MEMORANDUM AND ORDER denying 3192 Plaintiffs' Motion to Declare Defendant Has Waived Any Asserted Privilege With Regartd to Certain Docouments and Electronic Spreadsheets. Signed by Magistrate Judge David J. Waxse on 2/2/2006. (byk) (Entered: 02/02/2006)

02/02/2006 3551 Minute Entry for Status/Discovery Conference held on 2/02/2006 before Magistrate Judge David J. Waxse. Next discovery conference is set for 2/16/2006 at 2:00 PM. (Minute Sheet attached.) (byk) (Entered: 02/02/2006)

02/03/2006

3554

ORDER staying the provisions of the Court's February 1, 2006 Memorandum and Order (doc. 3549) directing Defendant to produce certain documents within five (5) days from the date of the Memorandum and Order. These provisions are hereby stayed until further order of the Court. If the order to produce is not either appealed or resolved prior to the February 16, 2006 Discovery/Status Conference it will be taken up then. Signed by Magistrate Judge David J. Waxse on 2/3/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 02/03/2006)

02/03/2006 3555 MEMORANDUM AND ORDER granting 3511 Motion to Dismiss opt−in plaintiff Davis Shikles. Signed by Judge John W. Lungstrum on 02/03/2006. (ses) (Entered: 02/03/2006)

02/06/2006 3556 Minute Entry for Telephone Conference regarding deposition dispute held on 2/6/2006 before Magistrate Judge David J. Waxse. Minute Sheet attached. (byk) (Entered: 02/06/2006)

02/06/2006 3557 Minute Entry for 2/6/2006 Telephone Conference continuing earlier telephone conference regarding deposition dispute before Magistrate Judge David J. Waxse. Minute Sheet attached. (byk) (Entered: 02/06/2006)

02/07/2006 3558 NOTICE by Plaintiff Shirley Williams of taking deposition of Susan Ott on March 2, 2006. (Graham, Gene) (Entered: 02/07/2006)

02/07/2006 3559 NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on February 15, 2006 at 9:00AM. (Klamann, John) (Entered: 02/07/2006)

02/07/2006 3560 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative: RE RIF−Related AARS and Document SPR−W191435−42 on March 9, 2006 AT 9:00AM. (Klamann, John) (Entered: 02/07/2006)

02/07/2006 3561 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Rasco on February 8, 2006. (Dupont, Philip) (Entered: 02/07/2006)

02/07/2006 3562 NOTICE by Defendant Sprint/United Management Company of taking deposition of Norman Rutkowski on February 8, 2006. (Dupont, Philip) (Entered: 02/07/2006)

02/07/2006 3563 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Patti Whitaker on February 9, 2006. (Dupont, Philip) (Entered: 02/07/2006)

02/08/2006 3564 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on February 15, 2006 at 9:00AM. (Klamann, John) (Entered: 02/08/2006)

02/08/2006

3565

ORDER memorializing the Court's rulings from the 2/02/2006 Discovery/Status Conference and finding as moot 3476 Defendant's Motion to Quash Subpoena. The 10−day time limitation for filing motions for review or motions for reconsideration of the Court's 2/01/2006 Memorandum and Order (doc. 3550) is extended to 2/21/2006. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 2/8/2006. (byk) (Entered: 02/08/2006)

02/08/2006 3566 MEMORANDUM AND ORDER memorializing the Court's rulings from the 2/6/2006 telephone status conferences regarding the deposition of John St. Angelo. Signed by Magistrate Judge David J. Waxse on 2/8/2006.(byk) (Entered: 02/08/2006)

02/08/2006 3567 NOTICE by Plaintiff Shirley Williams of taking deposition of Jan Price on March 1, 2006 at 9:00AM. (Klamann, John) (Entered: 02/08/2006)

02/08/2006

3568

SUPPLEMENTAL MEMORANDUM in Support of Cavanaugh Plaintiffs' Motion to Intervene for Limited Purpose of Seeking to Modify Protective Order and Motion to Modify Protective Order (doc. 3270) by Plaintiff Shirley Williams. (Attachments: #(1)) (Egan, Dennis) (Document title modified on 2/9/2006. Not a motion. (mg)) (Entered: 02/08/2006)

02/09/2006

3569

ORDER re 3354 Memorandum in Support of Motion to Compel filed by Sprint/United Management Company. In reviewing Defendant's Memorandum in Support of its Motion to Compel, the Court notes that the wrong set of Plaintiffs' discovery responses were attached as Exhibits A and B. Defendant is hereby directed to file within 5 days of this Order a Supplement to its Memorandum in Support of the Motion to Compel (doc. 3354) with the correct set of discovery responses at issue in its motion. Entered by Magistrate Judge David J. Waxse on 2/9/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 02/09/2006)

02/09/2006 3570 NOTICE by Plaintiff Shirley Williams of taking deposition of James Kissinger on March 8, 2006 at 9:00AM. (Klamann, John) (Entered: 02/09/2006)

02/09/2006

3571

SUPPLEMENT to 3354 Memorandum in Support of Motion, to Compel by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A−1 − Plaintiffs' Responses to Defendant's Fourth Set of Interrogatories# 2 Exhibit B−1 − Plaintiffs' Response to Defendant's Fourth Request for Production of Documents)(Dupont, Philip) (Entered: 02/09/2006)

02/10/2006 3572 CERTIFICATE OF SERVICE of Plaintiffs' Ninth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1) by Shirley Williams. (Hubbard, Dirk) (Entered: 02/10/2006)

02/13/2006

3573

MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of John St. Angelo by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A − Plaintiffs' Amended Notice for the Deposition of John St. Angelo #(2) Exhibit B − Affidavit of Compliance #(3) Exhibit C − 2/8/06 Letter to John Klamann) (Dupont, Philip) (Entered: 02/13/2006)

02/13/2006 3574 RETURN E−mail received re 3572 Certificate of Service addressed to Michael Jones. Attorney left firm and has not withdrawn. Notification not resent. (This is a text entry only). (lak) (Entered: 02/13/2006)

02/13/2006 3575 MOTION to Strike 3568 Plaintiffs' Supplemental Memorandum in Support of Cavenaugh Plaintiffs' Motion to Intervene by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 02/13/2006)

02/13/2006

3576

MEMORANDUM IN SUPPORT of 3575 MOTION to Strike 3568 Plaintiffs' Supplemental Memorandum in Support of Cavenaugh Plaintiffs' Motion to Intervene by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A − excerpts from deposition testimony of John Shannon) (Dupont, Philip) (Entered: 02/13/2006)

02/13/2006 3577 NOTICE by Plaintiff Shirley Williams of taking deposition of Eric Rice on 02/28/06 (Hubbard, Dirk) (Entered: 02/13/2006)

02/13/2006 3578 MOTION to Withdraw as Attorney −−Michael Jones by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 02/13/2006)

02/14/2006 3579 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Eric Rice on 02/28/06 at 9:30 AM. (Hubbard, Dirk) (Entered: 02/14/2006)

02/15/2006 3580 MOTION to Amend Scheduling Order , Motion to Compel Discovery, Motion for Sanctions, and Appeal from Paragraph (3) of Judge Waxse's 2/8/06 Order by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 02/15/2006)

02/15/2006

3581

MEMORANDUM IN SUPPORT of 3580 MOTION to Amend Scheduling Order , Motion to Compel Discovery, Motion for Sanctions, and Appeal from Paragraph (3) of Judge Waxse's 2/8/06 Order by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit 1 #(2) Exhibit 2 #(3) Exhibit 3 #(4) Exhibit 4) (Hubbard, Dirk) (Entered: 02/15/2006)

02/15/2006 3582 NOTICE by Plaintiff Shirley Williams of taking deposition of Lisa Watson on March 9, 2006 at 9:00AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3583 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on March 7, 2006 at 9:00AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3584 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Meyer on February 28, 2006 at 9:00AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3585 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John Garcia on February 23, 2006 at 9:00 AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3586 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Robin O'Conner on February 21, 2006 at 9:00 AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3587 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Kate Fisher on March 15, 2006 at 9:00 AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3588 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Kathi Kersti on March 23, 2006 at 9:00 AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3589 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Mark Klinger on March 2, 2006 at 9:00 AM. (Klamann, John) (Entered: 02/15/2006)

02/15/2006 3590 NOTICE by Plaintiff Shirley Williams of taking deposition of Right Management Consultants, Inc. and Steven Carter on February 22, 2006 at 3:30 PM. (Klamann, John) (Entered: 02/15/2006)

02/16/2006

3591

MOTION for Reconsideration re 3549 Memorandum and Order, and in the Alternative, For Clarification and Stay by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A − privilege log entries #(2) Exhibit B − transcript of 02/02/2006 Magistrate hearing) (Dupont, Philip) (Motion title modified on 3/8/2006. (mg)) (Entered: 02/16/2006)

02/16/2006 3592 MOTION for Protective Order Regarding 3570 Plaintiff's Notice for the Deposition of James Kissinger by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A − letter to John Klamann from Phil Dupont) (Dupont, Philip) (Entered:

02/16/2006)

02/16/2006 3593 TRANSCRIPT (Pages 1−35, continued as attached) of proceedings held on 02/02/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 36−71)(mg) (Entered: 02/16/2006)

02/16/2006

3594

Minute Entry for Discovery/Status Conference held on 2/16/2006 before Magistrate Judge David J. Waxse. Next Discovery/Status Conference set for 3/2/2006 at 02:00 PM before Magistrate Judge David J. Waxse. Minute Sheet attached. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 02/16/2006)

02/16/2006

3595

Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit 1. Documents Listed on Defendant Sprint's 8−12−05 #(2) Exhibit 2. Documents Listed on Defendant Sprint's New Entries #(3) Exhibit 3. Letter Dated January 23, 2006 #(4) Exhibit 4. Sprint Legal Staff) (Hubbard, Dirk) (Motion title modified on 2/17/2006. (mg)) (Entered: 02/16/2006)

02/17/2006

3596

ORDER memorializing the Court's rulings from the 2/16/2006 Discovery/Status conference. Defendant's 3573 Motion for Protective Order Regarding Plaintiffs' Deposition Notice for John St. Angelo is found to be moot. The 3578 Motion to Withdraw filed by Attorney Michael F. Jones is granted. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 2/17/2006. (byk) (Entered: 02/17/2006)

02/17/2006 3597 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Stine on February 20, 2006. (Yates, John) (Entered: 02/17/2006)

02/17/2006 3598 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Glenn Gillihan on February 21, 2006. (Yates, John) (Entered: 02/17/2006)

02/17/2006 3599 NOTICE by Defendant Sprint/United Management Company of taking deposition of Katherine Roe on February 23, 2006. (Yates, John) (Entered: 02/17/2006)

02/17/2006 3600 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Steele on February 23, 2006. (Yates, John) (Entered: 02/17/2006)

02/17/2006 3601 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Morris Smith on February 24, 2006. (Yates, John) (Entered: 02/17/2006)

02/17/2006 3602 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Jan Price by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A #(2) Exhibit B #(3) Exhibit C #(4) Exhibit D) (Dupont, Philip) (Entered: 02/17/2006)

02/17/2006 3603 MEMORANDUM IN SUPPORT of 3602 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Jan Price by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 02/17/2006)

02/20/2006 3604 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Depostion of Sprint by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A) (Dupont, Philip) (Entered: 02/20/2006)

02/20/2006 3605 MOTION for Review and Objections to Magistrate's Order of February 1, 2006 (Doc. #35491) as That Order Relates to Adverse Impact Analyses by Plaintiff Shirley Williams. (Hubbard, Dirk) (Text modified on 02/21/06. (mg)) (Entered: 02/20/2006)

02/20/2006 3606 RESPONSE by Plaintiff Shirley Williams re 3575 MOTION to Strike 3568 Plaintiffs' Supplemental Memorandum in Support of Cavenaugh Plaintiffs' Motion to Intervene. (Attachments: #(1)) (Egan, Dennis) (Entered: 02/20/2006)

02/21/2006 3607 MEMORANDUM AND ORDER granting 3270 Motion to Intervene. Cavanaugh Plaintiffs are granted leave to intervene for the limited purpose of seeking to modify the Stipulated Proctective Order. It is further ordered that Defendants 3575 Motion to Strike Plaintiffs' Supplemental Memorandum in Support of Cavanaugh Plaintiffs'

Motion to Intervene is denied. Signed by Magistrate Judge David J. Waxse on 02/17/06. (mg) (Entered: 02/21/2006)

02/21/2006 3608 NOTICE by Defendant Sprint/United Management Company of taking deposition of Teresa Nichols on February 22, 2006. (Dupont, Philip) (Entered: 02/21/2006)

02/21/2006 3609 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marjorie Hattrup on February 24, 2006. (Dupont, Philip) (Entered: 02/21/2006)

02/22/2006 3610 CERTIFICATE OF SERVICE of Plaintiffs' Tenth Supplemental Voluntary Disclosures Pursuant to Rule 26(a)(1) by Shirley Williams. (Hubbard, Dirk) (Entered: 02/22/2006)

02/22/2006 3611 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3591 MOTION for Reconsideration re 3549 Memorandum & Order. (Attachments: #(1) Exhibit 1 #(2) Exhibit 2 #(3) Exhibit 3 #(4) Exhibit 4 #(5) Exhibit 5) (Hubbard, Dirk) (Entered: 02/22/2006)

02/22/2006 3612 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3604 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Depostion of Sprint. (Attachments: #(1) Exhibit 1 #(2) Exhibit 2 #(3) Exhibit 3) (Hubbard, Dirk) (Entered: 02/22/2006)

02/22/2006 3613 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Joseph A. Ritt, Jr. on February 23, 2006. (Dupont, Philip) (Entered: 02/22/2006)

02/22/2006 3614 NOTICE by Defendant Sprint/United Management Company of taking deposition of Albert M. Frankovich on February 28, 2006. (Dupont, Philip) (Entered: 02/22/2006)

02/22/2006

3615

ORDER regarding 3580 Motion Order − specifically plaintiff's Appeal from Paragraph (3) of Judge Waxse's 2/8/06 Order − the court denies plaintiff's appeal without prejudice to refiling as a separate motion. Signed by John W. Lungstrum on 02/22/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 02/22/2006)

02/23/2006 3616 MOTION to Stay re 3607 Order Modifying the Protective Order Pending a Motion for Reconsideration or Objection by Defendant Sprint/United Management Company. (Dupont, Philip) (Motion title modified on 2/24/2006. (mg)) (Entered: 02/23/2006)

02/23/2006

3617

ORDER Setting Closed Evidentiary Hearing on Sealed Motion 3542 for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged. Closed Evidentiary Hearing set for 3/2/2006 at 02:00 PM before Magistrate Judge David J. Waxse. COUNSEL MUST VIEW ORDER FOR SPECIFIC DETAILS REGARDING PREPARATION FOR THIS CLOSED EVIDENTIARY HEARING. Signed by Magistrate Judge David J. Waxse on 02/23/2006. (mts) (Entered: 02/23/2006)

02/23/2006

3618

MOTION to Compel the Resumption of the Deposition of Jan Price and Memorandum in Support and Plaintiffs' Memorandum in Opposition to Defendant's Motion for Protective Order Regading Plaintiffs' Deposition Notice for the Deposition of Jan Price by Plaintiff Shirley Williams (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7) (Hubbard, Dirk) (Entered: 02/23/2006)

02/23/2006 3619 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3592 MOTION for Protective Order Regarding 3570 Plaintiff's Notice for the Deposition of James Kissinger. (Attachments: #(1) Exhibit 1)(Hubbard, Dirk) (Entered: 02/23/2006)

02/23/2006 3620 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Danette Norris on March 17, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006 3621 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Nancy Fox on March 29, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006 3622 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Ron Gier on April 4, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006 3623 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Nick Sweers on April 7, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006 3624 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Dan Falvey on April 26, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006 3625 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Kathy Walker on April 11, 2006 at 9:00AM. (Klamann, John) (Entered: 02/23/2006)

02/23/2006

3626

MOTION to Compel Discovery by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B #(3) Exhibit C #(4) Exhibit D #(5) Exhibit E #(6) Exhibit F #(7) Exhibit G #(8) Exhibit H #(9) Exhibit I #(10) Exhibit J #(11) Exhibit K #(12) (Exhibit L) (Meyers, Martin) (Duplicate text removed on 2/24/2006. (mg)) (Entered: 02/23/2006)

02/23/2006 3627 MEMORANDUM IN SUPPORT of 3626 MOTION to Compel Discovery by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 02/23/2006)

02/24/2006 3628 RESPONSE by Plaintiff Shirley Williams re 3616 MOTION to Stay re 3607 Order Modifying the Protective Order Pending a Motion for Reconsideration or Objection. (Egan, Dennis) (Entered: 02/24/2006)

02/27/2006 3629 TRANSCRIPT (Pages 1−35, continued as attached) of proceedings held on 02/16/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 36−70)(mg) (Entered: 02/27/2006)

02/27/2006 3630 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marla Lowe on March 1, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3631 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Kathy Pine on March 2, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3632 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Joseph A. Ritt, Jr. on March 2, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3633 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cheryl Lynn Davis on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3634 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of David Molz on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3635 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Schaffer on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3636 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Morris Smith on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3637 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Albers on March 7, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3638 NOTICE by Defendant Sprint/United Management Company of taking deposition of Alan D. Otto on March 7, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3639 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jennifer Ehart on March 8, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3640 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of David Haskins on March 8, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3641 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kevin L. Neuer on March 8, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3642 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Grahovac on March 9, 2006. (Dupont, Philip) (Entered: 02/27/2006)

02/27/2006 3643 NOTICE by Defendant Sprint/United Management Company of taking deposition of Deborah Viebrock on March 9, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3644 NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Barquist Kennedy on March 9, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3645 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Ralph Sweatte on March 9, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3646 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lamont Eanes on March 10, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3647 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Stephen Homan on March 10, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3648 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of David Molz on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3649 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Morris Smith on March 3, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3650 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Kenneth Cromley on March 8, 2006. (Dupont, Philip) (Entered: 02/27/2006)
02/27/2006 3651 NOTICE by Plaintiff Shirley Williams of taking deposition of Elaine Bishop on March 7, 2006. (Meyers, Martin) (Entered: 02/27/2006)
02/28/2006 3652 MOTION to Compel by Plaintiff Shirley Williams. (Braud, Bert) (Entered: 02/28/2006)
02/28/2006 3653 MEMORANDUM IN SUPPORT of 3652 MOTION to Compel by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A; #(2) Exhibit B)(Braud, Bert) (Entered: 02/28/2006)
02/28/2006 3654 CERTIFICATE OF COMPLIANCE by Plaintiff Shirley Williams re 3653 Memorandum in Support of Motion, 3652 MOTION to Compel. (Braud, Bert) (Entered: 02/28/2006)
02/28/2006 3655 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Diane Shoemaker−Katz on March 14, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3656 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Janet Larson on March 16, 2005 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3657 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Kelley Carlisle on March 24, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3658 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on March 30, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3659 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sheryl Bowlin on March 31, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3660 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 6, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3661 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 13, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3662 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Pamela Johnson on April 14, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)
02/28/2006 3663 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Keith Paglusch on April 18, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3664 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 20, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3665 NOTICE by Plaintiff Shirley Williams of taking deposition of Catherine Johnson on April 21, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3666 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 27, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3667 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Leon Lang on April 28, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3668 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Stout on May 2, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3669 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on May 4, 2006 at 9:00AM. (Klamann, John) (Entered: 02/28/2006)

02/28/2006

3670

MOTION to Compel Answers to Supplemental (Tenth) Request for Production of Documents by Plaintiff Shirley Williams (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13# 14 Exhibit 14) (Hubbard, Dirk) (Motion title modified on 3/15/2006. (mg)) (Entered: 02/28/2006)

02/28/2006 3671 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of TAMMY KINNEY on MAY 5, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3672 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of JOANE WALKER on MAY 9, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3673 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(1) MEMBERS OF "EVENTS GROUP" on MAY 11, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3674 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of JODY BRANN on MAY 12, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3675 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) REP RE: NATIONAL MANAGEMENT PRACTICES on MAY 18, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3676 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of AMY L. CANTON on MAY 19, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3677 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of KARIN MILLER on MAY 23, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3678 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) REP on MAY 24, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3679 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) REP on MAY 25, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3680 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of YOUSEF JAVADI on MAY 26, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3681 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) REP RE: "PROJECT HEMINGWAY − PROCESS GUIDE" on MAY 30, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3682 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(1) RE: DESIGNER & APPROVER OF SALADIN "ALPHA" PROCESS on MAY 31, 2006 @ 9AM (Klamann, John) (Entered: 02/28/2006)

02/28/2006 3683 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Elaine Bishop on March 28, 2006 (Meyers, Martin) (Entered: 02/28/2006)

02/28/2006 3684 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3616 MOTION to Stay re 3607 Order Modifying the Protective Order Pending a Motion for Reconsideration or Objection (Dupont, Philip) (Entered: 02/28/2006)

03/01/2006

3685

RESPONSE by Defendant Sprint/United Management Company re 3580 MOTION to Amend Scheduling Order , Motion to Compel Discovery, Motion for Sanctions, and Appeal from Paragraph (3) of Judge Waxse's 2/8/06 Order (Attachments: # 1 Exhibit A − excerpts from transcript of March 23, 2005 hearing# 2 Exhibit B − transcript of February 24, 2006 meet and confer)(Dupont, Philip) (Entered: 03/01/2006)

03/02/2006 3686 NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Sturgess on March 20, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3687 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Ford on March 22, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3688 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Steele on March 23, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3689 NOTICE by Defendant Sprint/United Management Company of taking deposition of Clinton Heintzelman on March 27, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3690 NOTICE by Defendant Sprint/United Management Company of taking deposition of Steven Lacey on March 28, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3691 NOTICE by Defendant Sprint/United Management Company of taking deposition of Floyd Summa on March 30, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3692 NOTICE by Defendant Sprint/United Management Company of taking deposition of Vickie Dickinson on March 30, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3693 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dave Molinaro on March 30, 2006. (Dupont, Philip) ). (Entered: 03/02/2006)

03/02/2006 3694 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jeffrey C. Shipley on March 30, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3695 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nolan Beatty on March 31, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3696 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carl Grady on March 31, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3697 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Teryl Casey on March 31, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3698 NOTICE by Plaintiff Shirley Williams of taking deposition of Al Kurtz on March 29, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3699 NOTICE by Plaintiff Shirley Williams of taking deposition of Alan Sykes on March 31, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3700 NOTICE by Plaintiff Shirley Williams of taking deposition of Shelly Wagoner on March 31, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3701 NOTICE by Plaintiff Shirley Williams of taking deposition of Jerine Newsome on April 5, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3702 NOTICE by Plaintiff Shirley Williams of taking deposition of Shawn Kincaid on April 5, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3703 NOTICE by Plaintiff Shirley Williams of taking deposition of Linda Gamso on April 7, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3704 NOTICE by Plaintiff Shirley Williams of taking deposition of Cody Krause on April 7, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3705 NOTICE by Plaintiff Shirley Williams of taking deposition of Don Hallacy on April 14, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3706 NOTICE by Plaintiff Shirley Williams of taking deposition of Carol Bussing on April 14, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3707 NOTICE by Plaintiff Shirley Williams of taking deposition of Craig Childs on April 19, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3708 NOTICE by Plaintiff Shirley Williams of taking deposition of Ralph Hodges on April 19, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3709 NOTICE by Plaintiff Shirley Williams of taking deposition of Bill Gunter on April 21, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3710 NOTICE by Plaintiff Shirley Williams of taking deposition of Cynthia Taylor−Wright on April 26, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3711 NOTICE by Plaintiff Shirley Williams of taking deposition of Janice Schonwetter on April 26, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3712 NOTICE by Plaintiff Shirley Williams of taking deposition of Debra Simpson on May 3, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3713 NOTICE by Plaintiff Shirley Williams of taking deposition of Lynne Simpson on May 3, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3714 NOTICE by Plaintiff Shirley Williams of taking deposition of Vickie Koch on May 10, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3715 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Jensen on May 10, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006 3716 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of David Molz on March 3, 2006. (Dupont, Philip) (Entered: 03/02/2006)

03/02/2006 3717 NOTICE by Plaintiff Shirley Williams of taking deposition of Tammy Keasling on April 4, 2006. (Graham, Gene) (Entered: 03/02/2006)

03/02/2006

3718

RESPONSE by Defendant Sprint/United Management Company re 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved. (Attachments: # 1 Exhibit A − log entries at issue# 2 Exhibit B − transcript of 2/8/06 meet and confer# 3 Exhibit C − Dirk Hubbard letter# 4 Exhibit D − Christine Miller letter# 5 Exhibit E − original log entries)(Dupont, Philip) (Entered: 03/02/2006)

03/03/2006

3719

Minute Entry for Closed Evidentiary Hearing re Sealed Motion 3542 for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged held on 3/2/2006 before Magistrate Judge David J. Waxse. Hearing continued to 3/10/2006 at 09:00 AM before Magistrate Judge David J. Waxse. (byk) (Entered: 03/03/2006)

03/03/2006 3720 ENTRY OF APPEARANCE by Brian D. DeFrain on behalf of all plaintiffs. (DeFrain, Brian) (Modified on 3/6/2006. (mg)) (Entered: 03/03/2006)

03/03/2006 3721 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eric Rice on March 7, 2006. (Dupont, Philip) (Entered: 03/03/2006)

03/06/2006 3722 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Eric Rice on March 7, 2006. (Dupont, Philip) (Entered: 03/06/2006)

03/06/2006 3723 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Winkler on March 7, 2006. (Hubbard, Dirk) (Entered: 03/06/2006)

03/06/2006 3724 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on March 7, 2006. (Meyers, Martin) (Entered: 03/06/2006)

03/06/2006 3725 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Eric Rice on March 7, 2006. (Meyers, Martin) (Entered: 03/06/2006)

03/06/2006

3726

RESPONSE by Defendant Sprint/United Management Company re 3605 MOTION for Review and Objections to Magistrate's Order of February 1, 2006 (Doc. #3549) as That Order Relates to Adverse Impact Analyses. (Attachments: # 1 Exhibit A − excerpts from transcript of 2/27/04 hearing# 2 Exhibit B − excerpts from transcript of 3/2/04 hearing# 3 Exhibit C − excerpts from transcript of 3/31/05 hearing)(Dupont, Philip) (Entered: 03/06/2006)

03/07/2006 3727 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3591 MOTION for Reconsideration re 3549 Memorandum and Order, and in the Alternative, For Clarification and Stay. (Attachments: #(1) Exhibit A) (Dupont, Philip) (Motion title modified on 3/8/2006. (mg)) (Entered: 03/07/2006)

03/08/2006 3728 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3604 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Depostion of Sprint. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Dupont, Philip) (Entered: 03/08/2006)

03/08/2006

3729

RESPONSE by Defendant Sprint/United Management Company re 3618 MOTION to Compel the Resumption of the Deposition of Jan Price and Memorandum in Support and Plaintiffs' Memorandum in Opposition to Defendant's Motion for Protective Order Regading Plaintiffs' Deposition Notice for the Deposition of Jan Price (Attachments: # 1 Exhibit A)(Dupont, Philip) (Entered: 03/08/2006)

03/09/2006 3730 RESPONSE by Defendant Sprint/United Management Company re 3626 MOTION to Compel Discovery. (Dupont, Philip) (Entered: 03/09/2006)

03/10/2006

3731

MOTION for Review Of Magistrate Judge's Memorandum And Order That Modifies The Protective Order Agreed To By The Parties, And That Thereby Permits Intervening Plaintiffs To Avoid The Discovery Process And Limits In Their Own Case by Defendant Sprint/United Management Company (Dupont, Philip) (Entered: 03/10/2006)

03/10/2006 3732 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Janet Larson by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G) (Dupont, Philip) (Entered: 03/10/2006)

03/10/2006 3733 MEMORANDUM IN SUPPORT of 3732 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Janet Larson by Defendant Sprint/United Management Company(Dupont, Philip) (Entered: 03/10/2006)

03/10/2006 3734 AFFIDAVIT of Compliance re 3732 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Janet Larson by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/10/2006)

03/14/2006

3735

Minute Entry for Closed Evidentiary Hearing re Sealed Motion 3542 for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged held on 3/10/2006 before Magistrate Judge David J. Waxse. Plaintiffs' oral request to extend their expert disclosures deadline is granted. The deadline for Plaintiffs to serve their disclosures required by Fed. R. Civ. P. 26(a)(2), including reports from retained experts, is extended to April 14, 2006, with depositions of said experts to be completed by May 15, 2006. Defendant's deadline to serve its disclosures required by Fed. R. Civ. P. 26(a)(2), including reports from retained experts, is accordingly extended to June 15, 2006, with depositions of said experts to be completed by July 15, 2006. Disclosures and reports by any rebuttal experts shall be served by July 15, 2006 with depositions to be completed by August 15, 2006. Next discovery/status conference set for 3/16/2006 at 02:00 PM before Magistrate Judge David J. Waxse. Minute Sheet attached. (byk) (Entered: 03/14/2006)

03/14/2006 3736 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Ford on March 21, 2006. (Dupont, Philip) (Entered: 03/14/2006)

03/14/2006

3737

RESPONSE by Defendant Sprint/United Management Company re 3652 MOTION to Compel. (Attachments: # 1 Exhibit Index# 2 Exhibit A − 8/1/05 Letter# 3 Exhibit B − 8/16/05 letter# 4 Exhibit C − 8/30/05 letter# 5 Exhibit D − 9/21/05 letter# 6 Exhibit E − 10/12/05 letter# 7 Exhibit F − 10/15/05 letter# 8 Exhibit G − 10/17/05 letter# 9 Exhibit H − 12/2/05 letter# 10 Exhibit I − 12/7/05 letter# 11 Exhibit J − 12/14/05 letter# 12 Exhibit K − 12/15/05 letter# 13 Exhibit L − 12/30/05 letter# 14 Exhibit M − 1/6/06 letter# 15 Exhibit N − 1/13/06 Transcript# 16 Exhibit O − 2/2/06 Transcript# 17 Exhibit P − 7/14/05 letter)(Dupont, Philip) (Entered: 03/14/2006)

03/14/2006 3738 RESPONSE by Defendant Sprint/United Management Company re 3670 MOTION to Compel Answers to Supplemental (Tenth) Request for Production of Documents. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit # 8 Exhibit # 9 Exhibit)(Dupont, Philip) (Entered: 03/14/2006)

03/15/2006 3739 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3580 MOTION to Amend Scheduling Order , Motion to Compel Discovery, Motion for Sanctions, and Appeal from Paragraph (3) of Judge Waxse's 2/8/06 Order. (Attachments: #(1) Exhibit One #(2) Exhibit Two)(Hubbard, Dirk) (Entered: 03/15/2006)

03/15/2006 3740 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3605 MOTION for Review and Objections to Magistrate's Order of February 1, 2006 (Doc. #35491) as That Order Relates to Adverse Impact Analyses. (Hubbard, Dirk) (Duplicate text removed on 3/16/2006. (mg)) (Entered: 03/15/2006)

03/15/2006

3741

RESPONSE by Plaintiff Shirley Williams re 3731 MOTION for Review Of Magistrate Judge's Memorandum And Order That Modifies The Protective Order Agreed To By The Parties, And That Thereby Permits Intervening Plaintiffs To Avoid The Discovery Process And Limits In Their Own Case. (Attachments: #(1) #(2) #(3))(Egan, Dennis) (Entered: 03/15/2006)

03/16/2006 3742 SEALED TRANSCRIPT (Pages 1−37, continued as attached) of proceedings held on 03/02/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 38−75)(mg) (Transcripts sealed per 3617 on 3/16/2006. (mg)) (Entered: 03/16/2006)

03/16/2006

3743

REPLY MEMORANDUM IN SUPPORT of 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit 1 #(2) Exhibit 2)(Hubbard, Dirk) (Document title modified on 3/17/2006. (mg)) (Entered: 03/16/2006)

03/16/2006 3744 Minute Entry for Discovery/Status Conference held on 3/16/2006 before Magistrate Judge David J. Waxse. Next Discovery/Status Conference set for 4/20/2006 at 02:00 PM before Magistrate Judge David J. Waxse. (Minute Sheet attached.)(byk) (Entered: 03/16/2006)

03/16/2006 3745 ORDER memorializing the Court's rulings from the 3/16/2006 Discovery/Status Conference. See attached Order for details. Signed by Magistrate Judge David J. Waxse on 3/16/2006. (byk) (Entered: 03/16/2006)

03/20/2006 3746 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Vickie Dickinson on March 24, 2006. (Dupont, Philip) (Entered: 03/20/2006)

03/20/2006 3747 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sharon Steele on March 24, 2006. (Dupont, Philip) (Entered: 03/20/2006)

03/20/2006 3748 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Steven Lacey on March 28, 2006. (Dupont, Philip) (Entered: 03/20/2006)

03/21/2006

3749

MEMORANDUM AND ORDER granting in part and denying in part 3353 Motion to Compel. Defendant's Motion to Compel is granted as to Defendant's Fourth Interrogatory Nos. 2, 3, 8−11, and 13−34, and granted in part and denied in part as to Fourth Interrogatory Nos. 1, 4 − 6, and denied as to Fourth Interrogatory Nos. 7, 35, and Fourth Request for Production Nos. 28−31. Plaintiffs shall serve their supplemental responses within thirty (30) days. See Memorandum and Order for further details. Signed by Magistrate Judge David J. Waxse on 3/21/2006.(byk) (Entered: 03/21/2006)

03/22/2006 3750 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3626 MOTION to Compel Discovery. (Meyers, Martin) (Entered: 03/22/2006)

03/23/2006

3751

REPLY to Response to Motion by Defendant Sprint/United Management Company re: 3731 MOTION for Review Of Magistrate Judge's Memorandum And Order That Modifies The Protective Order Agreed To By The Parties, And That Thereby Permits Intervening Plaintiffs To Avoid The Discovery Process And Limits In Their Own Case. (Attachments: #(1) Exhibit A − March 3, 2006 hearing transcript #(2) Exhibit B − February 14, 2006 hearing transcript #(3) Exhibit C − February 13, 2006 hearing transcript)(Yates, John) (Entered: 03/23/2006)

03/23/2006 3752 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Guth on April 4, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3753 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lloyd Sanders on April 4, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3754 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Joyce Savage on April 5, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3755 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianna Williams on April 5, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3756 NOTICE by Defendant Sprint/United Management Company of taking deposition of Audry Wise (Schultz) on April 6, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3757 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ruben Zaragoza on April 6, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3758 NOTICE by Defendant Sprint/United Management Company of taking deposition of Diane K. Bland on April 7, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3759 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Faucher on April 7, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3760 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jimmy Norfleet on April 10, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3761 NOTICE by Defendant Sprint/United Management Company of taking deposition of Henry B. Miller on April 10, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3762 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Jennifer Ehart on April 11, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3763 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bobbie Perry on April 11, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3764 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Settles on April 11, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3765 NOTICE by Defendant Sprint/United Management Company of taking deposition of Bertie Justice (Belfiglio) on April 12, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3766 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gary Shappell on April 12, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3767 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Lamont Eanes on April 13, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3768 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donald Shook on April 13, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3769 NOTICE by Defendant Sprint/United Management Company of taking deposition of Melvyn Dunkerley on April 13, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3770 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Affolder on April 18, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3771 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Pressell on April 18, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3772 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Kulka on April 18, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3773 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Roberts on April 19, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3774 NOTICE by Defendant Sprint/United Management Company of taking deposition of Catherine Prazenica on April 19, 2006. (Dupont, Philip) (Entered: 03/23/2006)

03/23/2006 3775 NOTICE by Defendant Sprint/United Management Company of taking deposition of Hyla Weeks on April 19, 2006 (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3776 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carl Robinson on April 20, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3777 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kermie Lackey on April 20, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3778 NOTICE by Defendant Sprint/United Management Company of taking deposition of Paul Lemay on April 20, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3779 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Judith Gaffney on April 21, 2006. (Dupont, (Entered: 03/23/2006)
03/23/2006 3780 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carldene Sue Green on April 21, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3781 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Sturgess on April 21, 2006. (Dupont, Philip) (Entered: 03/23/2006)
03/23/2006 3782 NOTICE by Plaintiff Shirley Williams of taking deposition of John Naylor on 4/5/2006. (Egan, Dennis) (Entered: 03/23/2006)
03/23/2006 3783 NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Betts on 4/18/2006. (Egan, Dennis) (Entered: 03/23/2006)
03/23/2006 3784 NOTICE by Plaintiff Shirley Williams of taking deposition of Renee Finks on 4/19/2006. (Egan, Dennis) (Entered: 03/23/2006)
03/23/2006 3785 NOTICE by Plaintiff Shirley Williams of taking deposition of Gavin Pinchback on 4/21/2006. (Egan, Dennis) (Entered: 03/23/2006)
03/23/2006 3786 NOTICE by Plaintiff Shirley Williams of taking deposition of John Shannon on 4/25/2006. (Egan, Dennis) (Entered: 03/23/2006)
03/24/2006 3787 NOTICE by Defendant Sprint/United Management Company of taking deposition of Werner Kalytka on April 24, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3788 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marca Snook on April 25, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3789 NOTICE by Defendant Sprint/United Management Company of taking deposition of Daniel Strader on April 25, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3790 NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Watkins−Case on April 26, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3791 NOTICE by Defendant Sprint/United Management Company of taking deposition of Charles Stephens on April 26, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3792 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Sumner on April 27, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3793 NOTICE by Defendant Sprint/United Management Company of taking deposition of Elaine Wilson on April 27, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3794 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Zabic on April 28, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3795 NOTICE by Defendant Sprint/United Management Company of taking deposition of Randy Yates on April 28, 2006. (Dupont, Philip) (Entered: 03/24/2006)
03/24/2006 3796 NOTICE OF SERVICE by Shirley Williams of Eleventh Supplemental Voluntary Disclosures. (Hubbard, Dirk) (Entered: 03/24/2006)
03/24/2006 3797 STIPULATION of Dismissal with Prejudice of Claims of Three Opt−In Plaintiffs by Shirley Williams. (Hubbard, Dirk) (Entered: 03/24/2006)

03/27/2006

3798

ORDER re 3542 SEALED MOTION for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged. All briefing of this motion, as ordered at the 3/10/2006 Closed Evidentiary Hearing (see doc. 3735), shall be filed under seal. Entered by Magistrate Judge David J. Waxse on 3/27/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 03/27/2006)

03/27/2006 3799 CERTIFICATE OF SERVICE of Plaintiff Eleventh Request for Production of Documents to Defendant Sprint by Shirley Williams. (Egan, Dennis) (Entered: 03/27/2006)

03/27/2006 3800 CERTIFICATE OF SERVICE of Plaintiffs' Tenth Interrogatories to Defendant Sprint by Shirley Williams. (Egan, Dennis) (Entered: 03/27/2006)

03/27/2006 3801 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Sturgess on April 28, 2006 (Dupont, Philip) (Entered: 03/27/2006)

03/27/2006 3802 ORDER OF DISMISSAL With Prejudice Opt−In Plaintiffs Thomas Lewis Long, James R. Canter, and Stephen Homan. Each party to bear it's own costs. Signed by Judge John W. Lungstrum on 03/27/06.(mg) (Entered: 03/27/2006)

03/27/2006 3803 MOTION to Compel in Relation to Deposition of John St. Angelo and Memorandum in Support by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B) (Hubbard, Dirk) (Entered: 03/27/2006)

03/27/2006 3804 ORDER taking under advisement 3605 Motion for Review and Objections to Magistrate's Order of February 1, 2006 (Doc. #35491) as That Order Relates to Adverse Impact Analyses . Signed by Judge John W. Lungstrum on 03/27/2006. (ses) (Entered: 03/27/2006)

03/27/2006 3811 SEALED POST−EVIDENTIARY HEARING BRIEF (with Exhibits HHH, JJJ, KKK, and LLL in support) regarding 3542 SEALED MOTION for In Camera Review of Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged by Defendant Sprint/United Management Company. (mg) (hw). (Entered: 03/28/2006)

03/28/2006 3805 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3670 MOTION to Compel Answers to Supplemental (Tenth) Request for Production of Documents (Plaintiffs' Reply Memorandum in Support) (Hubbard, Dirk) (Entered: 03/28/2006)

03/28/2006 3806 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3652 MOTION to Compel (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Braud, Bert) (Entered: 03/28/2006)

03/28/2006 3807 MOTION for Protective Order Regarding Depositions of Opt−In Plaintiffs Who Have Been De−Listed and Who are Thus Not Witnesses for the Pattern and Practice Trial and Memorandum in Support by Plaintiff Shirley Williams (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C) (Hubbard, Dirk) (Entered: 03/28/2006)

03/28/2006 3808 MOTION for Protective Order Regarding Depositions of Opt−In Plaintiffs Who Have Never Been Listed as Witnesses for the Pattern and Practice Trial by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D) (Hubbard, Dirk) (Duplicate text removed on 4/12/2006. (mg)) (Entered: 03/28/2006)

03/28/2006 3809 MOTION for Protective Order Regarding Depositions of Out−of−Town Opt−In Plaintiffs and Request That Such Depositions be Conducted by Telephone by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C) (Hubbard, Dirk) (Duplicate text removed on 4/21/2006. (mg)) (Entered: 03/28/2006)

03/28/2006 3810 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Carl Grady on April 27, 2006 (Dupont, Philip) (Entered: 03/28/2006)

03/28/2006 3812 RESPONSE to 3658 Notice to Take Deposition by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 03/28/2006)

03/29/2006 3813 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Steven Carter − Right Management Consultants, Inc. on April 4, 2006 at 10:00AM. (Klamann, John) (Entered: 03/29/2006)

03/29/2006 3814 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 17, 2006 at 9:00AM. (Klamann, John) (Entered: 03/29/2006)
03/29/2006 3815 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative on April 25, 2006 at 9:00AM. (Klamann, John) (Entered: 03/29/2006)
03/29/2006 3816 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Edwards on April 11, 2006. (Dupont, Philip) (Entered: 03/29/2006)
03/29/2006 3817 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Randy Yates on April 20, 2006. (Dupont, Philip) (Entered: 03/29/2006)
03/30/2006 3818 NOTICE by Plaintiff Shirley Williams of taking deposition of Shelly Wagner on May 12, 2006 at 9:00 a.m.. (Graham, Gene) (Entered: 03/30/2006)
03/30/2006 3819 NOTICE by Plaintiff Shirley Williams of taking deposition of Jarie Newsome on May 12, 2006 at 1:00 p.m.. (Graham, Gene) (Entered: 03/30/2006)
03/30/2006 3820 SEALED TRANSCRIPT (Pages 1−40, continued as attached) of proceedings held on 03/10/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 41−80; #(2) Pages 81−120; #(3) Pages 121−160; #(4) Pages 161−200; #(5) Pages 201−237) (Transcripts sealed per 3617 on 3/30/2006. (mg)) (Entered: 03/30/2006)
03/30/2006 3821 TRANSCRIPT (Pages 1−35, continued as attached) of proceedings held on 03/16/06 before Magistrate Judge David J. Waxse. (Attachments: #(1) Pages 36−60)(mg) (Entered: 03/30/2006)
03/30/2006 3822 OBJECTION(S) to 3679 Notice to Take Deposition of Representative of Sprint by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3823 OBJECTION(S) to 3678 Notice to Take Deposition of Defendant Sprint by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3824 OBJECTION(S) to 3682 Notice to Take Deposition of Sprint Employee by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3825 OBJECTION(S) to 3676 Notice to Take Deposition of Amy L. Canton by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3826 OBJECTION(S) to 3656 Notice to Take Deposition of Janet Larson by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3827 OBJECTION(S) to 3662 Notice to Take Deposition of Pamela Johnson by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/30/2006 3828 OBJECTION(S) to 3665 Notice to Take Deposition of Catherine Johnson by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/30/2006)
03/31/2006 3829 CERTIFICATE OF SERVICE of Plaintiffs' Eleventh Interrogatories, Twelfth Request for Production of Documents and Twelfth Supplemental Voluntary Disclosures to Defendant Sprint by Shirley Williams. (Hubbard, Dirk) (Entered: 03/31/2006)
03/31/2006 3830 CERTIFICATE OF SERVICE of Defendant's Second Request for Admissions to Plaintiff by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/31/2006)
03/31/2006 3831 CERTIFICATE OF SERVICE of Defendant's Sixth Phase II Supplemental Rule 26(a)(1) Disclosures by Sprint/United Management Company. (Yates, John) (Entered: 03/31/2006)
04/01/2006 3832 CERTIFICATE OF SERVICE of Plaintiffs' Request for Admissions to Defendant Sprint by Shirley Williams. (Hubbard, Dirk) (Entered: 04/01/2006)
04/03/2006 3833 NOTICE by Plaintiff Shirley Williams of taking deposition of Gaylene VanHorn on April 17, 2006. (Egan, Dennis) (Entered: 04/03/2006)
04/03/2006 3834 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gene Betts by Defendant Sprint/United Management Company. (Attachments: #(1) Exhibit A #(2) Exhibit B# 3 Affidavit of Compliance) (Dupont, Philip) (Entered: 04/03/2006)

04/04/2006 3835 MOTION for Reconsideration re 3749 Order on Motion to Compel, and, in the Alternative, for Clarification; and Plaintiffs' Extension of Time to Respond by Plaintiff Shirley Williams. (Hubbard, Dirk) (Duplicate text removed on 4/6/2006. (mg)) (Entered: 04/04/2006)

04/05/2006 3836 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Audry Wise (Schultz) on April 20, 2006. (Dupont, Philip) (Entered: 04/05/2006)

04/05/2006 3837 NOTICE of Hearing: Telephone Conference set for 4/6/2006 at 09:00 AM before Magistrate Judge David J. Waxse. Chambers will initiate the conference call. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 04/05/2006)

04/05/2006

3838

RESPONSE by Defendant Sprint/United Management Company re 3809 MOTION for Protective Order Regarding Depositions of Out−of−Town Opt−In Plaintiffs and Request That Such Depositions be Conducted by Telephone. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N)(Costello, Robert) (Duplicate text removed on 4/6/2006. (mg)) (Entered: 04/05/2006)

04/06/2006 3839 NOTICE by Plaintiff Shirley Williams of taking deposition of Cynthia Taylor Wright on May 8, 2006. (Graham, Gene) (Entered: 04/06/2006)

04/06/2006 3840 Minute Entry for Telephone Status Conferencer held on 4/6/2006 before Magistrate Judge David J. Waxse. Order to follow. (Minute Sheet attached.)(byk) (Entered: 04/06/2006)

04/06/2006

3841

ORDER memorializing the Court's rulings from the 4/6/2006 telephone Status Conference. All current 3523 Second Amended Second Phase Scheduling Order deadlines, except the deadline for completion of mediation, are hereby vacated pending further order of the Court. By 4/14/2006, the parties shall either (1) provide the Court with a proposed order setting forth their agreed pre−mediation procedures, including provisions and deadlines for exchanging preliminary settlement offers and preliminary expert reports, or (2) provide their respective positions on what the Court should order. Entered by Magistrate Judge David J. Waxse on 4/6/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 04/06/2006)

04/06/2006

3842

MEMORANDUM AND ORDER − 3616 Motion to Stay the courts February 21, 2006 order modifying the protective order in this case pending a motion for reconsideration or objection to be filed is hereby withdrawn and denied as moot, and 3731 Motion for Review of the magistrate judge's memorandum and order that modifies the protective order agreed to by the parties is denied. Signed by Judge John W. Lungstrum on 04/06/2006. (ses) (Entered: 04/06/2006)

04/06/2006 3843 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Renee Finks by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Affidavit of Compliance) (Costello, Robert) (Duplicate text removed on 4/7/2006. (mg)) (Entered: 04/06/2006)

04/06/2006 3844 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gavin Pinchback by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Affidavit of Compliance) (Costello, Robert) (Duplicate text removed on 4/7/2006. (mg)) (Entered: 04/06/2006)

04/06/2006 3845 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gaylene Van Horn by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Affidavit of Compliance) (Costello, Robert) (Duplicate text removed on 4/7/2006. (mg)) (Entered: 04/06/2006)

04/07/2006 3846 MOTION for Protective Order Regarding Limitations on All Future Deposition Discovery by Plaintiffs by Defendant Sprint/United Management Company. (Yates, John) (Entered: 04/07/2006)

04/07/2006 3847 SEALED DOCUMENT (Plaintiffs' Post−Hearing Brief Regarding Adverse Impact Documents). (mg) (hw). (Entered: 04/10/2006)

04/10/2006 3848 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 3803 MOTION to Compel in Relation to Deposition of John St. Angelo and Memorandum in Support. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Dupont, Philip) (Entered: 04/10/2006)

04/10/2006 3849 MEMORANDUM IN SUPPORT of 3846 MOTION for Protective Order Regarding Limitations on All Future Deposition Discovery by Plaintiffs by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A − list of deposition topics)(Yates, John) (Entered: 04/10/2006)

04/11/2006 3850 CERTIFICATE OF SERVICE of Objections to Plaintiffs' Notice for the Deposition of Sprint Employee (#3815) by Sprint/United Management Company re 3815 Notice to Take Deposition. (Dupont, Philip) (Entered: 04/11/2006)

04/11/2006 3851 MOTION for Extension of Time to File Reply as to 3847 Sealed Document − Plaintiffs' post−hearing brief on adverse impact documents by Defendant Sprint/United Management Company. (Yates, John) (Entered: 04/11/2006)

04/11/2006

3852

RESPONSE by Defendant Sprint/United Management Company re 3807 MOTION for Protective Order Regarding Depositions of Opt−In Plaintiffs Who Have Been De−Listed and Who are Thus Not Witnesses for the Pattern and Practice Trial and Memorandum in Support, 3808 MOTION for Protective Order Regarding Depositions of Opt−In Plaintiffs Who Have Never Been Listed as Witnesses for the Pattern and Practice Trial. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P)(Costello, Robert) (Duplicate text removed on 4/12/2006. (mg)) (Entered: 04/11/2006)

04/13/2006

3853

ORDER granting 3851 Sprint's MOTION for Extension of Time to File Reply as to 3847 Plaintiff's Sealed Post−Hearing Brief Regarding Adverse Impact Documents. For good cause shown, Defendant Sprint is hereby granted an extension of time, up to and including April 21, 2006, by which to file its Reply to Plaintiffs' Post−Hearing Brief Regarding Adverse Impact Documents. Entered by Magistrate Judge David J. Waxse on 4/13/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 04/13/2006)

04/17/2006

3854

MEMORANDUM in Opposition by Plaintiff Shirley Williams re 3834 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gene Betts. (Attachments: # 1 Exhibit A# 2 Appendix B# 3 Exhibit C# 4 Exhibit D−Excerpt from transcript# 5 Exhibit E−Excerpt from transcript)(Dennis, Stephen) (Entered: 04/17/2006)

04/18/2006 3855 NOTICE by Plaintiff Shirley Williams of taking deposition of Carol Bussing on May 12, 2006 at 2:00 PM. (Graham, Gene) (Entered: 04/18/2006)

04/18/2006 3856 NOTICE by Plaintiff Shirley Williams of taking deposition of Victoria Koch on May 10, 2006 at 9:00 AM. (Graham, Gene) (Entered: 04/18/2006)

04/18/2006 3857 NOTICE by Plaintiff Shirley Williams of taking deposition of Lamont Eanes on 4/25/06. (Dennis, Stephen) (Entered: 04/18/2006)

04/18/2006 3858 RESPONSE by Defendant Sprint/United Management Company re 3835 MOTION for Reconsideration re 3749 Order on Motion to Compel, and, in the Alternative, for Clarification; and Plaintiffs' Extension of Time to Respond Memorandum in Response to Plaintiffs' Motion to Reconsider. (Yates, John) (Entered: 04/18/2006)

04/18/2006 3859 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Lamont Eanes on 4/18/06 by Personal Service. (Dennis, Stephen) (Entered: 04/18/2006)

04/19/2006

3860

REPLY to Response to Motion by Plaintiff Shirley Williams re: 3809 MOTION for Protective Order Regarding Depositions of Out−of−Town Opt−In Plaintiffs and Request That Such Depositions be Conducted by Telephone. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(DeFrain, Brian) (Duplicate text removed on 4/21/2006. (mg)) (Entered: 04/19/2006)

04/20/2006 3861 Minute Entry for Discovery/Status Conferenc held on 4/20/2006 before Magistrate Judge David J. Waxse. Next Discovery/Status Conference set for 5/18/2006 at 02:00 PM before Magistrate Judge David J. Waxse. Order to follow. (Court Reporter Bowen.) (byk) (Entered: 04/20/2006)

04/21/2006

3862

MEMORANDUM in Opposition to Defendant's Motions for Protective Order Regarding Limitations on All Future Depositions by Plaintiff Shirley Williams re 3846 MOTION for Protective Order Regarding Limitations on All Future Deposition Discovery by Plaintiffs, 3844 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gavin Pinchback, 3843 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Renee Finks, 3845 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gaylene Van Horn. (Attachments: # 1 Appendix Index# 2 Appendix A# 3 Appendix B# 4 Appendix C# 5 Appendix D)(Hubbard, Dirk) (Document title modified on 4/24/2006. (mg)) (Entered: 04/21/2006)

04/21/2006 3863 SEALED POST−EVIDENTIARY HEARING REPLY to Plaintiffs' Post−Hearing Brief Regarding Adverse Impact Documents by Defendant Sprint/United Management Company. (mg) (Filed Under Seal) (hw). (Entered: 04/21/2006)

04/24/2006 3864 NOTICE by Plaintiff Shirley Williams of taking deposition of Vickie Koch on May 15, 2006 at 9:00 AM. (Graham, Gene) (Entered: 04/24/2006)

04/25/2006

3865

ORDER memorializing and supplementing the Court's rulings at the 4/20/2006 discovery conference. ORDER granting in part and denying in part 3580 Plaintiffs' Motion to Amend Scheduling Order, granting in part and denying in part 3592 Defendant's Motion for Protective Order, denying 3602 Defendant's Motion for Protective Order, denying 3604 Defendant's Motion for Protective Order, granting 3618 Plaintiffs' Motion to Compel, denying 3626 Plaintiffs' Motion to Compel, granting 3732 Defendant's Motion for Protective Order, granting 3803 Plaintiffs' Motion to Compel, denying 3807 Plaintiffs' Motion for Protective Order, denying 3808 Plaintiffs' Motion for Protective Order, denying 3809 Plaintiffs' Motion for Protective Order, denying 3834 Defendant's Motion for Protective Order, denying 3835 Plaintiffs' Motion for Reconsideration of 3/21/2006 Order. See Order for further details and rulings. Signed by Magistrate Judge David J. Waxse on 4/25/2006. (byk) (Entered: 04/25/2006)

04/26/2006 3866 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Beal on May 4, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3867 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lonnie Daniels on May 4, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3868 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronnie Cashwell on May 4, 2006 at 1:30 PM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3869 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert McIlrath on May 4, 2006 at 1:30 PM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3870 NOTICE by Defendant Sprint/United Management Company of taking deposition of Thomas Bilvin on May 5, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3871 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Markham on May 5, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3872 NOTICE by Defendant Sprint/United Management Company of taking deposition of Debra Markham on May 5, 2006 at 1:30 PM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3873 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gordon Dean Brown on May 5, 2006 at 1:30 PM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3874 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kevin D. Brown on April 28, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 04/26/2006)

04/26/2006 3875 MOTION (Application) for Leave to file Sur−Reply Brief Regarding Adverse Impact Documentsby Plaintiff Shirley Williams. (Meyers, Martin) (Motion title modified on 4/27/2006. (mg)) (Entered: 04/26/2006)

04/27/2006 3876 NOTICE by Defendant Sprint/United Management Company of taking deposition of Peggy Broughton on May 9, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3877 NOTICE by Defendant Sprint/United Management Company of taking deposition of Donna Kofsky on May 9, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3878 NOTICE by Defendant Sprint/United Management Company of taking deposition of Daniel Byrne on May 9, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3879 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jacob Rodriguez on May 9, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3880 NOTICE by Defendant Sprint/United Management Company of taking deposition of Edward Birch on May 10, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3881 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rafael Molina on May 10, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3882 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Canter on May 10, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3883 NOTICE by Defendant Sprint/United Management Company of taking deposition of Christina Siemens on May 10, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3884 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joseph Carroll on May 11, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3885 NOTICE by Defendant Sprint/United Management Company of taking deposition of Howard Tiffany on May 11, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3886 NOTICE by Defendant Sprint/United Management Company of taking deposition of Abigail Davis on May 11, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3887 NOTICE by Defendant Sprint/United Management Company of taking deposition of Patricia Cahoon on May 11, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3888 NOTICE by Defendant Sprint/United Management Company of taking deposition of Daniel Gilliam on May 12, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3889 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kevin Farley on May 12, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3890 NOTICE by Defendant Sprint/United Management Company of taking deposition of Eduardo Garrido on May 12, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3891 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Johnson on May 16, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3892 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Chance on May 16, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3893 NOTICE by Defendant Sprint/United Management Company of taking deposition of Diane Maxwell−Lambert on May 16, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3894 NOTICE by Defendant Sprint/United Management Company of taking deposition of Debra Zissis on May 17, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3895 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Nichols on May 17, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3896 NOTICE by Defendant Sprint/United Management Company of taking deposition of Miguel Arredondo on May 17, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3897 NOTICE by Defendant Sprint/United Management Company of taking deposition of Noel Strong on May 18, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)

04/27/2006 3898 NOTICE by Defendant Sprint/United Management Company of taking deposition of Craig Price on May 18, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3899 NOTICE by Defendant Sprint/United Management Company of taking deposition of Harold Gray on May 18, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3900 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lee Lewis on May 18, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3901 NOTICE by Defendant Sprint/United Management Company of taking deposition of Randal Hammond on May 19, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3902 NOTICE by Defendant Sprint/United Management Company of taking deposition of Claude Powell on May 19, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3903 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Sandra Edwards on May 19, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3904 NOTICE by Defendant Sprint/United Management Company of taking deposition of Howard Holbrook on May 23, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3905 NOTICE by Defendant Sprint/United Management Company of taking deposition of Frederic Fischer on May 23, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3906 NOTICE by Defendant Sprint/United Management Company of taking deposition of Larrie Loehr on May 24, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3907 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rosemary Delpino on May 24, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3908 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robin Karres on May 24, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3909 NOTICE by Defendant Sprint/United Management Company of taking deposition of Deborah Morton on May 25, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3910 NOTICE by Defendant Sprint/United Management Company of taking deposition of Susan Schwartz on May 25, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3911 NOTICE by Defendant Sprint/United Management Company of taking deposition of Roger Kelly on May 25, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3912 NOTICE by Defendant Sprint/United Management Company of taking deposition of Samir Demian on May 26, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3913 NOTICE by Defendant Sprint/United Management Company of taking deposition of Michael Kochevar on May 26, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3914 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joe McKinney on June 5, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3915 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rob Benson on June 5, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3916 NOTICE by Defendant Sprint/United Management Company of taking deposition of Nicole Bledsoe−Wise on June 5, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3917 NOTICE by Defendant Sprint/United Management Company of taking deposition of Matthew Bordowski on June 6, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3918 NOTICE by Defendant Sprint/United Management Company of taking deposition of Timothy Boyd on June 6, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)

04/27/2006 3919 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dayne Bozille on June 6, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3920 NOTICE by Defendant Sprint/United Management Company of taking deposition of Betty Cabello on June 6, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3921 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dave Carmel on June 7, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3922 NOTICE by Defendant Sprint/United Management Company of taking deposition of Barbara Combs on June 7, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3923 NOTICE by Defendant Sprint/United Management Company of taking deposition of Allen Dandeneau on June 7, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3924 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lennox Danielson on June 7, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3925 NOTICE by Defendant Sprint/United Management Company of taking deposition of Barbara Davis on June 8, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3926 NOTICE by Defendant Sprint/United Management Company of taking deposition of James Delaroche on June 8, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3927 NOTICE by Defendant Sprint/United Management Company of taking deposition of Beatrice Dewing on June 8, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3928 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gale Dorman on June 8, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3929 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sherry Drury on June 12, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3930 NOTICE by Defendant Sprint/United Management Company of taking deposition of Richard Eaton on June 12, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3931 NOTICE by Defendant Sprint/United Management Company of taking deposition of Marie Edwards on June 12, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3932 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ralph Evans on June 12, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3933 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mark Gaff on June 13, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3934 NOTICE by Defendant Sprint/United Management Company of taking deposition of Charles Oliver Hammond on June 13, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3935 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ruby Harvey−Burgin on June 13, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3936 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Hegstrom on June 13, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3937 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert Hodgson on June 14, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3938 NOTICE by Defendant Sprint/United Management Company of taking deposition of Judith Howard on June 14, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3939 NOTICE by Defendant Sprint/United Management Company of taking deposition of Virender Kumar on June 14, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3940 NOTICE by Defendant Sprint/United Management Company of taking deposition of Doreen Ledig on June 14, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3941 NOTICE by Defendant Sprint/United Management Company of taking deposition of Sally Leon−Guerrero on June 15, 2006 at 9:00 a.m. (Dupont, Philip) (Entered:

04/27/2006)
04/27/2006 3942 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mark Lundy on June 15, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3943 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Dianna Williams on June 15, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3944 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Majd on June 15, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3945 NOTICE by Defendant Sprint/United Management Company of taking deposition of Cy Matin (Nia) on June 15, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3946 NOTICE by Defendant Sprint/United Management Company of taking deposition of Russell Mehl on June 19, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3947 NOTICE by Defendant Sprint/United Management Company of taking deposition of Gerald Mersing on June 19, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3948 NOTICE by Defendant Sprint/United Management Company of taking deposition of Lonnie Miller on June 19, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3949 NOTICE by Defendant Sprint/United Management Company of taking deposition of Christine Monticue on June 19, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3950 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Morahan on June 20, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3951 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Radel on June 20, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3952 NOTICE by Defendant Sprint/United Management Company of taking deposition of B.J. Shiplet on June 20, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3953 NOTICE by Defendant Sprint/United Management Company of taking deposition of Rick Starling on June 20, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3954 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jerald Bethke on June 21, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3955 NOTICE by Defendant Sprint/United Management Company of taking deposition of Joan Boro on June 21, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3956 NOTICE by Defendant Sprint/United Management Company of taking deposition of Paul Buehler on June 21, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3957 NOTICE by Defendant Sprint/United Management Company of taking deposition of H. Marie Church on June 21, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3958 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ron Evangelista on June 22, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3959 NOTICE by Defendant Sprint/United Management Company of taking deposition of Debra Fields−Williams on June 22, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3960 NOTICE by Defendant Sprint/United Management Company of taking deposition of Carolyn Hawkins on June 22, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3961 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Henderson on June 22, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3962 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kevin Henry on June 26, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)

04/27/2006 3963 NOTICE by Defendant Sprint/United Management Company of taking deposition of Deborah Hufnagel on June 26, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3964 NOTICE by Defendant Sprint/United Management Company of taking deposition of J. Roger Hunt on June 26, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3965 RESPONSE by Defendant Sprint/United Management Company re 3875 MOTION (Application) for Leave to file Sur−Reply Brief Regarding Adverse Impact Documents (Yates, John) (Entered: 04/27/2006)
04/27/2006 3966 NOTICE by Defendant Sprint/United Management Company of taking deposition of Frank Kulikowski on June 26, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3967 NOTICE by Defendant Sprint/United Management Company of taking deposition of Martha Lally on June 27, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3968 NOTICE by Defendant Sprint/United Management Company of taking deposition of Kathy Lockaby on June 27, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3969 NOTICE by Defendant Sprint/United Management Company of taking deposition of Brenda Long on June 27, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3970 NOTICE by Defendant Sprint/United Management Company of taking deposition of Connie Miller on June 27, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3971 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mike O'Brien on June 28, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3972 NOTICE by Defendant Sprint/United Management Company of taking deposition of Linda Petersen on June 28, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3973 NOTICE by Defendant Sprint/United Management Company of taking deposition of Robyn Posey−Blue on June 28, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3974 NOTICE by Defendant Sprint/United Management Company of taking deposition of Fred Raby on June 28, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3975 NOTICE by Defendant Sprint/United Management Company of taking deposition of David Rohm on June 29, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3976 NOTICE by Defendant Sprint/United Management Company of taking deposition of William Benjamin Terrill on June 29, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3977 NOTICE by Defendant Sprint/United Management Company of taking deposition of Stacy Villines on June 29, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3978 NOTICE by Defendant Sprint/United Management Company of taking deposition of Karen Pence on June 29, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 04/27/2006)
04/27/2006 3979 CERTIFICATE OF SERVICE of Responses and Objections to Request No. 3 of Plaintiffs' Twelfth Request for Production of Documents by Sprint/United Management Company. (Dupont, Philip) (Entered: 04/27/2006)
05/01/2006 3980 NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on May 16, 2006. (Hubbard, Dirk) (Entered: 05/01/2006)
05/01/2006 3981 NOTICE by Plaintiff Shirley Williams of taking deposition of Defendant of Sprint on May 30, 2006. (Hubbard, Dirk) (Entered: 05/01/2006)
05/01/2006 3982 NOTICE by Plaintiff Shirley Williams of taking deposition of Jan Price on May 11, 2006. (Hubbard, Dirk) (Entered: 05/01/2006)
05/02/2006 3983 NOTICE by Plaintiff Shirley Williams of taking deposition of Don Hallacy on May 22, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3984 NOTICE by Plaintiff Shirley Williams of taking deposition of Kathy Walker on May 19, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)

05/02/2006 3985 NOTICE by Plaintiff Shirley Williams of taking deposition of Pamela Johnson on May 24, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3986 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Policies & Procedures Re: 1011 on May 25, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3987 NOTICE by Plaintiff Shirley Williams of taking deposition of Keith Paglusch on May 26, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3988 NOTICE by Plaintiff Shirley Williams of taking deposition of Craig Child on May 31, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3989 NOTICE by Plaintiff Shirley Williams of taking deposition of Ralph Hodge on June 1, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3990 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint on June 2, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3991 NOTICE by Plaintiff Shirley Williams of taking deposition of Catherine Johnson on June 5, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3992 NOTICE by Plaintiff Shirley Williams of taking deposition of Bill Gunter on June 6, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3993 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint on June 7, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3994 NOTICE by Plaintiff Shirley Williams of taking deposition of Dan Falvey on June 8, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3995 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative on June 12, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3996 NOTICE by Plaintiff Shirley Williams of taking deposition of John Dupree on June 1, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3997 NOTICE by Plaintiff Shirley Williams of taking deposition of Cynthia Taylor−Wright on June 9, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3998 NOTICE by Plaintiff Shirley Williams of taking deposition of David Farmer on June 2, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 3999 NOTICE by Plaintiff Shirley Williams of taking deposition of Carl Gast on June 5, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 4000 NOTICE by Plaintiff Shirley Williams of taking deposition of Karl Kramer on June 6, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 4001 NOTICE by Plaintiff Shirley Williams of taking deposition of Tom McEvoy on June 7, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 4002 NOTICE by Plaintiff Shirley Williams of taking deposition of Phyllis Robertson on June 12, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 4003 NOTICE by Plaintiff Shirley Williams of taking deposition of Randy Osler on June 9, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/02/2006 4004 NOTICE by Plaintiff Shirley Williams of taking deposition of John Mihalovich on June 8, 2006 (Hubbard, Dirk) (Entered: 05/02/2006)
05/03/2006 4005 NOTICE by Plaintiff Shirley Williams of taking deposition of Leon Lang on June 13, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4006 NOTICE by Plaintiff Shirley Williams of taking deposition of Robert Runke on June 13, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4007 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael W. Stout on June 14, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4008 NOTICE by Plaintiff Shirley Williams of taking deposition of Robert Walsh on June 14, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)

05/03/2006 4009 NOTICE by Plaintiff Shirley Williams of taking deposition of Debra Simpson on June 15, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4010 NOTICE by Plaintiff Shirley Williams of taking deposition of Christopher Clark on June 15, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4011 NOTICE by Plaintiff Shirley Williams of taking deposition of Lynn Simpson on June 16, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4012 NOTICE by Plaintiff Shirley Williams of taking deposition of Joseph Edward on June 16, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4013 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint on 30(b)(6) AAR on June 19, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4014 NOTICE by Plaintiff Shirley Williams of taking deposition of Daniel Dooley on June 19, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4015 NOTICE by Plaintiff Shirley Williams of taking deposition of Tammy Kinney on June 20, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4016 NOTICE by Plaintiff Shirley Williams of taking deposition of David Wilhelm on June 20, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4017 NOTICE by Plaintiff Shirley Williams of taking deposition of Joanne Walker on June 21, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4018 NOTICE by Plaintiff Shirley Williams of taking deposition of David Bottoms on June 21, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4019 NOTICE by Plaintiff Shirley Williams of taking deposition of Vickie Koch on June 22, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4020 NOTICE by Plaintiff Shirley Williams of taking deposition of Jerald Diepenbrock on June 22, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4021 NOTICE by Plaintiff Shirley Williams of taking deposition of Scott Jensen on June 23, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4022 NOTICE by Plaintiff Shirley Williams of taking deposition of Paul Kershisnik on June 23, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4023 NOTICE by Plaintiff Shirley Williams of taking deposition of David Dess on June 26, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4024 NOTICE by Plaintiff Shirley Williams of taking deposition of Jody Brann on June 27, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4025 NOTICE by Plaintiff Shirley Williams of taking deposition of John Yuzdepski on June 27, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4026 NOTICE by Plaintiff Shirley Williams of taking deposition of Walter Novick on June 28, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4027 NOTICE by Plaintiff Shirley Williams of taking deposition of Michael Hennigan on June 29, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4028 NOTICE by Plaintiff Shirley Williams of taking deposition of Jon Lightle on June 30, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4029 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint on National Management Practices training course on June 30, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4030 NOTICE by Plaintiff Shirley Williams of taking deposition of Oliver Valente on July 6, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4031 NOTICE by Plaintiff Shirley Williams of taking deposition of Karin Miller on July 7, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)

05/03/2006 4032 NOTICE by Plaintiff Shirley Williams of taking deposition of David Berry on July 13, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4033 NOTICE by Plaintiff Shirley Williams of taking deposition of Diane Parker on July 11, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4034 NOTICE by Plaintiff Shirley Williams of taking deposition of Amy L. Canton on July 6, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4035 NOTICE by Plaintiff Shirley Williams of taking deposition of David Flessas on July 7, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4036 NOTICE by Plaintiff Shirley Williams of taking deposition of Yasef Javadi on July 12, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4037 NOTICE by Plaintiff Shirley Williams of taking deposition of Robert Azzi on July 12, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4038 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint who prepared bates 149908 through 149914 on July 11, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4039 NOTICE by Plaintiff Shirley Williams of taking deposition of Faerie Kizzaire on July 10, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4040 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint Workforce Planning Group on July 10, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4041 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint The Project Hemingway Process Guide on July 13, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4042 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representatative of Sprint "Alpha" on July 14, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4043 NOTICE by Plaintiff Shirley Williams of taking deposition of Anthony D'Agata on July 14, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4044 NOTICE by Plaintiff Shirley Williams of taking deposition of Joe Crockett on July 17, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4045 NOTICE by Plaintiff Shirley Williams of taking deposition of Steven Fennel on July 17, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4046 NOTICE by Plaintiff Shirley Williams of taking deposition of Patrick O'Malley on July 18, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4047 NOTICE by Plaintiff Shirley Williams of taking deposition of Keith Woods on July 18, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4048 NOTICE by Plaintiff Shirley Williams of taking deposition of P. Von Der Linde on July 19, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4049 NOTICE by Plaintiff Shirley Williams of taking deposition of Kurt Gastrok on July 19, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4050 NOTICE by Plaintiff Shirley Williams of taking deposition of Steven Signoff on July 20, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4051 NOTICE by Plaintiff Shirley Williams of taking deposition of Maryetta Campbell on July 20, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4052 NOTICE by Plaintiff Shirley Williams of taking deposition of Kimberly Marshall on July 21, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4053 NOTICE by Plaintiff Shirley Williams of taking deposition of Karen Ynigues on July 21, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)

05/03/2006 4054 NOTICE by Plaintiff Shirley Williams of taking deposition of Robert Fox on July 24, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4055 NOTICE by Plaintiff Shirley Williams of taking deposition of Rhonda Beeler on July 24, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4056 NOTICE by Plaintiff Shirley Williams of taking deposition of Fernando Ramirez on July 25, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4057 NOTICE by Plaintiff Shirley Williams of taking deposition of Dave Pesh on July 25, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4058 NOTICE by Plaintiff Shirley Williams of taking deposition of Mike Machell on July 26, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4059 NOTICE by Plaintiff Shirley Williams of taking deposition of Melanie Horstmeier on July 27, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4060 NOTICE by Plaintiff Shirley Williams of taking deposition of Arthur Chaykin on July 27, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4061 NOTICE by Plaintiff Shirley Williams of taking deposition of Mark Bowser on July 28, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4062 NOTICE by Plaintiff Shirley Williams of taking deposition of Ted Stock on July 28, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4063 NOTICE by Plaintiff Shirley Williams of taking deposition of Jennifer Bice on July 31, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4064 NOTICE by Plaintiff Shirley Williams of taking deposition of Kimberly Klosak on July 31, 2006 (Hubbard, Dirk) (Entered: 05/03/2006)
05/03/2006 4065 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Noel Strong on May 19, 2006 at 9:00 a.m. (Dupont, Philip) (Entered: 05/03/2006)
05/04/2006 4066 NOTICE by Plaintiff Shirley Williams of taking deposition of William Blessing on 06/19/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4067 NOTICE by Plaintiff Shirley Williams of taking deposition of Ali Zanjani on 06/20/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4068 NOTICE by Plaintiff Shirley Williams of taking deposition of James Mickey on 06/21/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4069 NOTICE by Plaintiff Shirley Williams of taking deposition of Thomas Mateer on 06/22/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4070 NOTICE by Plaintiff Shirley Williams of taking deposition of Phillip Garrison on 06/23/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4071 NOTICE by Plaintiff Shirley Williams of taking deposition of Stephen Geldmacher on 06/26/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4072 NOTICE by Plaintiff Shirley Williams of taking deposition of David Stevens on 06/27/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4073 NOTICE by Plaintiff Shirley Williams of taking deposition of Terry Yu on 06/28/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4074 NOTICE by Plaintiff Shirley Williams of taking deposition of Kirk Baruth on 06/29/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4075 NOTICE by Plaintiff Shirley Williams of taking deposition of Barbara Edwards on 06/30/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4076 NOTICE by Plaintiff Shirley Williams of taking deposition of Lucinda Grove on 07/06/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)

05/04/2006 4077 NOTICE by Plaintiff Shirley Williams of taking deposition of Ken Winterman on 07/07/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4078 NOTICE by Plaintiff Shirley Williams of taking deposition of Roger Bailey on 07/10/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4079 NOTICE by Plaintiff Shirley Williams of taking deposition of Richard Hake on 07/11/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4080 NOTICE by Plaintiff Shirley Williams of taking deposition of David Soleno on 07/12/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4081 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint "Catalyst Meeting Events Group on May 24, 2006. (Hubbard, Dirk) (Entered: 05/04/2006)
05/04/2006 4082 NOTICE by Plaintiff Shirley Williams of taking deposition of Heather Thorndike on 07/13/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4083 NOTICE by Plaintiff Shirley Williams of taking deposition of Andrea Rogers on 07/14/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4084 NOTICE by Plaintiff Shirley Williams of taking deposition of Greg Cooper on 07/17/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4085 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint "Catalyst Meeting Videographer on May 23, 2006. (Hubbard, Dirk) (Entered: 05/04/2006)
05/04/2006 4086 NOTICE by Plaintiff Shirley Williams of taking deposition of Christy Milroy on 07/18/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4087 NOTICE by Plaintiff Shirley Williams of taking deposition of Linda Pickett on 07/19/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4088 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative of Sprint "Catalyst Meeting Video Editing on May 22, 2006. (Hubbard, Dirk) (Entered: 05/04/2006)
05/04/2006 4089 NOTICE by Plaintiff Shirley Williams of taking deposition of Lloyd Van Hooser on 07/20/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4090 NOTICE by Plaintiff Shirley Williams of taking deposition of Maureen McGuire on 07/21/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/04/2006 4091 NOTICE by Plaintiff Shirley Williams of taking deposition of Bill Hanson on 07/24/06 at 9AM. (Klamann, John) (Entered: 05/04/2006)
05/05/2006 4092 NOTICE by Plaintiff Shirley Williams of taking deposition of Vickie Koch on May 15, 2006 at 10:30 AM. (Graham, Gene) (Entered: 05/05/2006)
05/05/2006 4093 MOTION to Compel Defendant to Provide Dates for James Kissinger Deposition, AND Motion for Sanctions by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A) (Hubbard, Dirk) (Two−part motion: motion title modified on 5/8/2006. (mg)) (Entered: 05/05/2006)
05/05/2006 4094 REPLY to Memorandum in Opposition re 3846 MOTION for Protective Order Regarding Limitations on All Future Deposition Discovery by Plaintiffs by Defendant Sprint/United Management Company. (Yates, John) (Document title modified on 5/8/2006. (mg)) (Entered: 05/05/2006)
05/08/2006 4095 MOTION for Protective Order Regarding Deposition of Miguel Arredondo by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Hubbard, Dirk) (Motion title modified on 5/9/2006. (mg)) (Entered: 05/08/2006)
05/08/2006 4096 MOTION for Protective Order Regarding Deposition of Dale Aston by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Hubbard, Dirk) (Motion title modified on 5/9/2006. (mg)) (Entered: 05/08/2006)

05/08/2006 4097 MOTION for Protective Order Regarding Deposition of Howard Holbrook by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Hubbard, Dirk) (Motion title modified on 5/9/2006. (mg)) (Entered: 05/08/2006)

05/08/2006 4098 MOTION for Protective Order Regarding Deposition of Paul LeMay by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Hubbard, Dirk) (Motion title modified on 5/9/2006. (mg)) (Entered: 05/08/2006)

05/08/2006 4099 MOTION for Protective Order Regarding Deposition of Michael Affolder by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Hubbard, Dirk) (Motion title modified on 5/9/2006. (mg)) (Entered: 05/08/2006)

05/08/2006 4100 MOTION for Review and Objections to Paragraph 11 Magistrate's Order of April 25, 2006 Doc. #3865 by Plaintiff Shirley Williams. (Hubbard, Dirk) (Motion title modified on 5/23/2006. (mg)) (Entered: 05/08/2006)

05/09/2006 4101 MOTION for Protective Order Regarding Deposition of Carldene Sue Green by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Hubbard, Dirk) (Duplicate text removed on 5/10/2006. (mg)) (Entered: 05/09/2006)

05/09/2006

4102

MOTION for Review and Objections to Portions of Paragraph 8 of Magistrate's Order of April 25, 2006 [Doc. #3865] by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit 1; #(2) Exhibit 2; #(3) Exhibit 3; #(4) Exhibit 4; #(5) Exhibit 5; #(6) Exhibit 6) (Hubbard, Dirk) (Duplicate text removed on 10/2006. (mg)) (Entered: 05/09/2006)

05/10/2006 4103 MOTION for attorney J. Timothy McDonald to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit) (Yates, John) (Entered: 05/10/2006)

05/10/2006 4104 MOTION for attorney Hunter R. Hughes to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit) (Yates, John) (Entered: 05/10/2006)

05/10/2006 4105 MOTION for attorney John Da Grosa Smith to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit) (Yates, John) (Entered: 05/10/2006)

05/10/2006 4106 MOTION for attorney Thomas Joseph Mew, IV to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit) (Yates, John) (Entered: 05/10/2006)

05/10/2006 4107 MOTION for Leave to file Motion for Review and Objection of Magistrate's Order Out of Time by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Meyers, Martin) (Duplicate text removed on 5/11/2006. (mg)) (Entered: 05/10/2006)

05/11/2006

PRO HAC VICE FEE PAID: on 5/11/06 re: 4103 MOTION for attorney J. Timothy McDonald to appear pro hac vice in the amount of $50.00. Receipt Number 1002782. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 05/11/2006)

05/11/2006

PRO HAC VICE FEE PAID: on 5/11/06 re: 4104 MOTION for attorney Hunter R. Hughes to appear pro hac vice in the amount of $50.00. Receipt Number 1002783. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 05/11/2006)

05/11/2006

PRO HAC VICE FEE PAID: on 5/11/06 re: 4105 MOTION for attorney John Da Grosa Smith to appear pro hac vice in the amount of $50.00. Receipt Number 1002784. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 05/11/2006)

05/11/2006

PRO HAC VICE FEE PAID: on 5/11/06 re: 4106 MOTION for attorney Thomas Joseph Mew, IV to appear pro hac vice in the amount of $50.00. Receipt Number 1002785. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 05/11/2006)

05/12/2006 4108 ORDER granting 4103 , 4104 , 4105 , and 4106 Motions to Appear Pro Hac Vice. Attorneys J. Timothy McDonald, Hunter R. Hughes, III, John Da Grosa Smith, and Thomas Joseph Mew, IV are granted leave to appear pro hac vice on behalf of

Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a CM/ECF Electronic Filing Registration Form at http://www.ksd.uscourts.gov/forms/index.php. Signed by Magistrate Judge David J. Waxse on 05/12/06. (mg) (Entered: 05/12/2006)

05/15/2006

4109

ORDER denying 3875 Plaintiffs' Motion for Leave to File Surreply. At this time, the Court does not believe additional briefing is necessary for resolution of the pending dispute between the parties. If the Court later determines additional briefing would be helpful, the Court will notify the parties and enter the appropriate order. Entered by Magistrate Judge David J. Waxse on 5/15/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 05/15/2006)

05/15/2006 4110 CERTIFICATE OF COMPLIANCE by Plaintiffs. (Egan, Dennis) (Modified on 5/16/2006. (mg)) (Entered: 05/15/2006)

05/16/2006 4111 NOTICE by Plaintiff Shirley Williams of taking deposition of Carol Bussing on May 26, 2006 at 9:30 a.m.. (Graham, Gene) (Entered: 05/16/2006)

05/16/2006 4112 MOTION for attorney Ashley R. Hurst to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit) (Yates, John) (Entered: 05/16/2006)

05/16/2006

PRO HAC VICE FEE PAID: on 5/16/06 re: 4112 MOTION for attorney Ashley R. Hurst to appear pro hac vice in the amount of $50.00. Receipt Number 1002863. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 05/16/2006)

05/17/2006

4113

ORDER granting 4112 Motion to Appear Pro Hac Vice. Ashley R. Hurst is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a CM/ECF Electronic Filing Registration Form at http://www.ksd.uscourts.gov/forms/index.php. Signed by Magistrate Judge David J. Waxse on 05/17/06. (mg) (Entered: 05/17/2006)

05/18/2006 4114 NOTICE by Plaintiff Shirley Williams of taking deposition of one or more agents of Sprint who consent to testify on its behalf as to the matters set forth on the attached Exhibit A on 05/26/06. (Attachments: #(1) Exhibit A)(Meyers, Martin) (Duplicate text removed on 5/19/2006. (mg)) (Entered: 05/18/2006)

05/18/2006 4115 Minute Entry for Discovery/Status Conference held on 5/18/2006 before Magistrate Judge David J. Waxse. A telephone Status Conference is set for 5/25/2006 at 02:00 PM before Magistrate Judge David J. Waxse. The parties shall initiate the 2:00 PM conference call. (byk) (Entered: 05/18/2006)

05/18/2006

4116

ORDER memorializing rulings from 5/18/2006 Discovery/Status Conference. Defendant's Motion for Protective Order Regarding Limitations on All Future Deposition Discovery by Plaintiffs 3846 is denied without prejudice to refiling after the special master is appointed. Plaintiffs' Motion to Compel Defendant to Provide Dates 4093 is moot. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 5/18/2006. (byk) (Entered: 05/18/2006)

05/19/2006 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Graham, Gene) (Motion title modified on 5/22/2006. (mg)) (Entered: 05/19/2006)

05/19/2006 4118 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Witness re SPR−W1356353 and/or 1356326 on June 5, 2006. (Klamann, John) (Entered: 05/19/2006)

05/19/2006 4119 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Witness re SPR−W1460690 through 1460695 on May 31, 2006. (Klamann, John) (Entered: 05/19/2006)

05/19/2006 4120 NOTICE by Plaintiff Shirley Williams of taking deposition of Defendant Sprint re adverse impact processes and procedures on May 31, 2006. (Klamann, John) (Entered: 05/19/2006)

05/19/2006 4121 NOTICE by Plaintiff Shirley Williams of taking deposition of Defendant Sprint re Extraordinary Achievement Award on May 31, 2006. (Klamann, John) (Entered: 05/19/2006)

05/19/2006 4122 STIPULATION −− Joint Stipulation Regarding Suspension of Due Dates for Certain Discovery by Shirley Williams. (Hubbard, Dirk) (Entered: 05/19/2006)

05/22/2006 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A #(2) Exhibit B) (Graham, Gene) (Text modified on 5/23/2006. (mg)) (Entered: 05/22/2006)

05/22/2006 4124 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Frederic Fischer on May 22, 2006 at 1:30 p.m.. (Dupont, Philip) (Entered: 05/22/2006)

05/22/2006 4125 NOTICE by Plaintiff Shirley Williams of taking deposition of Carol Bussing on June 8, 2006 at 10:30 a.m.. (Graham, Gene) (Entered: 05/22/2006)

05/22/2006 4126 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Carol Faucher on May 24, 2006 at 1:30 p.m.. (Dupont, Philip) (Entered: 05/22/2006)

05/22/2006 4127 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Kevin Farley on May 24, 2006 at 1:30 p.m.. (Dupont, Philip) (Entered: 05/22/2006)

05/22/2006 4128 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Debra Zissis on May 25, 2006 at 9:00 a.m.. (Dupont, Philip) (Entered: 05/22/2006)

05/22/2006

4129

RESPONSE by Defendant Sprint/United Management Company re 4095 MOTION for Protective Order Regarding Deposition of Miguel Arredondo. (Attachments: #(1) Exhibit A #(2) Exhibit B #(3) Exhibit C #(4) Exhibit D #(5) Exhibit E #(6) Exhibit F #(7) Exhibit G #(8) Exhibit H)(Costello, Robert) (Duplicate text removed on 5/23/2006. (mg)) (Entered: 05/22/2006)

05/22/2006

4130

RESPONSE by Defendant Sprint/United Management Company re 4100 MOTION for Review and Objections to Paragraph 11 Magistrate's Order of April 25, 2006 Doc. #3865. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Costello, Robert) (Text modified on 5/23/2006. (mg)) (Entered: 05/22/2006)

05/22/2006 4131 RESPONSE by Defendant Sprint/United Management Company re 4098 MOTION for Protective Order Regarding Deposition of Paul LeMay. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Costello, Robert) (Entered: 05/22/2006)

05/22/2006 4132 RESPONSE by Defendant Sprint/United Management Company re 4099 MOTION for Protective Order Regarding Deposition of Michael Affolder. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Costello, Robert) (Entered: 05/22/2006)

05/22/2006 4133 RESPONSE by Defendant Sprint/United Management Company re 4097 MOTION for Protective Order Regarding Deposition of Howard Holbrook. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Costello, Robert) (Entered: 05/22/2006)

05/22/2006 4134 RESPONSE by Defendant Sprint/United Management Company re 4096 MOTION for Protective Order Regarding Deposition of Dale Aston. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Costello, Robert) (Entered: 05/22/2006)

05/22/2006 4135 RESPONSE by Defendant Sprint/United Management Company re 4101 MOTION for Protective Order Regarding Deposition of Carldene Sue Green. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Costello, Robert) (Entered: 05/22/2006)

05/22/2006 4136 CERTIFICATE OF SERVICE of Defendant's Responses and Objections to Plaintiffs' Eleventh and Twelfth Sets of Discovery by Sprint/United Management Company. (Yates, John) (Entered: 05/22/2006)

05/23/2006 4137 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4102 MOTION for Review and Objections to Portions of Paragraph 8 of Magistrate's Order of April 25, 2006 [Doc. # 3865]. (Yates, John) (Entered: 05/23/2006)

05/25/2006 4138 ENTRY OF APPEARANCE by Patrick M. Gavin on behalf of Sprint/United Management Company. (Gavin, Patrick) (Entered: 05/25/2006)

05/25/2006 4139 Minute Entry for Telephone Status Conference re: special master held on 5/25/2006 before Magistrate Judge David J. Waxse. Next Discovery/Status Conference set for 6/1/2006 at 02:00 PM before Magistrate Judge David J. Waxse. (byk) (Entered: 05/25/2006)

05/26/2006 4140 CERTIFICATE OF SERVICE of Supplemental Responses to Plaintiff's Eleventh Request for Production of Document by Sprint/United Management Company. (Yates, John) (Entered: 05/26/2006)

05/26/2006 4141 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative on AAR Surveys on June 1, 2006 at 9:00 A.M. (Hubbard, Dirk) (Entered: 05/26/2006)

05/26/2006 4142 NOTICE by Plaintiff Shirley Williams of taking deposition of James Kissinger on June 2, 2006 at 9:00 A.M. (Hubbard, Dirk) (Entered: 05/26/2006)

05/26/2006

4143

MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317 by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I) (Costello, Robert) (Entered: 05/26/2006)

05/26/2006 4144 CERTIFICATE OF COMPLIANCE (Affidavit of Compliance) by Defendant Sprint/United Management Company re 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317. (Costello, Robert) Modified title 5/30/2006. (kao) (Entered: 05/26/2006)

05/30/2006

4145

ORDER regarding Appointment of Special Master for discovery. Within five (5) days of the date of this Order, the parties shall file a pleading indicating whether they would be willing to consent to the appointment of John R. Phillips as special master even though his firm has represented Sprint in the matters disclosed herein. Signed by Magistrate Judge David J. Waxse on 5/30/2006.(byk) (Entered: 05/30/2006)

05/31/2006 4146 NOTICE by Plaintiff Shirley Williams of taking deposition of Gaylene VanHorn on June 9, 2006. (Egan, Dennis) (Entered: 05/31/2006)

06/01/2006 4147 MOTION to Strike 4144 Certificate of Compliance and 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317 by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 06/01/2006)

06/01/2006 4148 MOTION for Protective Order of Plaintiff Chris Monticue by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Graham, Gene) (Entered: 06/01/2006)

06/01/2006 4149 MOTION for Protective Order of Matt Borkowski by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Graham, Gene) (Entered: 06/01/2006)

06/01/2006 4150 MOTION for Protective Order of Deborah Hufnagel by Plaintiff Shirley Williams. (Attachments: #(1) Exhibit A) (Graham, Gene) (Entered: 06/01/2006)

06/01/2006 4151 MOTION for Extension of Time to File Reply as to 4095 Motion for Protective Order Regarding Deposition of Miguel Arredondo by Plaintiff Shirley Williams. (Graham, Gene) (Motion title and document association modified on 6/2/2006. (mg)) (Entered: 06/01/2006)

06/01/2006 4152 Minute Entry for Discovery/Status Conference held on 6/1/2006 before Magistrate Judge David J. Waxse. Written Order to follow. (byk) (Entered: 06/01/2006)

06/02/2006 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido, 4149 MOTION for Protective Order Matt Borkowski, 4150 MOTION for Protective Order

Deborah Hufnagel by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A# 2 Exhibit B) (Costello, Robert) (Entered: 06/02/2006)

06/02/2006 4154 RESPONSE by Defendant Sprint/United Management Company re 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Costello, Robert) (Entered: 06/02/2006)

06/02/2006 4155 RETURN OF SERVICE of subpoena(s) filed by Defendant Sprint/United Management Company executed upon Joe McKinney on May 31, 2006 by Personal Service. (Dupont, Philip) (Entered: 06/02/2006)

06/02/2006 4156 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Betty Cabello on June 8, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 06/02/2006)

06/02/2006

4157

ORDER memorializing 6/1/2006 discovery/status conference rulings. 3845 Defendant's Motion for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gaylene Van Horn Motion is found to be moot. See Order for further rulings. Signed by Magistrate Judge David J. Waxse on 6/2/2006. (byk) (Entered: 06/02/2006)

06/02/2006

4158

ORDER granting 4151 Plaintiffs' unopposed MOTION for Extension of Time to File Reply. Plaintiffs are hereby granted an extension of time, until June 19, 2006, to file their reply in support of their 4095 MOTION for Protective Order Regarding Deposition of Miguel Arredondo. Entered by Magistrate Judge David J. Waxse on 6/2/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 06/02/2006)

06/05/2006 4159 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4097 MOTION for Protective Order Regarding Deposition of Howard Holbrook. (Graham, Gene) (Entered: 06/05/2006)

06/05/2006 4160 STIPULATION −− Joint Stipulation Regarding Due Dates for Certain Discovery by Shirley Williams. (Hubbard, Dirk) (Entered: 06/05/2006)

06/05/2006

4161

RESPONSE by Defendant Sprint/United Management Company re 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Costello, Robert) (Typographical error corrected on 6/6/2006. (mg)) (Entered: 06/05/2006)

06/05/2006 4162 NOTICE of Plaintiffs' Consent to Appointment of John Phillips as Special Master by Shirley Williams. (Hubbard, Dirk) (Entered: 06/05/2006)

06/05/2006 4163 NOTICE by Plaintiff Shirley Williams of taking deposition of Jerine Newsome on July 7, 2006 at 8:00 AM. (Graham, Gene) (Entered: 06/05/2006)

06/05/2006 4164 Defendant's Consent to Appointment of John Phillips as Special Master by Defendant Sprint/United Management Company. (Yates, John) (Document title modified on 6/6/2006. (mg)) (Entered: 06/05/2006)

06/06/2006 4165 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of John St. Angelo on June 12, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4166 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint representative re Network Services RIF, Bates 190606−655 and all Exhibits on July 10, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4167 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re Candidate Selection Worksheet on June 28, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4168 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re RIF Project Managers on July 10, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4169 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint re RIF−related training on June 29, 2006. (Klamann, John) (Entered:

06/06/2006)

06/06/2006 4170 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint representative re RIF−related practices,policies and procedures on June 30, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4171 NOTICE by Plaintiff Shirley Williams of taking deposition of Representative of Sprint regarding identity of Sprint work groups which did not use Displacement Guidelines on June 26, 2006. (Klamann, John) (Entered: 06/06/2006)

06/06/2006 4172 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317. (Hubbard, Dirk) (Entered: 06/06/2006)

06/06/2006 4173 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4102 MOTION for Review and Objections to Portions of Paragraph 8 of Magistrate's Order of April 25, 2006 [Doc. # 3865]. (Hubbard, Dirk) (Entered: 06/06/2006)

06/07/2006 4174 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative re: Document #1002879−81 on July 7, 2006 at 9:00 a.m. (Hubbard, Dirk) (Entered: 06/07/2006)

06/07/2006 4175 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative re: Document #1133306−08 and #1180036−37 on July 6, 2006 at 9:00 a.m. (Hubbard, Dirk) (Entered: 06/07/2006)

06/07/2006 4176 NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative re: Document #1133761−1134365 and others on July 5, 2006 at 9:00 a.m. (Hubbard, Dirk) (Entered: 06/07/2006)

06/07/2006 4177 ORDER APPOINTING SPECIAL MASTER. John R. Phillips is hereby appointed as Special Master in this case. See Order for further details. Signed by Magistrate Judge David J. Waxse on 6/7/2006.(byk) (Entered: 06/07/2006)

06/08/2006 4178 MOTION for Protective Order by Plaintiff Kathy J. Lockaby. (Attachments: # 1 Exhibit A) (Graham, Gene) (Entered: 06/08/2006)

06/08/2006 4179 REPLY to Response to Motion by Plaintiff Eduardo S. Garrido re: 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido. (Attachments: #(1) Exhibit A)(Graham, Gene) (Entered: 06/08/2006)

06/13/2006 4180 RESPONSE by Defendant Sprint/United Management Company re 4148 MOTION for Protective Order of Plaintiff Chris Monticue. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Costello, Robert) (Entered: 06/13/2006)

06/13/2006 4181 RESPONSE by Defendant Sprint/United Management Company re 4149 MOTION for Protective Order Matt Borkowski. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Costello, Robert) (Entered: 06/13/2006)

06/13/2006 4182 RESPONSE by Defendant Sprint/United Management Company re 4150 MOTION for Protective Order Deborah Hufnagel. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Costello, Robert) (Entered: 06/13/2006)

06/15/2006 4183 STIPULATION −− Parties Joint Stipulatoin Regarding Due Dates for Certain Discovery by Shirley Williams. (Hubbard, Dirk) (Entered: 06/15/2006)

06/15/2006

4184

RESPONSE by Defendant Sprint/United Management Company re 4147 MOTION to Strike 4144 Certificate of Compliance, 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Costello, Robert) (Entered: 06/15/2006)

06/15/2006 4185 REPLY to Response to Motion by Plaintiff Michael Kochevar re: 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar. (Attachments: # 1 Exhibit A − Kochevar Declaration# 2 Exhibit B− Video Conferencing)(Graham, Gene) (Entered: 06/15/2006)

06/15/2006 4186 CERTIFICATE OF COMPLIANCE by Defendant Sprint/United Management Company , with June 1, 2006 Court Order. (Dupont, Philip) (Entered: 06/15/2006)

06/16/2006 4187 REPLY to Response to Motion by Plaintiff Aiguel Arredondo, Jr. re: 4095 MOTION for Protective Order Regarding Deposition of Miguel Arredondo. (Attachments: #(1) Exhibit A− Arredondo Declaration; #(2) Exhibit B− Arredondo B; #(3) Exhibit C − Videoconferencing)(Graham, Gene) (Entered: 06/16/2006)

06/16/2006

4188

MOTION for Extension of Time to File response as to 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 06/16/2006)

06/19/2006 4189 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Witness re SPR−W1460690 − 1460695 on August 2, 2006 at 9:00 AM. (Klamann, John) (Entered: 06/19/2006)

06/19/2006 4190 NOTICE by Plaintiff Shirley Williams of taking deposition of Debra Simpson on June 22, 2006 at 10:00 AM. (Graham, Gene) (Entered: 06/19/2006)

06/19/2006 4191 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Authorized Representative re the identity of each RIF Project Manager, etc. on August 1, 2006 at 9:30 AM. (Klamann, John) (Entered: 06/19/2006)

06/19/2006 4192 NOTICE by Plaintiff Shirley Williams of taking deposition of Ken Obercrom on August 3, 2006 at 9:00 AM. (Klamann, John) (Entered: 06/19/2006)

06/19/2006

4193

ORDER granting 4107 Motion for Leave to File one day out of time their motion for review and objections to the magistrate's order compelling plaintiffs to answer interrogatories about individual issues at the pattern and practice state of this litigation. Plaintiffs shall file the motion for review that is attached as Exhibit A totheir motion no later than Wednesday, June 21, 2006. Signed by Judge John W. Lungstrum on 06/19/2006. (ses) (Entered: 06/19/2006)

06/19/2006

4194

ORDER REFERRING MOTION TO SPECIAL MASTER. In accordance with the Court's June 7, 2006 Order Appointing Special Master (doc. 4177), Plaintiffs' 4188 MOTION for Extension of Time to File response as to 4153 MOTION to Strike, 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order Regarding Depositon of Eduardo Garrido is hereby referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 6/19/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 06/19/2006)

06/19/2006

4195

ORDER REFERRING MOTION TO SPECIAL MASTER. In accordance with the Court's June 7, 2006 Order Appointing Special Master (doc. 4177), Plaintiffs' 4178 MOTION for Protective Order Regarding Deposition of Kathy Lockaby is hereby referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 6/19/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 06/19/2006)

06/19/2006 4196 MOTION for Review and Objections to Memorandum and Order Compelling Plaintiffs to Respond to Discovery Requests Regarding Individual Issues by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 06/19/2006)

06/20/2006 4197 STIPULATION (Parties Joint Stipulation Regarding Due Dates for Certain Discovery) by Shirley Williams. (Hubbard, Dirk) (Entered: 06/20/2006)

06/20/2006 4198 MOTION for Extension of Time to File Reply as to 4172 Memorandum in Opposition to 4143 Motion for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317 by Defendant Sprint/United Management Company. (Costello, Robert) (Entered: 06/20/2006)

06/21/2006 4199 NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Betts on June 30, 2006. (Egan, Dennis) (Entered: 06/21/2006)

06/22/2006 4200 NOTICE by Plaintiff Shirley Williams of taking deposition of Tammy Edwards on July 31, 2006. (Klamann, John) (Entered: 06/22/2006)

06/22/2006 4201 RESPONSE by Defendant Sprint/United Management Company re 4178 MOTION for Protective Order Regarding Deposition of Kathy Lockaby. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Costello, Robert) (Modified on 6/23/2006. (mg)) (Entered: 06/22/2006)

06/22/2006

4202

MOTION for Extension of Time to File Reply as to 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4149 MOTION for Protective Order of Matt Borkowski, 4150 MOTION for Protective Order of Deborah Hufnagel by Plaintiffs Matthew J. Borkowski, Christine Evelyn Monticue, Deborah M. Hufnagel. (Blakely, Deborah) (Entered: 06/22/2006)

06/23/2006 4203 NOTICE OF SERVICE by Shirley Williams of Plaintiffs' Thirteenth Supplemental Voluntary Disclosures. (Hubbard, Dirk) (Entered: 06/23/2006)

06/27/2006 4204 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317. (Costello, Robert) (Entered: 06/27/2006)

06/27/2006 4205 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Betts on August 10, 2006. (Egan, Dennis) (Entered: 06/27/2006)

06/27/2006

4206

ORDER REFERRING MOTIONS TO SPECIAL MASTER. In accordance with the Court's June 7, 2006 Order Appointing Special Master (doc. 4177), Defendant's 4198 MOTION for Extension of Time to File Reply in support of Defendant's Motion for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317 (doc. 4143) and Plaintiffs' 4202 MOTION for Extension of Time to File Reply in Support of Plaintiffs' Motions for Protective Order (docs. 4149, 4150, 4153 & 4178) are hereby referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 6/27/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 06/27/2006)

06/28/2006 4207 MOTION for Protective Order by Plaintiff Carol Morahan. (Attachments: #(1) Exhibit A − Morahan Declaration) (Graham, Gene) (Entered: 06/28/2006)

06/29/2006 4208 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Ronnie Cashwell on July 10, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 06/29/2006)

06/29/2006 4209 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Carolyn Hawkins on July 12, 2006 at 1:30 p.m. (Dupont, Philip) (Entered: 06/29/2006)

06/29/2006

4210

Second MOTION for Extension of Time to File response as to 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido by Plaintiff Shirley Williams (Hubbard, Dirk) (Entered: 06/29/2006)

06/30/2006 4211 MEMORANDUM AND ORDER denying 4100 Motion for Review and objections to the magistrate judge's April 25, 2006 order. Signed by Judge John W. Lungstrum on 06/30/2006. (ses) (Entered: 06/30/2006)

06/30/2006

4212

MEMORANDUM AND ORDER taking under advisement 4102 Motion for Review and objections to paragraph 8 of the magistrate judge's April 25, 2006 order. This matter is remanded to the magistrate judge as set forth in this order. Upon the magistrate judge's filing the additional factual findings referred to in this order, plaintiffs shall have 10 days from the date thereof to supplement their brief with specific reference to the magistrate judge's findings and defendant shall have 10 days thereafter to file a supplemental brief in response.. Signed by Judge John W. Lungstrum on 06/30/2006. (ses, ) (Entered: 06/30/2006)

07/01/2006

4213

MEMORANDUM AND ORDER granting in part and denying in part 3542 Plaintiffs' Motion for Relief with Regard to Documents Inadvertently Disclosed by Defendant and Claimed to be Privileged; Plaintiffs shall return the inadvertently disclosed documents at issue, and all copies thereof, within five (5) days from the date of this Memorandum and Order. See Memorandum and Order for further details. Signed by Magistrate Judge David J. Waxse on 07/01/2006 (mts). (Entered: 07/01/2006)

07/03/2006 4214 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4196 MOTION for Review and Objections to Memorandum and Order Compelling Plaintiffs to Respond to Discovery Requests Regarding Individual Issues. (Yates, John) (Entered: 07/03/2006)

07/05/2006 4215 STIPULATION: Parties' Joint Stipulation Regarding Due Dates For Certain Discovery by Shirley Williams. (Hubbard, Dirk) (Entered: 07/05/2006)

07/06/2006 4216 MOTION to Stay regarding 4213 Order on Motion for In Camera Inspection, by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 07/06/2006)

07/07/2006 4217 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4216 MOTION to Stay regarding 4213 Order on Motion for In Camera Inspection. (Dupont, Philip) (Entered: 07/07/2006)

07/10/2006

4218

ORDER granting 4216 Plaintiffs' Motion to Stay Court's July 1, 2006 Order Pending a Motion for Reconsideration or an Objection to be Filed. To preserve the status quo, the provisions of the Court's July 1, 2006 Memorandum and Order (doc. 4213) ordering Plaintiffs to return the inadvertently disclosed adverse impact/due diligence documents, and all copies thereof, within five (5) days from the date of the Memorandum and Order is hereby stayed until further order of the Court. Entered by Magistrate Judge David J. Waxse on 7/10/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 07/10/2006)

07/10/2006 4219 REPLY to Response to Motion by Plaintiff Deborah M. Hufnagel re: 4150 MOTION for Protective Order of Deborah Hufnagel. (Blakely, Deborah) (Document association modified and text removed on 7/11/2006. (mg)) (Entered: 07/10/2006)

07/10/2006 4220 REPLY in Support of 4148 MOTION for Protective Order of Plaintiff Chris Monticue by Plaintiffs. (Blakely, Deborah) (Document title modified and text removed on 7/11/2006. (mg)) (Entered: 07/10/2006)

07/10/2006

4221

ORDER re 4212 Memorandum and Order on Motion for Review. Factual findings re 3580 Plaintiffs' Motion to Compel Discovery. Signed by Magistrate Judge David J. Waxse on 7/10/2006. (Attachments: #(1) Exhibit Transcript of 4−20−2006 Discovery Conference; #(2) Exhibit Transcript of 4−20−2006 Discovery Conference, pages 41−59)(byk) (Exhibit #2 added on 7/10/2006. (mg)) (Entered: 07/10/2006)

07/10/2006

4222

NOTICE TO COUNSEL OF DOCUMENT ATTACHMENT by Deputy Clerk regarding 4221 Order. A second exhibit of the Transcript of 4−20−2006 Discovery Conference, pages 41−59, has been attached to that docket entry, and is also attached to this notice for the purpose of electronic notification. Contact the Clerk's Office with any questions. (mg) (Entered: 07/10/2006)

07/10/2006

4225

REPORT TO THE COURT by John R. Phillips, Special Master. (Attachments: #(1) Proposed Third Amended, Second−Phase Scheduling Order) Any motion for review or objections to the Special Master's Report to the Court and proposed Third Amended, Second−Phase Scheduling Order shall be filed within ten (10) days of the date of this filing. (Entered: 07/11/2006)

07/11/2006 4223 REPLY to Response to 4149 MOTION for Protective Order of Matt Borkowski by Plaintiff Matthew J. Borkowski. (Attachments: # 1 Exhibit A− Declaration# 2 Exhibit B− Videoconferencing)(Blakely, Deborah) (Document title modified on 7/12/2006. (mg)) (Entered: 07/11/2006)

07/11/2006 4224 REPLY to Response to 4178 MOTION for Protective Order of Kathy J. Lockaby by Plaintiff Kathy J. Lockaby. (Attachments: # 1 Exhibit A − Declaration# 2 Exhibit B− Videoconferencing)(Blakely, Deborah) (Document title modified on 7/12/2006. (mg)) (Entered: 07/11/2006)

07/12/2006 4226 RESPONSE by Defendant Sprint/United Management Company re 4207 MOTION for Protective Order Regarding Deposition of Carol Morahan. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Costello, Robert) (Entered: 07/12/2006)

07/13/2006 4227 NOTICE OF SERVICE by Sprint/United Management Company of Sprint's Responses to Plaintiffs' Requests for Admissions. (Yates, John) (Entered: 07/13/2006)

07/13/2006 4228 NOTICE OF SERVICE by Shirley Williams of Plaintiffs' Responses and Objections to Defendant's Second Request for Admissions to Plaintiff. (Hubbard, Dirk) (Entered: 07/13/2006)

07/13/2006 4229 CERTIFICATE OF SERVICE of Sprint's Answers and Objections to Plaintiffs' Tenth Interrogatories by Sprint/United Management Company. (Yates, John) (Entered: 07/13/2006)

07/13/2006 4230 NOTICE OF SERVICE by Shirley Williams of Plaintiffs' Supplemental Responses and Objections to Defendant's Fourth Set of Interrogatories Directed to Plaintiffs. (Meyers, Martin) (Entered: 07/13/2006)

07/17/2006 4231 MOTION for Leave to file Under Seal Plaintiff's Motion for Reconsideration of July 1, 2006, Order (Doc #4213) and, in the Alternative, for Clarification; Motion for Stay; and Memorandum in Support by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 07/17/2006)

07/17/2006

4232

REPLY to Response to Motion by Plaintiff Shirley Williams re: 4196 MOTION for Review and Objections to Memorandum and Order Compelling Plaintiffs to Respond to Discovery Requests Regarding Individual Issues. (Attachments: #(1) Exhibit A)(DeFrain, Brian) (Duplicate text removed on 7/18/2006. (mg)) (Entered: 07/17/2006)

07/18/2006

4233

ORDER granting 4231 Plaintiffs' Motion for Leave to File Under Seal Plaintiffs' Motion for Reconsideration of July 1, 2006 Order. Plaintiffs are hereby granted leave to file their Motion for Reconsideration of the Court's July 1, 2006 (doc. 4213) Order under seal. Entered by Magistrate Judge David J. Waxse on 7/18/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 07/18/2006)

07/18/2006 4234 SEALED MOTION for Reconsideration of July 1, 2006, Order 4213 and, in the Alternative, for Clarification; Motion for Stay; and Memorandum in Support by Plaintiff Shirley Williams. (mg) (hw). (Entered: 07/18/2006)

07/24/2006 4235 MOTION for Reconsideration of July 10, 2006 Order (Doc. #4221) and In The Alternative, For Clarification by Plaintiff Shirley Williams. (Egan, Dennis) (Motion title modified on 7/26/2006. (mg)) (Entered: 07/24/2006)

07/24/2006 4236 MOTION for Rule 16 Conference by Defendant Sprint/United Management Company. (Yates, John) (Motion title modified on 7/26/2006. (mg)) (Entered: 07/24/2006)

07/24/2006

4237

MOTION for Review of Special Master's Recommendations Regarding Discovery Limits by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A − excerpts from meet and confer transcript# 2 Exhibit B − excerpts from status hearing transcript# 3 Exhibit C − excerpts from Special Master conference transcript) (Yates, John) (Entered: 07/24/2006)

07/24/2006 4238 MOTION for hearing regarding scheduling order by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 07/24/2006)

07/25/2006 4239 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dale Aston on July 31, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 07/25/2006)

07/25/2006 4240 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Carolyn Adams−Hawkins on August 2, 2006 at 1:30 PM. (Dupont, Philip) (Entered: 07/25/2006)

07/26/2006 4241 MOTION for Order Granting Leave to Depose Plaintiff Toby Young in Prison by Defendant Sprint/United Management Company (Costello, Robert) (Entered: 07/26/2006)

07/26/2006 4242 MEMORANDUM IN SUPPORT of 4241 MOTION for Order Granting Leave to Depose Plaintiff Toby Young in Prison by Defendant Sprint/United Management Company (Attachments: # 1 Exhibit A# 2 Exhibit B)(Costello, Robert) (Entered: 07/26/2006)

07/26/2006 4243 REPLY to Response to Motion by Plaintiff Carol Morahan re: 4207 MOTION for Protective Order (Attachments: # 1 Exhibit A − Video Conferencing)(Blakely,

Deborah) (Entered: 07/26/2006)

07/27/2006

4244

MOTION to Compel Defendant to Produce Attachments to E−Mails by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit Index# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8# 10 Exhibit 9# 11 Exhibit 10# 12 Exhibit 11# 13 Exhibit 12# 14 Exhibit 13# 15 Exhibit 14# 16 Exhibit 15# 17 Exhibit 16# 18 Exhibit 17# 19 Exhibit 18# 20 Exhibit 19# 21 Exhibit 20# 22 Exhibit 21# 23 Exhibit 22# 24 Exhibit 23# 25 Exhibit 24# 26 Exhibit 25# 27 Exhibit 26# 28 Exhibit 27# 29 Exhibit 28# 30 Exhibit 29# 31 Exhibit 30# 32 Exhibit 31# 33 Exhibit 32# 34 Exhibit 33# 35 Exhibit 34# 36 Exhibit 35# 37 Exhibit 36# 38 Exhibit 37# 39 Exhibit 38# 40 Exhibit 39# 41 Exhibit 40# 42 Exhibit 41# 43 Exhibit 42# 44 Exhibit 43# 45 Exhibit 44# 46 Exhibit 45# 47 Exhibit 46# 48 Exhibit 47# 49 Exhibit 48# 50 Exhibit 49# 51 Exhibit 50# 52 Exhibit 51# 53 Exhibit 52# 54 Exhibit 53# 55 Exhibit 54# 56 Exhibit 55# 57 Exhibit 56# 58 Exhibit 57# 59 Exhibit 58# 60 Exhibit 59# 61 Exhibit 60# 62 Exhibit 61# 63 Exhibit 62# 64 Exhibit 63) (Hubbard, Dirk) (Motion title modified on 8/8/2006. (mg)) (Entered: 07/27/2006)

07/28/2006 4245 MOTION to Compel Defendant to Produce Transmittal E−Mails in Native Format by Plaintiff Shirley Williams. (Hubbard, Dirk) (Modified on 8/1/2006. (mg)) (Entered: 07/28/2006)

07/28/2006

4246

MOTION to Compel Documents with Original Bates Numbers by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit Index# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8# 10 Exhibit 9# 11 Exhibit 10# 12 Exhibit 11# 13 Exhibit 12# 14 Exhibit 13# 15 Exhibit 14# 16 Exhibit 15# 17 Exhibit 16# 18 Exhibit 17) (Hubbard, Dirk) (Modified on 8/1/2006. (mg)) (Entered: 07/28/2006)

07/31/2006

4247

SUPPLEMENTAL BRIEF regarding 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involvedby Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9)(Hubbard, Dirk) (Document title modified on 8/1/2006. (mg)) (Entered: 07/31/2006)

07/31/2006 4248 SEALED MEMORANDUM in Opposition by Defendant Sprint/United Management Company regarding 4234 SEALEDMOTION for Reconsideration of July 1, 2006 Order Regarding Adverse Impact Documents. (mg) (hw). (Entered: 08/01/2006)

08/01/2006 4249 CERTIFICATE OF SERVICE of Final Phase II Supplemental Rule 26(a)(1) Disclosures by Sprint/United Management Company. (Gavin, Patrick) (Entered: 08/01/2006)

08/01/2006 4250 MOTION to Compel Resumption of Deposition of James Kissinger by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 08/01/2006)

08/02/2006

4251

MOTION to Compel Defendant to Produce Document #1000194203 Without Redactions by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G − FILED UNDER SEAL# 8 Exhibit H) (Hubbard, Dirk) (Motion title modified on 8/3/2006. (mg)) (Entered: 08/02/2006)

08/03/2006 4252 SEALED EXHIBIT G IN SUPPORT of 4251 MOTION to Compel Defendant to Produce Document #1000194203 Without Redactions by Plaintiff Shirley Williams. (mg) (hw). (Entered: 08/03/2006)

08/03/2006 4253 NOTICE by Plaintiff Shirley Williams of taking deposition of Gene Betts on September 7, 2006. (Egan, Dennis) (Entered: 08/03/2006)

08/03/2006 4254 CERTIFICATE OF SERVICE of Third Request for Admissisons, Fifth Request for Production of Documents and Fifth Set of Interrogatories to Plaintiff by Sprint/United Management Company. (Gavin, Patrick) (Entered: 08/03/2006)

08/04/2006 4255 MEMORANDUM AND ORDER granting 4196 Motion for Review. Plaintiff's objection to the magistrate judge's 03/21/06 order compelling plaintiffs to respond to defendant's Fourth Interrogatory No. 2 is sustained. Signed by Judge John W. Lungstrum on 08/03/06. (mg) (Entered: 08/04/2006)

08/04/2006

4256

ORDER regarding 4102 Motion for Review and Objections to Paragraph 8 of the Magistrate Judge's 04/25/06 Order: Plaintiffs shall have ten (10) days from the date the magistrate judge issues an order resolving 4235 Motion for Reconsideration, to file a supplemental brief. Defendant shall have ten (10) days thereafter to file a supplemental brief in response. Signed by Judge John W. Lungstrum on 08/03/06. (mg) (Entered: 08/04/2006)

08/07/2006

4257

ORDER regarding 4225 Proposed Third Amended Second−Phase Scheduling Order by Special Master: an informal conference to discuss scheduling matters is set for Saturday, 8/19/2006 at 10:00 AM before Chief Judge John W. Lungstrum. See this order for detailed information regarding this matter. Signed by Judge John W. Lungstrum on 08/04/06. (mg) (Entered: 08/07/2006)

08/07/2006 4258 RESPONSE by Plaintiff Shirley Williams re 4241 MOTION for Order Granting Leave to Depose Plaintiff Toby Young in Prison. (Braud, Bert) (Entered: 08/07/2006)

08/07/2006

4259

RESPONSE to Defendant's Objections to Special Master's Scheduling Order Recommendations by Plaintiff Shirley Williams re 4237 MOTION for Review of Special Master's Recommendations Regarding Discovery Limits. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13# 14 Exhibit 14# 15 Exhibit 15# 16 Exhibit 16# 17 Exhibit 17# 18 Exhibit 18)(Hubbard, Dirk) (Document title modified on 8/8/2006. (mg)) (Entered: 08/07/2006)

08/07/2006 4260 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4235 MOTION for Reconsideration of July 10, 2006 Order (Doc. #4221) and In The Alternative, For Clarification. (Yates, John) (Entered: 08/07/2006)

08/07/2006 4261 RESPONSE (Oppostion) by Defendant Sprint/United Management Company re 4238 MOTION hearing regarding scheduling order. (Yates, John) (Document title modified on 8/8/2006. (mg)) (Entered: 08/07/2006)

08/07/2006 4262 Consent MOTION for Extension of Time to File Response as to 4244 MOTION to Compel Defendant to Produce Attachments to E−Mails by Defendant Sprint/United Management Company. (Yates, John) (Docket text modified on 8/8/2006. (mg)) (Entered: 08/07/2006)

08/09/2006 4263 MOTION for Extension of Time to File Reply as to 4234 SEALED MOTION for Reconsideration re 4213 Order on Motion for In Camera Inspection, by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 08/09/2006)

08/11/2006 4264 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4245 MOTION to Compel Defendant to Produce Transmittal E−Mails in Native Format. (Yates, John) (Motion title modified on 8/15/2006. (mg)) (Entered: 08/11/2006)

08/11/2006 4265 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4246 MOTION to Compel Documents with Original Bates Numbers. (Attachments: #(1) Exhibit A − April 27, 2006 letter)(Yates, John) (Modified on 8/16/2006. (mg)) (Entered: 08/11/2006)

08/14/2006

4266

MOTION for extension of time to File Motion to Compel Concerning Plaintiffs' Tenth Interrogatories and Eleventh Request for Production of Documents by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E) (Braud, Bert) (Motion title modified on 8/16/2006. (mg)) (Entered: 08/14/2006)

08/14/2006

4267

RESPONSE by Defendant Sprint/United Management Company to Plaintiffs' Supplemental Brief in Support 4247 regarding Plaintiffs' 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved. Attachments: # 1 Exhibit A − excerpts from June 22, 2006 transcript# 2 Exhibit B − excerpts from May 25, 2006 transcript)(Yates, John) (Document title modified on 8/16/2006. (mg)) (Entered: 08/14/2006)

08/15/2006 4268 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4250 MOTION to Compel Resumption of Deposition of James Kissinger. (Attachments: # 1 Exhibit Index# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit

D# 6 Exhibit E# 7 Exhibit F# 8 Exhibit G# 9 Exhibit H# 10 Exhibit I)(Costello, Robert) (Entered: 08/15/2006)

08/16/2006 4269 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4251 MOTION to Compel Defendant to Produce Document #1000194203 Without Redactions. (Yates, John) (Entered: 08/16/2006)

08/17/2006

4270

NOTICE of Hearing on Motions: 4238 MOTION for hearing regarding scheduling order, 4237 MOTION for Review of Special Master's Recommendations Regarding Discovery Limits, and 4236 MOTION for Rule 16 Conference: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Motion Hearing set for 8/24/2006 at 02:00 PM before Chief Judge John W. Lungstrum in courtroom #427. (ses) (Entered: 08/17/2006)

08/17/2006

4271

ORDER granting 4262 Defendant Sprint's Consent MOTION for an Extension of Time to File Response as to 4244 MOTION to Compel Defendant to Produce Attachments to E−Mails. Defendant is hereby granted an extension of time, until 8/21/2006, within which to respond to Plaintiffs' Motion to Compel Defendant to Produce Attachments to E−mails. Entered by Magistrate Judge David J. Waxse on 8/17/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/17/2006)

08/17/2006

4272

ORDER granting 4263 Plaintiffs' Motion for Extension of Time to File Reply re 4234 SEALED MOTION for Reconsideration re 4213 Order on Motion for In Camera Inspection. Plaintiffs shall have up to and including August 21, 2006 to file such reply brief. Entered by Magistrate Judge David J. Waxse on 8/17/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/17/2006)

08/18/2006 4273 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Christine Monticue on August 26, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 08/18/2006)

08/18/2006 4274 MOTION for Reconsideration/Clarification of 4255 Memorandum and Order on Motion for Review by Defendant Sprint/United Management Company. (Yates, John) (Motion title modified on 8/21/2006. (mg)) (Entered: 08/18/2006)

08/18/2006

4275

MEMORANDUM IN SUPPORT of 4274 MOTION for Reconsideration/Clarification of 4255 Memorandum and Order on Motion for Review by Defendant Sprint/United Management Company. (Attachments: #(1) Part 1 − pages 1 thru 30; #(2) Part 2 − pages 31 thru 61; #(3) Part 3 − pages 62 thru 96)(Yates, John) (Motion title modified on 8/21/2006. (mg)) (Entered: 08/18/2006)

08/19/2006 4284 Minute Entry for proceedings held before Judge John W. Lungstrum: Status Conference held on 8/19/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 08/24/2006)

08/21/2006 4276 ORDER summarily denied in part and retaining under advisement in part the 4274 Motion for Reconsideration re 4255 Order on Motion for Review. Signed by Judge John W. Lungstrum on 08/21/2006. (ses) (Entered: 08/21/2006)

08/21/2006 4277 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Robert McIlrath on August 29, 2006 at 9:00 AM. (Dupont, Philip) (Entered: 08/21/2006)

08/21/2006 4278 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4241 MOTION for Order Granting Leave to Depose Plaintiff Toby Young in Prison. (Attachments: # 1 Exhibit C# 2 Exhibit D# 3 Exhibit E# 4 Exhibit F# 5 Exhibit G)(Costello, Robert) (Entered: 08/21/2006)

08/21/2006 4279 Unopposed MOTION for Extension of Time to File Response as to 4244 MOTION to Compel Defendant to Produce Attachments to E−Mails by Defendant Sprint/United Management Company. (Yates, John) (Entered: 08/21/2006)

08/21/2006 4280 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4235 MOTION for Reconsideration of July 10, 2006 Order (Doc. #4221) and In The Alternative, For Clarification. (Hubbard, Dirk) (Duplicate text removed on 8/22/2006. (mg)) (Entered: 08/21/2006)

08/21/2006

4281

ORDER granting 4279 Defendant Sprint's Consent MOTION for a Three (3) Day Extension of Time to File Response as to 4244 MOTION to Compel Defendant to Produce Attachments to E−Mails. Defendant is hereby granted an extension of time, until 8/24/2006, within which to respond to Plaintiffs' Motion to Compel Defendant to Produce Attachments to E−mails. Entered by Magistrate Judge David J. Waxse on 8/21/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/21/2006)

08/21/2006 4282 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4234 SEALED MOTION for Reconsideration re 4213 Order on Motion for In Camera Inspection. (Meyers, Martin) (Entered: 08/21/2006)

08/23/2006

4283

ORDER APPROVING SPECIAL MASTER FEES. The Special Master's July 31, 2006 Invoice in the amount of $11,772.50 is approved as reasonable and appropriate. Payment apportioned as follows: $5,886.25 to be paid by Plaintiffs and $5,886.25 to be paid by Defendant. The parties shall tender payment to the Special Master by 9/13/2006. Signed by Magistrate Judge David J. Waxse on 8/23/2006. (byk) (Entered: 08/23/2006)

08/24/2006

4285

Minute Entry for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 8/24/2006 re 4238 MOTION for hearing regarding scheduling order filed by Shirley Williams, 4237 MOTION for Review of Special Master's Recommendations Regarding Discovery Limits filed by Sprint/United Management Company, 4236 MOTION for Rule 16 Conference filed by Sprint/United Management Company. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 08/24/2006)

08/24/2006 4286 RESPONSE by Defendant Sprint/United Management Company re 4244 MOTION to Compel Defendant to Produce Attachments to E−Mails. (Attachments: #(1) Exhibit A − excerpts from January 13, 2006 transcript)(Yates, John) (Entered: 08/24/2006)

08/24/2006 4287 EXHIBIT(S) IN SUPPORT of 4286 Response to Motion − Exhibit A−1 by Defendant Sprint/United Management Company. (Yates, John) (Entered: 08/24/2006)

08/24/2006 4288 RESPONSE by Defendant Sprint/United Management Company re 4266 MOTION for extension of time to File Motion to Compel Concerning Plaintiffs' Tenth Interrogatories and Eleventh Request for Production of Documents. (Yates, John) (Entered: 08/24/2006)

08/25/2006 4289 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4246 MOTION to Compel Documents with Original Bates Numbers. (Hubbard, Dirk) (Modified on 8/28/2006. (mg)) (Entered: 08/25/2006)

08/25/2006 4290 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4245 MOTION to Compel Defendant to Produce Transmittal E−Mails in Native Format. (Attachments: #(1) Exhibit 1)(Hubbard, Dirk) (Modified on 8/28/2006. (mg)) (Entered: 08/25/2006)

08/25/2006

4291

ORDER re 4285 Motion Hearing held on 08/24/2006: granting 4236 Motion for Hearing, granting in part and denying in part 4237 Motion for Review, granting in part and denying in part 4238 Motion, denying 4274 Motion for Reconsideration, and remanding in part to Magistrate Judge David J. Waxse 4177 Order Appointing Special Master for clarification. SEE ORDER FOR FURTHER DEADLINE INFORMATION Signed by Judge John W. Lungstrum on 08/25/2006. (ses) (Additional text added on 8/25/2006. (mg)) (Entered: 08/25/2006)

08/25/2006 4292 THIRD AMENDED SECOND−PHASE SCHEDULING ORDER: See order for all deadlines. Signed by Judge John W. Lungstrum on 08/25/2006.(ses) (Entered: 08/25/2006)

08/28/2006

4293

ORDER REFERRING MOTION TO SPECIAL MASTER. In accordance with the Court's June 7, 2006 Order Appointing Special Master (doc. 4177), Plaintiffs' 4250 MOTION to Compel Resumption of Deposition of James Kissinger, is hereby referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 8/28/2006.(jm) (Entered: 08/28/2006)

08/28/2006 4294 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved. (Hubbard, Dirk) (Entered: 08/28/2006)

08/28/2006 4295 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4250 MOTION to Compel Resumption of Deposition of James Kissinger. (Hubbard, Dirk) (Entered: 08/28/2006)

08/29/2006

4296

ORDER granting 4266 Plaintiffs' MOTION for extension of time to File Motion to Compel Concerning Plaintiffs' Tenth Interrogatories and Eleventh Request for Production of Documents. Plaintiffs are hereby granted an extension of time, up to and including August 31, 2006, to file a motion to compel relating to Defendants' responses to Plaintiff's Tenth Interrogatories and Eleventh Request for Production of Documents. Entered by Magistrate Judge David J. Waxse on 8/29/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/29/2006)

08/30/2006 4297 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4251 MOTION to Compel Defendant to Produce Document #1000194203 Without Redactions. (Hubbard, Dirk) (Entered: 08/30/2006)

08/30/2006 4298 AMENDED ORDER APPOINTING SPECIAL MASTER ORDER. Signed by Magistrate Judge David J. Waxse on 8/30/2006.(byk) (Entered: 08/30/2006)

08/30/2006

4299

ORDER REFERRING MOTIONS TO SPECIAL MASTER. In accordance with the Court's August 30, 2006 Amended Order Appointing Special Master (doc. 4298), Plaintiffs' Motion for Protective Order Regarding Deposition of Carol Morahan (doc. 4207) and Plaintiffs' Second Motion to Extend Time to Respond to Defendant's Motion to Strike (doc. 4210) are hereby referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 8/30/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 08/30/2006)

08/31/2006 4300 MOTION to Compel Responses to Plaintiffs' 10th Interrogatories and Eleventh Request for Production of Documents by Plaintiff Shirley Williams. (Braud, Bert) (Entered: 08/31/2006)

08/31/2006 4301 MEMORANDUM IN SUPPORT of 4300 MOTION to Compel Responses to Plaintiffs' 10th Interrogatories and Eleventh Request for Production of Documents by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Braud, Bert) (Entered: 08/31/2006)

08/31/2006 4302 AFFIDAVIT of Bert S. Braud re 4300 MOTION to Compel Responses to Plaintiffs' 10th Interrogatories and Eleventh Request for Production of Documents by Plaintiff Shirley Williams. (Braud, Bert) (Entered: 08/31/2006)

08/31/2006

4303

REPORT OF THE SPECIAL MASTER (Dated August 31, 2006) regarding 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido, 4250 MOTION to Compel Resumption of Deposition of James Kissinger, 4098 MOTION for Protective Order Regarding Deposition of Paul LeMay, 4095 MOTION for Protective Order Regarding Deposition of Miguel Arredondo, 3844 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Gavin Pinchback, 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4147 MOTION to Strike 4144 Certificate of Compliance, 4143 MOTION for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317, 4207 MOTION for Protective Order, 4099 MOTION for Protective Order Regarding Deposition of Michael Affolder, 3843 MOTION for Protective Order Regarding Plaintiffs' Deposition Notice for the Deposition of Renee Finks, 4123 MOTION for Protective Order Regarding Deposition of Eduardo Garrido, 4149 MOTION for Protective Order of Matt Borkowski, 4097 MOTION for Protective Order Regarding Deposition of Howard Holbrook, 4188 MOTION for Extension of Time to File response as to 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order, 4210 Second MOTION for Extension of Time to File response as to 4153 MOTION to Strike 4148 MOTION for Protective Order of Plaintiff Chris Monticue, 4117 MOTION for Protective Order Regarding Deposition of Michael Kochevar, 4123 MOTION for Protective Order, 4096

MOTION for Protective Order Regarding Deposition of Dale Aston, 4101 MOTION for Protective Order Regarding Deposition of Carldene Sue Green, and 4150 MOTION for Protective Order of Deborah Hufnagel. (mg) (Entered: 08/31/2006)

08/31/2006

4304

ORDER WITHDRAWING REFERRAL TO SPECIAL MASTER. In accordance with the Court's August 30, 2006 Amended Order Appointing Special Master (doc. 4298), the automatic referral to the Special Master of Plaintiffs' 4300 MOTION to Compel Reponses to Plaintiffs' 10th Interrogatories and 11th Request for Production of Documents is hereby withdrawn. Entered by Magistrate Judge David J. Waxse on 8/31/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(byk) (Entered: 08/31/2006)

08/31/2006

4305

SPECIAL MASTER ORDER denying as moot 3843 Motion for Protective Order, denying as moot 3844 Motion for Protective Order, granting 4250 Motion to Compel Resumption of Deposition of James Kissinger, and granting Plaintiffs' Oral Motion to Substitute. Signed by John R. Phillips, Special Master on 08/31/06. (mg) (Entered: 08/31/2006)

08/31/2006

4306

ORDER withdrawing the referral to the Special Master and denying without prejudice the following motions: 4095 Motion for Protective Order, 4096 Motion for Protective Order, 4097 Motion for Protective Order, 4098 Motion for Protective Order, 4099 Motion for Protective Order, 4101 Motion for Protective Order, 4117 Motion for Protective Order, 4123 Motion for Protective Order, 4148 Motion for Protective Order, 4149 Motion for Protective Order, 4150 Motion for Protective Order, 4207 Motion for Protective Order. Signed by Judge John W. Lungstrum on 08/31/2006. (ses) (Entered: 08/31/2006)

09/05/2006 4307 MOTION for attorney David L. Schenberg to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit of David L. Schenberg) (Yates, John) (Entered: 09/05/2006)

09/05/2006 4308 MOTION for extension of time To Respond To Defendant's Third Request For Admissions by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 09/05/2006)

09/06/2006

PRO HAC VICE FEE PAID: on 9/6/06 re: 4307 MOTION for attorney David L. Schenberg to appear pro hac vice in the amount of $50.00. Receipt Number 1004445. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (jb) (Entered: 09/06/2006)

09/06/2006

4309

ORDER granting 4307 Motion to Appear Pro Hac Vice. David Lawrence Schenberg is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a CM/ECF Electronic Filing Registration Form at http://www.ksd.uscourts.gov/forms/index.php. Signed by Magistrate JudgeDavid J. Waxse on 09/06/06. (mg) (Entered: 09/06/2006)

09/06/2006 4310 MOTION for attorney Gerard K. Rodriguez to appear pro hac vice by Defendant Sprint/United Management Company. (Attachments: #(1) Affidavit of Gerard K. Rodriguez) (Yates, John) (Entered: 09/06/2006)

09/06/2006

4311

SPECIAL MASTER ORDER denying as moot 4147 Motion to Strike Documents #4143 and #4144, denying as moot 4153 Motion to Strike Documents #4117, #4123, #4148, #4149, and #4153, denying as moot 4188 Motion for Extension of Time to Respond, denying as moot 4210 Second Motion for Extension of Time to Respond, and deferring ruling on 4143 Motion for Protective Order until 09/11/06. See this Special Master Order for additional information and deadlines. Signed by John R. Phillips, Special Master on 09/06/06. (mg) (Entered: 09/06/2006)

09/06/2006

PRO HAC VICE FEE PAID: On 9/6/2006 in the amount of $50.00 for attorney Gerard K. Rodriguez re: 4310 MOTION for attorney Gerard K. Rodriguez to appear pro hac vice. Receipt Number K4631004463. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (kao) (Entered: 09/06/2006)

09/07/2006 4312 ORDER granting 4310 Motion to Appear Pro Hac Vice. Gerard Karl Rodriguez is granted leave to appear pro hac vice on behalf of Sprint/United Management Company. If pro hac vice counsel has not already done so, counsel is directed to

immediately register for electronic notification pursuant to the court's Administrative Procedures by completing a CM/ECF Electronic Filing Registration Form at http://www.ksd.uscourts.gov/forms/index.php. Signed by Magistrate JudgeDavid J. Waxse on 09/07/06. (mg) (Entered: 09/07/2006)

09/12/2006 4313 SPECIAL MASTER ORDER overruling 4143 Motion for Protective Order Regarding Plaintiffs' 30(b)(6) Deposition Notice Concerning Deposition Exhibit 1317. See this order for provisions. Signed by John R. Phillips, Special Master on 09/12/06. (mg) (Entered: 09/12/2006)

09/13/2006 4314 ORDER denying 4235 Plaintiffs' Motion for Reconsideration of July 10, 2006 Order (doc. 4221). Signed by Magistrate Judge David J. Waxse on 9/13/2006. (byk) (Entered: 09/13/2006)

09/13/2006 4315 MEMORANDUM AND ORDER denying 4234 Plaintiffs' Motion for Reconsideration of July 1, 2006 Order. See Memorandum and Order for further details. Signed by Magistrate Judge David J. Waxse on 09/13/2006. (mts) (Entered: 09/13/2006)

09/14/2006 4316 SPECIAL MASTER REPORT AND RECOMMENDATION TO THE COURT (Dated September 13, 2006). (mg) (Entered: 09/14/2006)

09/14/2006

4317

SPECIAL MASTER ORDER: It is ordered that counsel for Plaintiffs and Defendant report to the Special Master and the Court by 09/20/06 with respect to their voluntary agreement for production/exchange of expert witness information preparatory to the resumption of the mediation process. Signed by John R. Phillips, Special Master on 09/13/06. (mg) (Entered: 09/14/2006)

09/15/2006 4318 Consent MOTION for extension of time To Respond To Defendant's 3rd Request for Admissions to Plaintiff by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 09/15/2006)

09/20/2006 4319 MOTION Continue stay entered 07/01/06 re 4213 Memorandum and Order on Motion for In Camera Inspection, Pending Motion for Review or Objection by Plaintiff Shirley Williams. (Meyers, Martin) (Modified on 9/21/2006. (mg)) (Entered: 09/20/2006)

09/21/2006

4320

RESPONSE by Defendant Sprint/United Management Company re 4300 MOTION to Compel Responses to Plaintiffs' 10th Interrogatories and Eleventh Request for Production of Documents. (Attachments: # 1 Exhibit A − Excerpts from 8/17/06 Transcript# 2 Exhibit B − Email to Monafo from Braud on 8/28/06# 3 Exhibit C − Excerpts from 8/24/06 Transcript)(Yates, John) (Entered: 09/21/2006)

09/22/2006 4321 MOTION for extension of time to Respond to Defendant's Third Request for Admissions to Plaintiffs by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 09/22/2006)

09/22/2006 4322 RESPONSE by Defendant Sprint/United Management Company re 4319 MOTION Continue stay entered 07/01/06 re 4213 Memorandum and Order on Motion for In Camera Inspection, Pending Motion for Review or Objection. (Dupont, Philip) (Entered: 09/22/2006)

09/25/2006 4323 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint 30(b)(1) witness on 10/6/06. (Meyers, Martin) (Entered: 09/25/2006)

09/25/2006 4324 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Former Employees on Multiple dates. (Meyers, Martin) (Entered: 09/25/2006)

09/25/2006 4325 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of Designated Representative of Sprint pursuant to Rule 30(b)(6) on multiple dates. (Meyers, Martin) (Entered: 09/25/2006)

09/25/2006

4326

MEMORANDUM AND ORDER granting in part and denying in part 3652 Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production of Documents. If it has not already done so, Defendant shall produce documents responsive to Plaintiffs' Eighth Request No. 20, and Ninth Request Nos. 10, 12−14, 16, 40, 45−59, 64−66, 41−42, and 60−63 within thirty (30) days of the date of this Memorandum and Order. (See Memorandum and Order for further details.) Signed by

Magistrate Judge David J. Waxse on 9/25/2006. (byk) (Entered: 09/25/2006)

09/25/2006 4327 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Employees on multiple dates. (Meyers, Martin) (Entered: 09/25/2006)

09/26/2006

4328

ORDER granting 4319 Plaintiffs' Motion to Continue Stay of July 1, 2006 Order Pending Motion for Review or Objection. To preserve the status quo, the stay entered July 10, 2006 is hereby continued until the Court rules on Plaintiffs' motion for review of the September 13, 2006 Memorandum and Order overruling Plaintiffs' motion for reconsideration. Pending ruling on said motion, Plaintiffs are to make no use of the documents in question. Entered by Magistrate Judge David J. Waxse on 9/26/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 09/26/2006)

09/26/2006 4329 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Former Employees on multiple dates. (Meyers, Martin) (Entered: 09/26/2006)

09/26/2006 4330 NOTICE by Plaintiff Shirley Williams of taking deposition of Sprint Employees on multiple dates. (Meyers, Martin) (Entered: 09/26/2006)

09/26/2006 4331 NOTICE by Plaintiff Shirley Williams of taking deposition of designated representatives of Sprint pursuant to 30(b)(6) on multiple dates. (Meyers, Martin) (Entered: 09/26/2006)

09/26/2006 4332 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of designated representatives of defendant Sprint pursuant to Rule 30(b)(6) on multiple dates. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Meyers, Martin) (Entered: 09/26/2006)

09/26/2006 4333 NOTICE by Plaintiff Shirley Williams of taking deposition of Chris Hubert on November 2, 2006. (Meyers, Martin) (Entered: 09/26/2006)

09/27/2006 4334 MOTION for Review and Objections to Magistrate's Orders of April 25, 2006 − Paragrah 8 (Doc #3865), July 10, 2006 (Doc #4221) and September 13, 2006 (Doc #4315) Denying Plaintiffs' Motion for Santions by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 09/27/2006)

09/27/2006

4335

MEMORANDUM IN SUPPORT of 4334 MOTION for Review and Objections to Magistrate's Orders of April 25, 2006 − Paragrah 8 (Doc #3865), July 10, 2006 (Doc #4221) and September 13, 2006 (Doc #4315) Denying Plaintiffs' Motion for Santions by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 2# 2 Exhibit 3# 3 Exhibit 4)(Hubbard, Dirk) (Entered: 09/27/2006)

09/27/2006 4336 MOTION Leave to File Motion for Review and Objections Under Seal by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 09/27/2006)

09/27/2006 4338 SEALED MOTION for Review and Objections to Magistrate's Orders by Plaintiff Shirley Williams. (mg) (hw). (Entered: 09/28/2006)

09/27/2006 4339 SEALED MEMORANDUM IN SUPPORT of 4338 SEALED MOTION for Review and Objections to Magistrate's Orders by Plaintiff Shirley Williams.(mg) (hw). (Entered: 09/28/2006)

09/28/2006 4337 ORDER granting 4336 Motion for leave to file motion for review under SEAL. Signed by Judge John W. Lungstrum on 09/28/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 09/28/2006)

09/29/2006 4340 AMENDED CERTIFICATE OF SERVICE of Service of Motion for Review of Magistrate's February 1, 2006 and July 1, 2006 Orders (Doc. 4338) and Supporting Memorandum Doc. 4339 (Filed Under Seal) by Shirley Williams. (Meyers, Martin) (Document title modified on 10/2/2006. (mg)) (Entered: 09/29/2006)

10/02/2006 4341 RESPONSE by Defendant Sprint/United Management Company re 4321 MOTION for extension of time to Respond to Defendant's Third Request for Admissions to Plaintiffs (Opposition) (Gavin, Patrick) (Entered: 10/02/2006)

10/04/2006 4342 ORDER denying without prejudice 4241 Defendant's Motion for Leave to Depose Plaintiff Toby Young in Prison. In accordance with the provisions of the Third Amended, Second−Phase Scheduling Order (doc. 4292), the Court finds that

Defendant's Motion for Leave to Depose Plaintiff Toby Young in Prison is premature and is therefore denied without prejudice to refiling at the appropriate time. Entered by Magistrate Judge David J. Waxse on 10/4/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 10/04/2006)

10/05/2006 4343 MEMORANDUM AND ORDER granting 3417 Defendant's Motion for Protective Order to the extent specifically set forth in the Memorandum and Order. Signed by Magistrate Judge David J. Waxse on 10/5/2006 (mts). (Entered: 10/05/2006)

10/05/2006 4344 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4300 MOTION to Compel Responses to Plaintiffs' 10th Interrogatories and Eleventh Request for Production of Documents (Braud, Bert) (Entered: 10/05/2006)

10/06/2006 4345 MOTION to Compel Production of John Shannon Documents and Computer Information by Plaintiff Shirley Williams. (Hubbard, Dirk) (Modified on 10/11/2006. (mg)) (Entered: 10/06/2006)

10/09/2006

4346

MOTION for Extension of Time to File Response as to 4334 MOTION for Review and Objections to Magistrate's Orders of April 25, 2006 − Paragrah 8 (Doc #3865), July 10, 2006 (Doc #4221) and September 13, 2006 (Doc #4315) Denying Plaintiffs' Motion for Santions by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 10/09/2006)

10/09/2006 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326) by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 10/09/2006)

10/09/2006

4348

MEMORANDUM IN SUPPORT of 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326) by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8)(Hubbard, Dirk) (Entered: 10/09/2006)

10/09/2006 4349 NOTICE of Exhibit Attachment by Shirley Williams re 4348 Memorandum in Support of 4347 Motion. (Exhibits 3−7 are Filed Under Seal) (Hubbard, Dirk) (Entered: 10/09/2006)

10/10/2006 4350 REPORT OF THE SPECIAL MASTER (Dated October 9, 2006). (mg) (Entered: 10/10/2006)

10/10/2006

4351

ORDER granting 4346 Motion for Extension of Time to File Responsere 4334 MOTION for Review and Objections to Magistrate's Orders of April 25, 2006 − Paragrah 8 (Doc #3865), July 10, 2006 (Doc #4221) and September 13, 2006 (Doc #4315) Denying Plaintiffs' Motion for Santions. Response deadline extended to 10/18/2006. Signed by Judge John W. Lungstrum on 10/10/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 10/10/2006)

10/10/2006 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 10/10/2006)

10/10/2006

4353

MEMORANDUM IN SUPPORT of 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A)(Dupont, Philip) (Entered: 10/10/2006)

10/10/2006 4354 SEALED EXHIBITS (3−7) IN SUPPORT of 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326) by Plaintiff Shirley Williams. (mg) (hw). (Entered: 10/11/2006)

10/11/2006

4355

NOTICE of Telephone Conference: A Telephone Conference to discuss the Special Master's recommendations with regard to resumption of mediation is set for 10/12/2006 at 09:00 AM before Magistrate Judge David J. Waxse. The Court will initiate the conference call. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 10/11/2006)

10/11/2006 4356 SEALED RESPONSE by Defendant Sprint/United Management Company regarding 4338 SEALED MOTION for Review and Objections to Magistrate's Orders. (mg) (hw). (Entered: 10/11/2006)

10/11/2006 4357 RESPONSE by Plaintiff Shirley Williams re 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production. (Hubbard, Dirk) (Entered: 10/11/2006)

10/11/2006 4358 ORDER approving Special Master's fees as set out herein. Signed by Magistrate Judge David J. Waxse on 10/11/2006.(jm) (Entered: 10/11/2006)

10/12/2006

4359

Minute Entry for Telephone Status Conference held on 10/12/2006 before Magistrate Judge David J. Waxse. After hearing the respective positions of the parties which includes the objections of Defendant to the Special Master Report to the Court of October 9, 2006 (doc. 4350), the Court declines to enter any order at this time regarding mediation. Minute Sheet attached. (byk) (Entered: 10/12/2006)

10/13/2006 4360 MOTION for Review and Objections to Portions of Magistrate's Order of October 5, 2006 [Doc. # 4343] by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 10/13/2006)

10/13/2006

4361

MEMORANDUM IN SUPPORT of 4360 MOTION for Review and Objections to Portions of Magistrate's Order of October 5, 2006 [Doc. # 4343] by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L)(Hubbard, Dirk) (Entered: 10/13/2006)

10/13/2006

4362

MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K) (Hubbard, Dirk) (Modified on 10/16/2006. (mg)) (Entered: 10/13/2006)

10/18/2006 4363 MOTION to Compel Rule 30(b)(6) Deposition by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C) (Hubbard, Dirk) (Motion title modified on 10/19/2006. (mg)) (Entered: 10/18/2006)

10/18/2006 4364 MOTION to Compel Defendant to Produce Documents by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J) (Hubbard, Dirk) (Motion title modified on 10/19/2006. (mg)) (Entered: 10/18/2006)

10/18/2006

4365

ORDER WITHDRAWING REFERRAL TO SPECIAL MASTER. The automatic referral to the Special Master of Plaintiffs' 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions is hereby withdrawn. Plaintiffs' request for District Judge Lungstrum to rule on this motion is denied. The Magistrate Judge will rule on this motion after District Judge Lungstrum rules on the parties' pending motions for review that relate to the issues in this motion. Signed by Magistrate Judge David J. Waxse on 10/18/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 10/18/2006)

10/18/2006 4366 RESPONSE to Plaintiffs' 9/27/06 Memorandum in Support (#4335) of Motion for Review of Magistrate's Order Denying Sanctions by Defendant Sprint/United Management Company. (Yates, John) (Entered: 10/18/2006)

10/18/2006 4367 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4321 MOTION for extension of time to Respond to Defendant's Third Request for Admissions to Plaintiffs. (Meyers, Martin) (Entered: 10/18/2006)

10/19/2006

4368

ORDER WITHDRAWING REFERRAL TO SPECIAL MASTER. The automatic referral to the Special Master of Plaintiffs' 4364 MOTION to Compel Defendant to Produce Documents is hereby withdrawn. Entered by Magistrate Judge David J. Waxse on 10/19/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 10/19/2006)

10/20/2006 4369 NOTICE OF SERVICE by Shirley Williams of Plaintiffs' Thirteenth Request for Production of Documents to Defendant. (Egan, Dennis) (Entered: 10/20/2006)

10/20/2006 4370 RESPONSE by Defendant Sprint/United Management Company re 4345 MOTION to Compel Production of John Shannon Documents and Computer Information. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Dupont, Philip) (Entered: 10/20/2006)

10/20/2006 4371 MOTION to Stay Portions of 4326 Order Pending Reconsideration and/or Review of the Order by Defendant Sprint/United Management Company. (Yates, John) (Motion title modified on 10/23/2006. (mg)) (Entered: 10/20/2006)

10/20/2006 4372 RESPONSE by Defendant Sprint/United Management Company re 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326). (Yates, John) (Entered: 10/20/2006)

10/24/2006 4373 CERTIFICATE OF SERVICE of Plaintiffs' TWELFTH Interrogatories to Sprint by Shirley Williams. (Egan, Dennis) (Entered: 10/24/2006)

10/24/2006 4374 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production. (Yates, John) (Entered: 10/24/2006)

10/25/2006 4375 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4345 MOTION to Compel Production of John Shannon Documents and Computer Information. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Hubbard, Dirk) (Entered: 10/25/2006)

10/25/2006 4376 MOTION for Extension of Time to File Reply as to 4338 SEALED MOTION for Review and Objections to Magistrate's Orders by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 10/25/2006)

10/26/2006

4377

ORDER granting 4376 Motion for Extension of Time to File Reply re 4338 SEALED MOTION for Review and Objections to Magistrate's Orders Reply deadline extended to 10/30/2006. Signed by Judge John W. Lungstrum on 10/26/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 10/26/2006)

10/26/2006 4378 MOTION for Extension of Time to File Response as to 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions by Defendant Sprint/United Management Company. (Yates, John) (Entered: 10/26/2006)

10/27/2006 4379 RESPONSE by Defendant Sprint/United Management Company re 4360 MOTION for Review and Objections to Portions of Magistrate's Order of October 5, 2006 [Doc. # 4343]. (Yates, John) (Entered: 10/27/2006)

10/30/2006 4380 SEALED REPLY to Sealed Response to Sealed Motion by Plaintiff Shirley Williams regarding 4338 SEALED MOTION for Review and Objections to Magistrate's Orders. (mg) (hw). (Entered: 10/30/2006)

10/30/2006 4381 SEALED EXHIBITS IN SUPPORT of 4380 Sealed Reply to Sealed Response to 4338 Sealed Motion by Plaintiff Shirley Williams. (mg) (hw). (Entered: 10/30/2006)

10/30/2006 4382 SEALED HEARING AND DEPOSITION TRANSCRIPTS regarding 4380 Sealed Reply to Sealed Response to 4338 Sealed Motion by Plaintiff Shirley Williams. (mg) (hw). (Entered: 10/30/2006)

10/31/2006 4383 MOTION for Extension of Time to File Response as to 4364 MOTION to Compel Defendant to Produce Documents by Defendant Sprint/United Management Company. (Costello, Robert) (Entered: 10/31/2006)

11/01/2006

4384

RESPONSE by Defendant Sprint/United Management Company re 4363 MOTION to Compel Rule 30(b)(6) Deposition. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P)(Dupont, Philip) (Entered: 11/01/2006)

11/01/2006 4385 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4334 MOTION for Review and Objections to Magistrate's Orders of April 25, 2006 − Paragrah 8 (Doc #3865), July 10, 2006 (Doc #4221) and September 13, 2006 (Doc #4315) Denying Plaintiffs' Motion for Santions. (Hubbard, Dirk) (Entered: 11/01/2006)

11/01/2006

4386

ORDER granting 4383 Defendant's unopposed MOTION for One−Week Extension of Time to File Response to Plaintiffs' Motion to Compel. Defendant is hereby granted an extension of time, up to and including November 8, 2006, to file its response to 4364 Plaintiffs' MOTION to Compel Defendant to Produce Documents. Entered by Magistrate Judge David J. Waxse on 11/1/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/01/2006)

11/03/2006 4387 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4371 MOTION to Stay Portions of 4326 Order Pending Reconsideration and/or Review of the Order. (Hubbard, Dirk) (Entered: 11/03/2006)

11/03/2006 4388 SPECIAL MASTER ORDER granting in part and denying in part Plaintiff's 4345 Motion to Compel Production of John Shannon Documents and Computer Information. See order for detailed information and instructions. Signed by John R. Phillips, Special Master on 11/03/06. (mg) (Entered: 11/03/2006)

11/03/2006 4389 MOTION for Extension of Time to File reply as to 4372 Response to 4347 Motion for Review and Objections to Portions of Magistrate's Order of September 25, 2006 [#4347] by Plaintiff Shirley Williams. (Hubbard, Dirk) (Document association to original motion made on 11/6/2006. (mg)) (Entered: 11/03/2006)

11/03/2006 4390 AMENDED NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Represenative of Sprint on November 20, 2006. (Attachments: # 1 Exhibit A)(Klamann, John) (Entered: 11/03/2006)

11/06/2006

4391

ORDER granting 4389 Motion for Extension of Time to File a Reply re 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326). Reply deadline extended to 11/7/2006. Signed by Judge John W. Lungstrum on 11/06/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 11/06/2006)

11/06/2006

4392

MEMORANDUM AND ORDER granting in part and denying in part 3454 Defendant's Motion for Protective Order,as follows: (1)That portion of the Motion requesting protection for the Criteria Document is granted and Plaintiffs shall return the Criteria document, and all copies thereof, within five days from the date of this Memorandum and Order. It is further ORDERED that Plaintiffs shall be prohibited from using this document in any manner. (2) That portion of the Motion requesting protection for five e−mails inadvertently produced is denied as moot. Signed by Magistrate Judge David J. Waxse on 11/6/2006.(jm) (Entered: 11/06/2006)

11/06/2006 4393 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4378 MOTION for Extension of Time to File Response as to 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions. (Hubbard, Dirk) (Entered: 11/06/2006)

11/06/2006 4394 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Jeff Mott on 10/23/06 by Personal Service. (Hubbard, Dirk) (Entered: 11/06/2006)

11/06/2006 4395 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Teddy Stock on 11/06/06 by Personal service. (Hubbard, Dirk) (Entered: 11/06/2006)

11/07/2006

4396

NOTICE of Hearing on Motion: 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326): (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Telephone conference set for 11/8/2006 at 04:00 PM before Chief Judge John W. Lungstrum. All counsel wishing to participate in this conference call shall call the conference operator prior to 4:00 p.m. The conference operator can be reached at 1−866−207−0261 and the conference ID # is 1805030.(ses) (Entered: 11/07/2006)

11/07/2006 4397 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326). (Hubbard, Dirk) (Entered: 11/07/2006)

11/08/2006 4398 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon David Soleno on 10/19/06 by Personal Service. (Meyers, Martin) (Entered: 11/08/2006)

11/08/2006 4399 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Jerry Batt on 10/24/06 by Personal Service. (Meyers, Martin) (Entered: 11/08/2006)

11/08/2006 4400 RESPONSE by Defendant Sprint/United Management Company re 4364 MOTION to Compel Defendant to Produce Documents. (Attachments: # 1 Exhibit A)(Yates, John) (Entered: 11/08/2006)

11/08/2006

Minute Entry for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 11/08/2006 re 4347 MOTION for Review and Objections to Portions of Magistrate's Order of September 25, 2006 (Doc # 4326) filed by Shirley Williams. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 11/09/2006)

11/09/2006

4401

ORDER granting 4347 Motion for Review and plaintiffs' objections to the portion of the magistrate judge's 09/25/2006 order denying plaintiffs' motion to compel defendant to produce documents responsive to Requests Nos. 27 through 36 of Plaintiffs' Ninth Request for Product of Documents. Signed by Judge John W. Lungstrum on 11/09/2006. (ses) (Entered: 11/09/2006)

11/09/2006 4402 MOTION for Sanctions by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 11/09/2006)

11/09/2006 4403 MEMORANDUM IN SUPPORT of 4402 MOTION for Sanctions by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H)(Dupont, Philip) (Entered: 11/09/2006)

11/09/2006

4404

MEMORANDUM AND ORDER − 3605 Motion for Review, AND 4338 Motion for Review are granted with respect to Exhibits A through E and Exhibit L and the court remands to the magistrate judge the issue of whether defendant waived the attorney−client privilege with respect to these Exhibits by not asserting that privilege in its privilege log and, if he concludes that defendant did waive the privilege, to consider the merits of defendant's claim that the documents are protected from discovery by the work product doctrine. The motions are retained under advisement with respect to plaintiffs' assertion that defendant waived the attorney−client privilege by asserting its good faith compliance with the ADEA. The motions are otherwise denied. The court will conduct a telephone conference on Thursday, November 16, 2006 at 2:00 PM to hear additional argument concerning whether defendant has waived the attorney−client privilege by asserting its good faith compliance with the ADEA. Signed by Judge John W. Lungstrum on 11/09/2006. (ses) (Corrected Memorandum and Order attached as directed on 11/13/2006. See 4408 Order Nunc Pro Tunc. (mg)) (Entered: 11/09/2006)

11/10/2006 4405 MOTION to Withdraw as Attorney Robert C. Johnson by Defendant Sprint/United Management Company. (Costello, Robert) (Entered: 11/10/2006)

11/10/2006 4406 MOTION to Stay Deadlines of Magistrate's 11/06/06 Order (Doc. #4392) by Plaintiff Shirley Williams. (Hubbard, Dirk) (Modified on 11/13/2006. (mg)) (Entered: 11/10/2006)

11/10/2006 4407 MEMORANDUM IN SUPPORT of 4360 MOTION for Review and Objections to Portions of Magistrate's Order of October 5, 2006 [Doc. # 4343] by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 11/10/2006)

11/13/2006

4408

ORDER NUNC PRO TUNC correcting 4404 Memorandum and Order on Motion for Review. The clerk is directed to substitute the attached memorandum and order for the order filed on 11/9/2006 (doc. 4404). Signed by Judge John W. Lungstrum on 11/13/2006. (Attachments: # 1 11/09/2006 Memorandum and Order)(ses) (Entered: 11/13/2006)

11/13/2006

4409

NOTICE TO COUNSEL OF DOCUMENT CORRECTION AND ATTACHMENT by Deputy Clerk: as directed in the Court's 4408 Order Nunc Pro Tunc, a corrected Memorandum and Order has been attached to docket entry 4404 . The corrected Memorandum and Order is also attached to this notice for the purpose of electronic notification. Contact the Clerk's Office with questions. (mg) (Entered: 11/13/2006)

11/14/2006

4410

ORDER granting in part 4371 Defendant's MOTION to Stay Portions of 4326 Order Pending Reconsideration and/or Review of the Order. The Court hereby stays the portions of the 9/25/2006 Memorandum and Order requiring Defendant to produce adverse impact documents that the Court has previously held to be privileged until such time as the Court rules on 4352 Defendant's Motion for Reconsideration of 9/25/06 Order. Entered by Magistrate Judge David J. Waxse on 11/14/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/14/2006)

11/14/2006

4411

ORDER granting in part 4378 Defendant's Motion for Extension of Time to File Response re 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions. Defendant is hereby granted an extension of time until 11/27/2006 to file a response to Plaintiffs' Motion to Compel Defendant's Witnesses to Respond to Deposition Questions (doc. 4362). Entered by Magistrate Judge David J. Waxse on 11/14/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/14/2006)

11/14/2006

4412

NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Telephone Conference (regarding motions #3605 and #4338) set for 11/16/2006 at 02:00 PM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call shall call the conference operator prior to 2:00 p.m. The conference operator can be reached at 1−866−207−0261 and the conference ID # is 2301363. (ses) (Entered: 11/14/2006)

11/14/2006 4413 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4363 MOTION to Compel Rule 30(b)(6) Deposition. (Hubbard, Dirk) (Entered: 11/14/2006)

11/14/2006

4414

ORDER granting 4406 Plaintiff's Motion to Stay Deadlines set forth in the Magistrate's Order [see document 4392]. This Motion is granted to the extent that the deadline imposed for return of the Criteria document is stayed pending a ruling from the district judge on Plaintiff's Motion for Review of the Magistrate's ruling. Entered by Magistrate Judge David J. Waxse on 11/14/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/14/2006)

11/14/2006

4415

NOTICE of Hearing: Telephone Conference set for 11/20/2006 at 11:15 AM before Magistrate Judge David J. Waxse to discuss issue remanded by Judge Lungstrum in his Memorandum and Order dated 11/09/2006 (doc. 4404). All counsel who wish to participate in this conference call shall call the conference operator prior to **11:10 a.m.** The conference operator can be reached at 1−866−207−2194 and the conference ID # is 2379609. Signed by Magistrate Judge David J. Waxse on 11/16/2006. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (mts) (Entered: 11/14/2006)

11/15/2006 4416 ORDER granting 4405 Motion to Withdraw as Attorney. Attorney Robert C. Johnson is withdrawn as counsel for defendant Sprint/United Management Company. Signed by Magistrate Judge David J. Waxse on 11/15/06. (mg) (Entered: 11/15/2006)

11/15/2006 4417 MOTION for Leave to File Exhibits Under Seal with regard to 12/16/06 hearing by Plaintiff Shirley Williams. (Meyers, Martin) (Motion title modified on 11/17/2006. (mg)) (Entered: 11/15/2006)

11/15/2006 4418 STATEMENT on Defendant's "Good Faith" and Other Defenses Waiving the Attorney Client Privilege by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 11/15/2006)

11/16/2006 4419 ORDER granting 4417 Motion to Seal Exhibits. Signed by Judge John W. Lungstrum on 11/16/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 11/16/2006)

11/16/2006 4420 TRANSCRIPT of telephone conference held 11/8/06 before Judge Lungstrum. Court Reporter: B. Ryder.

NOTICE RE: REDACTION OF TRANSCRIPTS: Within 5 business days of this filing, each party shall inform the Court, by filing a Notice of Redaction, of the parties intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ksd.uscourts.gov. Please read this policy carefully. If no Notice of Intent to Redact is filed within the allotted time, the transcript will be made electronically available after 5 business days.

NOTICE: For access to this document only (unlike other documents) via the Notice of Electronic Filing, click on the CASE NUMBER (not the Document Number) hyperlink; at the login screen enter your ECF login and password; click on Run Report; enter your PACER login and password; and click on the DOCUMENT NUMBER hyperlink.

(Ryder, Becky) (Transcript made electronically available on 12/5/2006. (mg)) (Entered: 11/16/2006)

11/16/2006 4421 NOTICE by Plaintiff Shirley Williams of taking deposition of 30(b)(6) Representative of Ernst & Young on 11/22/06. (Meyers, Martin) (Entered: 11/16/2006)

11/16/2006

4422

Minute Entry for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 11/16/2006 re 4338 SEALED MOTION for Review and Objections to Magistrate's Orders filed by Shirley Williams, 3605 MOTION for Review and Objections to Magistrate's Order of February 1, 2006 (Doc. #35491) as That Order Relates to Adverse Impact Analyses filed by Shirley Williams. Supplemental briefing is ordered Plaintiffs deadline is 11/20/2006 and defendant's deadline is 11/27/2006. (Court Reporter Becky Ryder.) (ses) (Entered: 11/16/2006)

11/16/2006

4423

MEMORANDUM AND ORDER granting 4102 Motion for Review and granting 4334 Motion for Review. This matter is remanded to the magistrate judge for factual findings concerning the denial of plaintiffs' motion for sanctions. If plaintiffs remain aggrieved after the issuance of the magistrate judge's factual findings, they may file a new motion to review. Signed by Judge John W. Lungstrum on 11/16/2006. (ses) (Entered: 11/16/2006)

11/17/2006

4424

SPECIAL MASTER ORDER: Defendant's Objection to Plaintiffs' 4390 Amended Notice Duces Tecum is overruled. See this order for additional instructions. Further, the following are denied as moot: 4308 , 4318 , and 4321 Motions for Extensions of Time to Respond to Defendant's Third Request for Admissions. Signed by John R. Phillips, Special Master on 11/17/06. (mg) (Entered: 11/17/2006)

11/20/2006 4425 RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Dianne Parker on 11/13/2006 by Personal Service. (Meyers, Martin) (Entered: 11/20/2006)

11/20/2006

4426

Minute Entry for Telephone Conference held on 11/20/2006 before Magistrate Judge David J. Waxse. Hearing held on the issue remanded by Judge Lungstrum in his 11/9/2006 Memorandum and Order (doc. 4404) of whether defendant waived the attorney−client privilege with respect to Exhibits A through E and Exhibit L. Matter taken under advisement with written ruling to follow. Defendant shall file any supplemental briefing or proposed factual findings with regard Judge Lungstrum's 11/16/2006 Memorandum and Order (doc. 4423) remanding Plaintiffs' motion for sanctions no later than 11/22/2006. Plaintiffs shall have until 11/29/2006 to file any response. (Minute Sheet attached)(byk) (Entered: 11/20/2006)

11/20/2006 4427 MOTION for Review and Objections to Magistrate's Order of November 6, 2006 [Doc. #4392] and Memorandum in Support by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 11/20/2006)

11/20/2006 4428 NOTICE of Exhibit Attachment by Shirley Williams re 4427 MOTION for Review and Objections to Magistrate's Order of November 6, 2006 [Doc. #4392]. (Hubbard, Dirk) (Entered: 11/20/2006)

11/20/2006 4429 SEALED EXHIBITS IN SUPPORT of 4427 MOTION for Review and Objections to Magistrate's Order of November 6, 2006 [Doc. #4392] by Plaintiff Shirley Williams. (Filed Under Seal)(mg) (hw). (Entered: 11/20/2006)

11/20/2006 4430 RESPONSE by Plaintiff Shirley Williams re 4404 Order on Motion for Review. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Meyers, Martin) (Corrected Response attached on 11/21/2006; Original Response restricted from public viewing. (mg)) (Entered: 11/20/2006)

11/20/2006 4431 NOTICE TO COUNSEL OF DOCUMENT SUBSTITUTION by Deputy Clerk regarding 4430 Response to Order. Due to a formatting problem at the time of filing, a correctly formatted Memorandum in Response has been attached to the above

named docket entry and the original Response has been restricted from public viewing. A copy of the corrected Memorandum in Response is attached to this notice for the purpose of electronic notification. Contact the Clerk's Office with questions. (mg) (Entered: 11/21/2006)

11/21/2006 4432 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4364 MOTION to Compel Defendant to Produce Documents. (Hubbard, Dirk) (Entered: 11/21/2006)

11/22/2006 4433 Joint MOTION for Extension of Time to File Response as to 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions and 4402 MOTION for Sanctions by Defendant Sprint/United Management Company. (Yates, John) (Entered: 11/22/2006)

11/22/2006 4434 NOTICE by Plaintiff Shirley Williams of taking deposition of John Shannon on November 30, 2006. (Egan, Dennis) (Entered: 11/22/2006)

11/22/2006 4435 CERTIFICATE OF SERVICE of Defendant's Responses to Plaintiffs' Thirteenth Request for Production of Documents by Sprint/United Management Company. (Yates, John) (Entered: 11/22/2006)

11/22/2006 4436 Proposed Findings of Fact by Sprint/United Management Company. (Attachments: # 1 Exhibit A)(Yates, John) (Entered: 11/22/2006)

11/22/2006

4437

CERTIFICATE OF SERVICE of Plaintiff's Responses and Objections to Defendant's Third Request for Admissions to Plaintiff, Plaintiff's Answers and Objections to Defendant's 5th Interrogatories to Plaintiff and Plaintiff's Responses and Objections to Defendant's 5th Request for Production of Documents to Plaintiff by Shirley Williams. (Meyers, Martin) (Entered: 11/22/2006)

11/27/2006 4438 CERTIFICATE OF SERVICE of Sprint's Answers to Plaintiffs' Twelfth Interrogatories Directed to Defendant Sprint by Sprint/United Management Company. (Yates, John) (Entered: 11/27/2006)

11/27/2006 4439 SEALED MOTION For Reconsideration of Factual Finding Regarding Exhibits A−E and L in 11/09/06 Adverse Impact Order (Court Document #4404) by Defendant Sprint/United Management Company. (mg) (Motion title modified on 11/28/2006. (mg)) (hw). (Entered: 11/27/2006)

11/27/2006 4440 SEALED STATEMENT Establishing That it Has Not Injected Any Advice of Counsel or The Adverse Impact Analysis Into This Case by Defendant Sprint/United Management Company. (Filed Under Seal) (mg) (hw). (Entered: 11/28/2006)

11/28/2006

4441

ORDER granting 4433 the parties' Joint MOTION for Extensions of Time for File Responses. Defendant is hereby granted an extension of time until 12/08/2006 to file a response in opposition to 4362 Plaintiffs' Motion to Compel Defendant's Witnesses to Respond to Deposition Questions (doc. 4362). Plaintiffs are granted an extension of time until 12/08/2006 to file a response in opposition to 4402 Defendant's Motion for Sanctions. Entered by Magistrate Judge David J. Waxse on 11/28/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 11/28/2006)

11/28/2006

4442

ORDER re 4430 Response to Order filed by Shirley Williams and 4440 Statement filed by Sprint/United Management Company. In light of the position taken by defendant in its supplemental brief, the court believes that a reply from plaintiffs is appropriate. Plaintiffs reply shall be filed no later than 9:00am on Wednesday, November 29, 2006. Signed by Judge John W. Lungstrum on 11/28/2006.(ses) (Entered: 11/28/2006)

11/28/2006 4443 ORDER APPROVING SPECIAL MASTER FEES, re 4177 Order, as set out herein. The parties shall tender payment to the Special Master by December 19, 2006. Signed by Magistrate Judge David J. Waxse on 11/28/2006.(jm) (Entered: 11/28/2006)

11/29/2006

4444

REPLY by Plaintiff Shirley Williams re 4442 Order. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N)(Meyers, Martin) (Document title modified on 11/29/2006. (mg)) (Entered: 11/29/2006)

11/29/2006 4445 AMENDED NOTICE by Plaintiffs of taking deposition of John Shannon on December 6, 2006. (Egan, Dennis) (Modified on 12/1/2006. (mg)) (Entered: 11/29/2006)

11/29/2006 4446 MOTION for Leave to file a surreply in response to plaintiffs' reply to defendant's supplemental brief by Defendant Sprint/United Management Company. (Costello, Robert) (Entered: 11/29/2006)

11/29/2006

4447

ORDER granting 4446 Motion for Leave to File to file a sur−reply in response to plaintiff's reply to defendant's supplemental brief. Said sur−reply shall be filed no later than 11:00 a.m. on 11/30/2006. Signed by Judge John W. Lungstrum on 11/29/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 11/29/2006)

11/30/2006 4448 SUPPLEMENTAL BRIEF establishing that it has not injected any advice of counsel or the adverse impact analysis into this case by Defendant Sprint/United Management Company. (Yates, John) /30/2006) (Entered: 11/30/2006)

12/01/2006

4450

ORDER − Defendant shall file its supplemental brief no later than 12:00 pm on Monday, December 4, 2006. As the court is ultimately resolving plaintiffs motion to review, plaintiffs shall have the proverbial last word and shall file a response to defendants brief no later than 5:00 pm on Tuesday, December 5, 2006. (SEE ORDER FOR FURTHER INFORMATION). Signed by Judge John W. Lungstrum on 12/01/2006.(ses) (Entered: 12/01/2006)

12/04/2006 4451 RESPONSE by Defendant Sprint/United Management Company re 4450 Court's Order of December 1, 2006. (Yates, John) (Modified on 12/5/2006. (mg)) (Entered: 12/04/2006)

12/04/2006 4452 NOTICE by Plaintiff Shirley Williams of taking deposition of Corporate Designee of Development Dimensions International on 12/11/06 at 9AM. (Attachments: # 1 Exhibit A# 2 Exhibit B − part I# 3 Exhibit B − part II# 4 Exhibit B − part III)(Klamann, John) (Entered: 12/04/2006)

12/04/2006 4453 Joint MOTION for Extension of Time to File Response as to 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions and to 4402 Motion for Sanctions by Defendant Sprint/United Management Company. (Yates, John) (Entered: 12/04/2006)

12/05/2006

4454

ORDER granting 4453 the parties' Joint MOTION for Extensions of Time for File Responses. Defendant is hereby granted an extension of time until 12/13/2006 to file a response in opposition to 4362 Plaintiffs' Motion to Compel Defendant's Witnesses to Respond to Deposition Questions (doc. 4362). Plaintiffs are granted an extension of time until 12/13/2006 to file a response in opposition to 4402 Defendant's Motion for Sanctions. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/05/2006)

12/05/2006 4455 MOTION for extension of time to comply with court order 4401 by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A − Declaration of Mark Browne) (Yates, John) (Entered: 12/05/2006)

12/05/2006

4456

SEALED REPLY MEMORANDUM by Plaintiff Shirley Williams re 4450 Order. (Attachments: # 1 Exhibit A)(Meyers, Martin) (Document title modified on 12/6/2006. (mg)) (Document sealed on 12/6/2006 pursuant to Court's Order; see 4460 . (Sealed User MG)) (Additional attachment(s) added on 10/9/2014: # 2 Main Document) (hw). (Entered: 12/05/2006)

12/06/2006

4457

RETURN OF SERVICE of subpoena(s) filed by Plaintiff Shirley Williams executed upon Corporate Counsel − Development Dimensions International on 12/05/2006 by personal service. (Attachments: # 1 Notice to take deposition# 2 Exhibit A# 3 Exhibit B − Part I# 4 Exhibit B − part II# 5 Exhibit B − part III)(Klamann, John) (Entered: 12/06/2006)

12/06/2006 4458 Consent MOTION for Order to Place Plaintiffs' Document #4456 Under Seal by Defendant Sprint/United Management Company. (Costello, Robert) (Entered: 12/06/2006)

12/06/2006 4459 RESPONSE to 4436 Proposed Findings of Fact and Motion for Findings of Fact Related to Denial of Plaintiffs' Motion for Sanctions by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5)(Hubbard, Dirk) (Entered: 12/06/2006)

12/06/2006 4460 ORDER granting 4458 Motion for Order to Place Plaintiffs' Document #4456 Under Seal. Signed by Judge John W. Lungstrum on 12/06/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 12/06/2006)

12/08/2006 4461 MEMORANDUM AND ORDER: The portion of plaintiffs' 3605 and 4338 Motions for Review that the court previously retained under advisement are denied. Signed by Judge John W. Lungstrum on 12/08/06. (mg) (Entered: 12/08/2006)

12/08/2006 4462 MEMORANDUM AND ORDER denying plaintiffs' 4360 Motion for Review. Signed by Judge John W. Lungstrum on 12/08/06. (mg) (Entered: 12/08/2006)

12/11/2006 4463 RESPONSE by Plaintiff Shirley Williams re 4439 SEALED MOTION For Reconsideration of Factual Finding Regarding Exhibits A−E and L in 11/09/06 Adverse Impact Order (Court Document #4404). (Hubbard, Dirk) (Entered: 12/11/2006)

12/11/2006 4464 CERTIFICATE OF SERVICE of Sprint's Supplemental Response to Plaintiffs' Ninth Request for Production of Documents and Things by Sprint/United Management Company. (Yates, John) (Entered: 12/11/2006)

12/12/2006

4465

MEMORANDUM AND ORDER finding as moot 4244 Plaintiffs' Motion to Compel Defendant to Produce Attachments to E−Mails (doc. 4244); and denying 4245 Plaintiffs' Motion to Compel Defendant to Produce Transmittal E−Mails in Native Format. Signed by Magistrate Judge David J. Waxse on 12/12/2006. (byk) (Entered: 12/12/2006)

12/12/2006 4466 Joint MOTION for Extension of Time to File Response as to 4402 MOTION for Sanctions, 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 12/12/2006)

12/13/2006

4467

MEMORANDUM AND ORDER denying 3591 Defendant's Motion for Reconsideration based on an updated privilege log. Defendant's Motion to Clarify the February 1, 2006 Memorandum and Order is granted in part and denied in part: It is granted to the extent that Defendant shall not be required to produce documents 54630, 54874, 54922, 57215, 57429−57471, 57330 and 163528; and Defendant shall not be required to produce the three documents referenced by Defendant that were listed multiple times in the privilege log and found by the Court in at least one instance to be protected by the attorney−client privilege. It is denied to the extent that no clarification is necessary with regard to documents 46294−46298, 179512, 154188−197, 154259−268, 154084−095, 153995−154001, 154084−95, 130597−130600, 130624−130626, 57214 and 153918. Defendant's Motion to Stay the February 1, 2006 Memorandum and Order is granted to the extent that Defendant need not produce any documents pending review of objections to be filed with the District Judge. Signed by Magistrate Judge David J. Waxse on 12/13/2006.(jm) (Entered: 12/13/2006)

12/13/2006

4468

ORDER granting 4466 the parties' Joint MOTION for Extensions of Time for File Responses. Defendant is hereby granted an extension of time until 12/18/2006 to file a response in opposition to 4362 Plaintiffs' Motion to Compel Defendant's Witnesses to Respond to Deposition Questions (doc. 4362). Plaintiffs are granted an extension of time until 12/18/2006 to file a response in opposition to 4402 Defendant's Motion for Sanctions.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/13/2006)

12/14/2006 4469 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4439 SEALED MOTION For Reconsideration of Factual Finding Regarding Exhibits A−E and L in 11/09/06 Adverse Impact Order (Court Document #4404). (Yates, John) (Entered: 12/14/2006)

12/18/2006 4470 REPLY Memorandum and Request for Ruling on Motion for Review and Objections to Magistrate's Order of November 6, 2006 [Doc #4392] by Plaintiff Shirley

Williams. (Hubbard, Dirk) (Document title modified on 12/19/2006; not a motion. (mg)) (Entered: 12/18/2006)

12/18/2006 4471 MOTION to Compel Production of John Shannon Documents and Memorandum in Support by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F) (Hubbard, Dirk) (Entered: 12/18/2006)

12/18/2006 4472 MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged and Memorandum in Support by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C − part 1# 4 Exhibit C − part 2) (Hubbard, Dirk) (Entered: 12/18/2006)

12/18/2006 4473 RESPONSE by Defendant Sprint/United Management Company re 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions. (Attachments: # 1 Exhibit A − deposition testimony of John Shannon)(Yates, John) (Entered: 12/18/2006)

12/18/2006 4474 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4402 MOTION for Sanctions. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Kimak Judy, J'Nan) (Entered: 12/18/2006)

12/18/2006 4475 MOTION for Leave to File Brief Out of Time in Response to Plaintiffs' Motion for Review of Magistrate Judge's Order Regarding Attorney−Client Privilege by Defendant Sprint/United Management Company. (Yates, John) (Entered: 12/18/2006)

12/19/2006

4476

ORDER WITHDRAWING REFERRAL TO SPECIAL MASTER. In accordance with the Court's August 30, 2006 Amended Order Appointing Special Master [Document 4298], the automatic referrals to the Special Master of 4471 Plaintiffs' MOTION to Compel Production of John Shannon documents and 4472 Plaintiffs' MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged are hereby withdrawn. Entered by Magistrate Judge David J. Waxse on 12/19/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/19/2006)

12/19/2006

4477

ORDER TO EXPEDITE BRIEFING: − At the request of the District Judge to expedite briefing on this issue, Plaintiffs shall file their reply brief in support of their 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions no later than Friday, December 29, 2006. Entered by Magistrate Judge David J. Waxse on 12/19/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/19/2006)

12/19/2006

4478

SUPPLEMENTAL RESPONSE by Plaintiff Shirley Williams re 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production. (Attachments: # 1 Exhibit A)(Hubbard, Dirk) (Duplicate text removed on 12/20/2006. (mg)) (Entered: 12/19/2006)

12/19/2006 4479 MOTION to Expedite Defendnt's Responses to Motions by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 12/19/2006)

12/19/2006 4480 ORDER granting 4475 Motion for Leave to File response to plaintiff's review out of time − Response due no later than 12/22/2006. Signed by Judge John W. Lungstrum on 12/19/2006. (ses) (Entered: 12/19/2006)

12/19/2006

4481

ORDER TO EXPEDITE BRIEFING: − Defendant shall file any response in opposition to 4479 Plaintiffs' MOTION to Expedite Defendant's Responses to Motions no later than 5:00 p.m. on Thursday, December 21, 2006. Plaintiffs' Reply due no later than 5:00 p.m. on Friday, December 22, 2006. Entered by Magistrate Judge David J. Waxse on 12/19/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/19/2006)

12/21/2006 4482 RESPONSE by Defendant Sprint/United Management Company re 4479 MOTION to Expedite Defendnt's Responses to Motions. (Yates, John) (Entered: 12/21/2006)

12/21/2006 4483 MOTION to Compel Responses to Discovery by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A Part 1# 2 Exhibit A Part 2# 3 Exhibit A Part3# 4 Exhibit B# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E) (Gavin,

Patrick) (Entered: 12/21/2006)

12/22/2006 4484 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4479 MOTION to Expedite Defendnt's Responses to Motions. (Hubbard, Dirk) (Entered: 12/22/2006)

12/22/2006

4485

ORDER granting 4479 Plaintiffs' unopposed MOTION to Expedite Defendant's Responses to Motions. Defendant shall file its response in opposition to 4471 Plaintiffs' MOTION to Compel Production of John Shannon Documents and 4472 Plaintiffs' MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged by December 29, 2006. Plaintiffs shall file their reply briefs in support of these motions by January 5, 2007. Entered by Magistrate Judge David J. Waxse on 12/22/2006.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 12/22/2006)

12/22/2006 4486 NOTICE of Filing Under Seal by Shirley Williams of Motion to Reconsider and/or Clarify 12/8/06 Order (Doc. #4461); Motion to Stay; and Memorandum in Support and Exhibits. (Hubbard, Dirk) (Entered: 12/22/2006)

12/22/2006 4487 ORDER granting 4455 Motion for Extension of Time to comply and defendant shall produce all responsive documents no later than February 9, 2007. Signed by Judge John W. Lungstrum on 12/22/2006. (ses) (Entered: 12/22/2006)

12/22/2006 4488 MOTION to Compel Responses to Plaintiffs' Thirteenth Request for Production of Documents by Plaintiff Shirley Williams. (Braud, Bert) (Entered: 12/22/2006)

12/22/2006 4489 MEMORANDUM IN SUPPORT of 4488 MOTION to Compel Responses to Plaintiffs' Thirteenth Request for Production of Documents by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Braud, Bert) (Entered: 12/22/2006)

12/22/2006 4490 AFFIDAVIT of Bert S. Braud re 4488 MOTION to Compel Responses to Plaintiffs' Thirteenth Request for Production of Documents by Plaintiff Shirley Williams. (Braud, Bert) (Entered: 12/22/2006)

12/22/2006 4491 CERTIFICATE OF SERVICE of Dr. Ward's Expert Report by Shirley Williams. (Kimak Judy, J'Nan) (Entered: 12/22/2006)

12/22/2006 4492 RESPONSE by Defendant Sprint/United Management Company re 4427 MOTION for Review and Objections to Magistrate's Order of November 6, 2006 [Doc. #4392]. (Yates, John) (Entered: 12/22/2006)

12/22/2006 4493 Plaintiffs' Identification of Potential Witnesses by Shirley Williams.(Meyers, Martin) (Document title modified on 12/27/2006. (mg)) (Entered: 12/22/2006)

12/22/2006 4494 (WITHDRAWN: See 4525 WITHDRAWAL.) MOTION to Supplement Expert Reports by Plaintiff Shirley Williams. (Meyers, Martin) (Modified on 1/9/2007. (mg)) (Entered: 12/22/2006)

12/22/2006 4495 SEALED MOTION to Reconsider and/or Clarify 4461 Order; and SEALED MOTION to Stay Orders (and Memorandum in Support) by Plaintiff Shirley Williams. (Filed Under Seal.) (mg) (hw). (Entered: 12/22/2006)

12/22/2006 4496 SEALED EXHIBITS IN SUPPORT of 4495 SEALED MOTION to Reconsider and/or Clarify 4461 Order; and SEALED MOTION to Stay Orders by Plaintiff Shirley Williams. (Filed Under Seal.) (mg) (Additional attachment(s) added on 10/9/2014: # 1 Attachemnt) (hw). (Entered: 12/22/2006)

12/22/2006 4497 CERTIFICATE OF SERVICE of Disclosure of Expert Reports of Dr. Outtz, Dr. Mann and Dr. Roberson by Shirley Williams (Meyers, Martin) (Entered: 12/22/2006)

12/22/2006 4498 CERTIFICATE OF SERVICE of Plaintiffs' Expert Witness Reports of D. Jan Duffy, Helen Dennis and Colin England by Shirley Williams. (Egan, Dennis) (Entered: 12/22/2006)

12/26/2006 4499 CERTIFICATE OF SERVICE of Report of John R. Michael, Ph.D. on December 22, 2006 by Shirley Williams. (Meyers, Martin) (Entered: 12/26/2006)

12/27/2006 4500 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4402 MOTION for Sanctions. (Dupont, Philip) (Entered: 12/27/2006)

12/28/2006 4501 MOTION for Review of Magistrate Judge's Orders of 2/1/06 and 12/13/06 Compelling the Production of Certain Privileged Documents from Sprint's Privilege Log and Memorandum in Support by Defendant Sprint/United Management Company. (Yates, John) (Entered: 12/28/2006)

12/29/2006 4502 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4362 MOTION to Compel Defendant's Witnesses to Respond to Deposition Questions (Hubbard, Dirk) (Entered: 12/29/2006)

12/29/2006 4503 RESPONSE by Defendant Sprint/United Management Company re 4472 MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged (Yates, John) (Entered: 12/29/2006)

12/29/2006 4504 RESPONSE by Defendant Sprint/United Management Company re 4471 MOTION to Compel Production of John Shannon Documents (Attachments: # 1 Exhibit A − Testimony from John Shannon's 12−06−06 Deposition)(Yates, John) (Entered: 12/29/2006)

01/02/2007

4505

MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4501 MOTION for Review of Magistrate Judge's Orders of 2/1/06 and 12/13/06 Compelling the Production of Certain Privileged Documents from Sprint's Privilege Log. (Attachments: # 1 Exhibit 2# 2 Exhibit 3# 3 Exhibit 4# 4 Exhibit 5# 5 Exhibit 6# 6 Exhibit 7# 7 Exhibit 1)(Hubbard, Dirk) (Exhibit 1 replaced 1/2/07 by request of filer. (jb)) (Entered: 01/02/2007)

01/02/2007 4506 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4427 MOTION for Review and Objections to Magistrate's Order of November 6, 2006 [Doc. #4392]. (Hubbard, Dirk) (Entered: 01/02/2007)

01/02/2007

4507

ORDER WITHDRAWING REFERRAL TO SPECIAL MASTER. In accordance with the Court's August 30, 2006 Amended Order Appointing Special Master [Doc. 4298], the automatic referral to the Special Master of 4402 Defendant's MOTION for Sanctions is hereby withdrawn. Entered by Magistrate Judge David J. Waxse on 1/2/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 01/02/2007)

01/02/2007

4508

ORDER that the Special Master's November 14, 2006 Invoice for professional services rendered and costs advanced through October 31, 2006 in the amount of $8,726.21 is approved as reasonable and appropriate. IT IS FURTHER ORDERED that the Special Master's November 14, 2006 Invoice be apportioned as follows: $4,363.10 to be paid by Plaintiffs and $4,363.10 to be paid by Defendant. The parties shall tender payment to the Special Master by January 23, 2007. Signed by Magistrate Judge David J. Waxse on 1/2/2007.(jm) (Entered: 01/02/2007)

01/02/2007 4509 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326). (Yates, John) (Modified on 1/4/2007. (mg)) (Entered: 01/02/2007)

01/03/2007 4510 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4472 MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged. (Hubbard, Dirk) (Entered: 01/03/2007)

01/03/2007 4511 NOTICE of Change of Address by Dirk L. Hubbard. (Hubbard, Dirk) (Entered: 01/03/2007)

01/03/2007 4512 MEMORANDUM AND ORDER granting 4439 Sealed Motion for reconsideration of factual finding. Signed by Judge John W. Lungstrum on 1/3/2007. (ses) (Entered: 01/03/2007)

01/03/2007 4513 NOTICE TO COUNSEL by Deputy Clerk: Attached to this Notice is the Memorandum and Order (document #4512) filed on 01/03/07; this notice is for the purpose of electronic noticing only. If you have any questions contact the Clerk's Office. (mg) (Entered: 01/03/2007)

01/03/2007 4514 Minute Entry for proceedings held before Judge John W. Lungstrum: Telephone Conference held on 1/3/2007. (No court reporter.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 01/03/2007)

01/04/2007 4515 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4471 MOTION to Compel Production of John Shannon Documents. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Hubbard, Dirk) (Entered: 01/04/2007)

01/04/2007 4516 Unopposed MOTION for Extension of Time to File Response as to 4483 MOTION to Compel Responses to Discovery by Plaintiff Shirley Williams. (Meyers, Martin) (Entered: 01/04/2007)

01/05/2007

4517

RESPONSE to 4494 Motion to Supplement Expert Reports, AND MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such Deadlines by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A)(Gavin, Patrick) (Document/Motion title modified on 1/5/2007. (mg)) (Entered: 01/05/2007)

01/05/2007

4518

MOTION to Expedite Briefing regarding 4517 RESPONSE to 4494 Motion to Supplement Expert Reports, AND MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such Deadlines by Defendant Sprint/United Management Company. (Gavin, Patrick) (Motion title modified on 1/5/2007. (mg)) (Entered: 01/05/2007)

01/05/2007

4519

ORDER granting 4516 Plaintiffs' Unopposed MOTION for Extensions of Time to Respond to Defendant's Motion to Compel 4483 . After consultation with the Special Master, Plaintiffs are granted a two−day extension of time until 1/08/2007 to file a response in opposition to 4483 Defendant Sprint's Motion to Compel Responses to its Third Request for Admissions, Fifth Interrogatories and Fifth Request for Production of Documents. Entered by Magistrate Judge David J. Waxse on 1/5/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 01/05/2007)

01/05/2007 4520 RESPONSE by Defendant Sprint/United Management Company re 4488 MOTION to Compel Responses to Plaintiffs' Thirteenth Request for Production of Documents. (Attachments: # 1 Exhibit A − 08/24/06 Hearing Transcript# 2 Exhibit B − 03/03/06 Proceeding Transcript)(Yates, John) (Entered: 01/05/2007)

01/05/2007

4521

MEMORANDUM AND ORDER granting in part and denying in part 4427 Motion for Review. If plaintiffs have already returned the redacted Criteria Document to defendant, defendant shall provide another copy of the redacted Criteria Document to plaintiffs within 5 days of the date of this order. Otherwise, plaintiffs are entitled to retain the redacted Criteria Document. The court remands to the magistrate judge the limited issue of whether plaintiffs are entitled to an unredacted copy of the Criteria Document. Signed by Judge John W. Lungstrum on 1/5/2007. (ses) (Entered: 01/05/2007)

01/05/2007 4522 SEALED MEMORANDUM in Opposition by Defendant Sprint/United Management Company regarding 4495 SEALED MOTION to Reconsider and/or Clarify 4461 Order; and SEALED MOTION to Stay Orders. (Filed Under Seal.)(mg) (hw). (Entered: 01/08/2007)

01/08/2007

4523

ORDER − Motion Hearing (by telephone) is set for 1/18/2007 at 01:00 PM before Chief Judge John W. Lungstrum re 4494 MOTION to Supplement Expert Reports filed by Shirley Williams, and 4517 RESPONSE to 4494 Motion to Supplement Expert Reports, AND MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such deadlines. All counsel wishing to participate in the conference call shall call the conference operator prior to 1:00 p.m. The conference operator can be reached by dialing 1−866−207−0261. The conference ID # is 5966996. Signed by Judge John W. Lungstrum on 1/8/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 01/08/2007)

01/08/2007

4524

ORDER granting 4518 Defendant's MOTION to Expedite Briefing Concerning Defendant's Motion for Extension of Defendant's Deadline to Complete Plaintiffs' Experts' Depositions, or in the Alternative, For a Stay of Such Deadlines. After consultation with the District Judge, Plaintiffs shall file their response to Defendant's Motion for Extension of Deadlines to Complete Plaintiffs' Experts' Depositions (doc. 4517) no later than 1/11/2007. Defendant shall file its reply no later than 1/12/2007. Entered by Magistrate Judge David J. Waxse on 1/8/2007.(jm) (Entered: 01/08/2007)

01/08/2007 4525 WITHDRAWAL Without Prejudice of 4494 MOTION to Supplement Expert Reports by plaintiffs. (Meyers, Martin) (Document title modified on 1/9/2007. (mg)) (Entered: 01/08/2007)

01/08/2007 4526 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4483 MOTION to Compel Responses to Discovery. (Meyers, Martin) (Entered: 01/08/2007)

01/09/2007

4527

MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4517 RESPONSE to 4494 Motion to Supplement Expert Reports, AND MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such DeadlinesRESPONSE to 4494 Motion to Supplement Expert Reports, AND MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such Deadlines (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Meyers, Martin) (Entered: 01/09/2007)

01/10/2007

4528

REPLY to Response to 4517 MOTION for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such Deadlines by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Dupont, Philip) (Document title and docket text modified on 1/12/2007. (mg)) (Entered: 01/10/2007)

01/12/2007 4529 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4488 MOTION to Compel Responses to Plaintiffs' Thirteenth Request for Production of Documents. (Braud, Bert) (Entered: 01/12/2007)

01/15/2007 4530 MEMORANDUM IN SUPPORT of 4483 MOTION to Compel Responses to Discovery by Defendant Sprint/United Management Company. (Gavin, Patrick) (Duplicate text removed on 1/16/2007. (mg)) (Entered: 01/15/2007)

01/16/2007 4531 REPLY to Response to Motion by Defendant Sprint/United Management Company re: 4501 MOTION for Review of Magistrate Judge's Orders of 2/1/06 and 12/13/06 Compelling the Production of Certain Privileged Documents from Sprint's Privilege Log. (Dupont, Philip) (Entered: 01/16/2007)

01/18/2007 4532 NOTICE of Regarding Pleading Filed Under Seal (Motion to Compel Answers to Deposition Questions in the Depositions of Michael Machell, Deb Sprayberry, and Amy Canton) by Shirley Williams. (Klamann, John) (Entered: 01/18/2007)

01/18/2007 4533 SPECIAL MASTER ORDER granting in part and denying in part Plaintiffs' 4363 Motion to Compel. See this order for additional information. Signed by John R. Phillips, Special Master on 01/18/07. (mg) (Entered: 01/18/2007)

01/18/2007 4534 SPECIAL MASTER ORDER granting in part and denying in part Plaintiffs' 4488 Motion to Compel Responses to Plaintiffs' 13th Request for Production of Documents. See this order for additional information. Signed by John R. Phillips, Special Master on 01/18/07. (mg) (Entered: 01/18/2007)

01/18/2007 4535 SEALED MOTION to Compel Answers to Deposition Questions in the Depositions of Michael Machell, Deb Sprayberry, and Amy Canton by Plaintiffs. (mg) (hw). (Entered: 01/19/2007)

01/18/2007 4536 SEALED EXHIBITS IN SUPPORT of 4535 SEALED MOTION to Compel Answers to Deposition Questions in the Depositions of Michael Machell, Deb Sprayberry, and Amy Canton by Plaintiffs. (mg) (hw). (Entered: 01/19/2007)

01/18/2007

4563

Minute Entry for proceedings held before Judge John W. Lungstrum − Motion Hearing held on 1/18/2007 : granting in part as set forth in full on the record the 4517 Motion for Extension of Defendants Deadline to Complete Plaintiffs Experts Depositions, or in the Alternative, For a Stay of Such filed by Sprint/United Management Company. (Court Reporter Becky Ryder.) (ses) (Entered: 02/13/2007)

01/19/2007 4537 NOTICE of Filing Pleading Under Seal − Reply memorandum in Support of Motion to Reconsider and/or Clarify 12/8/06 Order (Doc. #4461) by Shirley Williams. (Hubbard, Dirk) Mo (Entered: 01/19/2007)

01/19/2007 4538 SEALED REPLY to Response to Motion by Plaintiffs' regarding 4495 SEALED MOTION to Reconsider and/or Clarify 4461 Order; and SEALED MOTION to Stay Orders. (Filed Under Seal.) (mg) (hw). (Entered: 01/19/2007)

01/19/2007 4539 SEALED EXHIBITS IN SUPPORT of 4538 SEALED Reply to SEALED Response to 4495 SEALED MOTION to Reconsider and/or Clarify 4461 Order; and SEALED MOTION to Stay Orders by Plaintiffs'. (Filed Under Seal.) (mg) (hw). (Entered: 01/19/2007)

01/23/2007 4540 MEMORANDUM AND ORDER denying 4501 Motion for Review. Signed by Judge John W. Lungstrum on 1/23/2007. (ses) (Entered: 01/23/2007)

01/23/2007 4541 MEMORANDUM AND ORDER re 4423 remand for factual findings concerning and explanation of reasons for denial of 3580 Plaintiffs' motion for sanctions. Signed by Magistrate Judge David J. Waxse on 1/23/2007.(byk) (Entered: 01/23/2007)

01/24/2007 4542 MEMORANDUM AND ORDER granting in part and denying in part 3670 Plaintiffs' Motion to Compel Answers to Supplemental (Tenth) Request for Production of Documents. Signed by Magistrate Judge David J. Waxse on 1/24/2007. (byk) (Entered: 01/24/2007)

01/25/2007 4543 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dr. John Ward on February 9, 2007 at 8:30 a.m. (Dupont, Philip) (Entered: 01/25/2007)

01/26/2007 4544 NOTICE by Defendant Sprint/United Management Company of taking deposition of Dr. James L. Outtz on January 31, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 01/26/2007)

01/26/2007 4545 NOTICE by Defendant Sprint/United Management Company of taking deposition of Colin England on February 1, 2007 at 9:00 a.m. (Attachments: # 1 Exhibit A)(Dupont, Philip) (Entered: 01/26/2007)

01/26/2007 4546 NOTICE by Defendant Sprint/United Management Company of taking deposition of John Michael on February 2, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 01/26/2007)

01/26/2007 4547 NOTICE by Defendant Sprint/United Management Company of taking deposition of Mitzi Miller on February 27, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 01/26/2007)

01/29/2007 4548 SPECIAL MASTER ORDER denying as moot 4483 Motion to Compel Responses. Signed by John R. Phillips, Special Master on 01/29/07. (mg) (Entered: 01/29/2007)

01/30/2007

4549

ORDERED that the Special Master's December 13, 2006 Invoice for professional services rendered and costs advanced through November 30, 2006 in the amount of $3,204.01 is approved as reasonable and appropriate. IT IS FURTHER ORDERED that the Special Master's December 13, 2006 Invoice be apportioned as follows: $1,602.01 to be paid by Plaintiffs and $1,602.01 to be paid by Defendant. The parties shall tender payment to the Special Master by February 20, 2007. Signed by Magistrate Judge David J. Waxse on 1/30/2007.(jm) (Entered: 01/30/2007)

01/30/2007 4550 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Colin England on February 1, 2007 at 9:00 a.m. (Attachments: # 1 Exhibit A)(Dupont, Philip) (Entered: 01/30/2007)

01/31/2007 4551 MEMORANDUM AND ORDER denying 4495 Motion for Reconsideration and/or clarify. Signed by Judge John W. Lungstrum on 1/31/2007. (ses) (Entered: 01/31/2007)

02/01/2007 4552 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jan Duffy on February 6, 2007. (Dupont, Philip) (Entered: 02/01/2007)

02/01/2007 4553 SEALED RESPONSE by Defendant Sprint/United Management Company regarding 4535 SEALED MOTION to Compel Ansers to Deposition Questions in Deposititons of Michael Machell, Deb Sprayberry, and Amy Canton. (Filed Under Seal.)(mg) (hw). (Entered: 02/01/2007)

02/01/2007

4554

MOTION for Review of Paragraphs 1 and 3 of Special Master's Order Dated January 18, 2007, and memorandum in support by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P#

17 Exhibit Q# 18 Exhibit R# 19 Exhibit S# 20 Exhibit T# 21 Exhibit U# 22 Exhibit V# 23 Exhibit W# 24 Exhibit X# 25 Exhibit Y# 26 Exhibit Z# 27 Exhibit AA) (Costello, Robert) (Entered: 02/01/2007)

02/05/2007 4555 NOTICE by Plaintiff Shirley Williams of taking deposition of Corporate Representative Re: Bates SPRCS−000150 on 02/16/2007 at 9AM. (Klamann, John) (Entered: 02/05/2007)

02/05/2007 4556 NOTICE by Plaintiff Shirley Williams of taking deposition of Corporate Representative Re: Bates SPRCS−000151 on 02/17/2007 at 9AM. (Klamann, John) (Entered: 02/05/2007)

02/05/2007

4557

NOTICE of Hearing on Motion 4554 MOTION for Review of Paragraphs 1 and 3 of Special Master's Order Dated January 18, 2007: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Motion Hearing by telephone is set for 2/13/2007 at 01:30 PM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call shall call the conference operator prior to 1:30 p.m. on 2/13/2007. The conference operator can be reached at 1−866−207−0261 and the conference ID # is 8438531.(ses) (Entered: 02/05/2007)

02/05/2007

4558

ORDER expediting the response deadline as to the 4554 MOTION for Review of Paragraphs 1 and 3 of Special Master's Order Dated January 18, 2007 filed by Sprint/United Management Company. Response deadline is now 2/9/2007. Signed by Judge John W. Lungstrum on 2/05/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 02/05/2007)

02/07/2007 4559 MEMORANDUM AND ORDER granting in part and denying in part 4362 Plaintiffs' Motion to Compel Defendant's Witnesses to Respond to Deposition Questions, as set out herein. Signed by Magistrate Judge David J. Waxse on 2/7/2007.(jm) (Entered: 02/07/2007)

02/09/2007 4560 MOTION to Withdraw as Attorney regarding Jill S. Ferrell by Defendant Sprint/United Management Company. (Dupont, Philip) (Motion title modified on 2/12/2007. (mg)) (Entered: 02/09/2007)

02/09/2007 4561 MEMORANDUM in Opposition by Plaintiff Shirley Williams re 4554 MOTION for Review of Paragraphs 1 and 3 of Special Master's Order Dated January 18, 2007. (Attachments: # 1 Exhibit 1)(Hubbard, Dirk) (Entered: 02/09/2007)

02/13/2007 4562 NOTICE by Defendant Sprint/United Management Company of taking deposition of Helen Dennis on February 16, 2007. (Dupont, Philip) (Entered: 02/13/2007)

02/13/2007

4564

MINUTE ENTRY for proceedings held before Judge John W. Lungstrum − Motion Hearing held on 2/13/2007: denying as set forth in full on the record 4554 MOTION for Review of Paragraphs 1 and 3 of Special Master's Order Dated January 18, 2007 filed by Sprint/United Management Company. (Court Reporter Becky Ryder.) (ses) (Entered: 02/13/2007)

02/14/2007 4565 NOTICE by Defendant Sprint/United Management Company of taking deposition of Quinetta Roberson on February 20, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 02/14/2007)

02/15/2007 4566 SEALED REPLY to 4553 Sealed Response to Sealed Motion by Plaintiffs' regarding 4535 SEALED MOTION to Compel Ansers to Deposition Questions in Deposititons of Michael Machell, Deb Sprayberry, and Amy Canton. (Filed Under Seal.)(mg) (hw). (Entered: 02/15/2007)

02/23/2007

4567

ORDERED that the Special Master's January 16, 2007 Invoice for professional services rendered and costs advanced through December 31, 2006 in the amount of $1,225.81 is approved as reasonable and appropriate. IT IS FURTHER ORDERED that the Special Master's January 16, 2006 Invoice be apportioned as follows: $612.90 to be paid by Plaintiffs and $612.90 to be paid by Defendant. The parties shall tender payment to the Special Master by March 16, 2007. Signed by Magistrate Judge David J. Waxse on 2/23/2007.(jm) (Entered: 02/23/2007)

02/23/2007 4568 CERTIFICATE OF SERVICE of Defendant's Supplemental Responses to Plaintiffs' 10th Request for Production of Documents by Sprint/United Management Company. (Yates, John) (Entered: 02/23/2007)

02/23/2007 4569 CERTIFICATE OF SERVICE of Plaintiffs' Supplemental and Amended Responses and Objections to Defendant's Third Request for Admissions and Plaintifs' Supplemental Answers to Defendant's Fifth Set of Interrogatories Directed to Plaintiffs by Shirley Williams. (Meyers, Martin) (Entered: 02/23/2007)

02/26/2007 4570 CERTIFICATE OF SERVICE of Defendant's Supplemental Responses to Plaintiffs' 13th Request for Production of Documents by Sprint/United Management Company. (Yates, John) (Entered: 02/26/2007)

02/27/2007 4571 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on the Subject of Exhibit 1115; Motion for Sanctions; and Memorandum in Support by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 02/27/2007)

02/27/2007

4572

MEMORANDUM AND ORDER granting 4246 Plaintiffs' Motion to Compel Defendant to Produce Documents with Original Bates Numbers. Within 10 days of the date of this Memorandum and Order, Defendant shall re−produce the following documents with their original bates numbers: (1) documents bearing the new bates numbers of 201807 through 202605, and (2) documents identified by Defendant on its May 30, 2006 eleven−page listing of bates numbers ranges appearing on the privilege log but produced in the litigation from other sources. IT IS FURTHER ORDERED that although the Court overrules Defendant's work product objection, the Court finds the objection to be substantially justified under Fed. R. Civ. P. 37(a)(4)(A) so that the parties shall bear their own costs incurred with making the motion. Signed by Magistrate Judge David J. Waxse on 2/27/2007.(jm) (Entered: 02/27/2007)

02/27/2007

4573

MEMORANDUM AND ORDER granting 4251 Plaintiffs' Motion to Compel Defendant to Produce Document #1000194[−]203 Without Redactions. Within 10 days of the date of this Memorandum and Order, Defendant shall produce document with bates number SPR−W1000194 through SPR−W1000203 without redaction. IT IS FURTHER ORDERED that Plaintiffs' request for a hearing on this matter is denied. IT IS FURTHER ORDERED that although the Court overrules Defendant's work product objection, the Court finds the objection to be substantially justified under Fed. R. Civ. P. 37(a)(4)(A) so that the parties shall bear their own costs incurred with making the motion. Signed by Magistrate Judge David J. Waxse on 2/27/2007.(jm) (Entered: 02/27/2007)

02/27/2007 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for sanctions; and Memorandum in Support by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 02/27/2007)

02/27/2007 4575 ORDER granting 4560 Motion to Withdraw. Attorney Jill S. Ferrell is granted leave to withdraw as counsel of record for Defendant Sprint/United Management Company. Signed by Magistrate Judge David J. Waxse on 2/27/2007. (byk) (Entered: 02/27/2007)

02/28/2007 4576 MOTION to Compel Defendant to Produce Witness for Deposition and Memorandum in Support (re: Doc #4559) by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 02/28/2007)

02/28/2007 4577 CERTIFICATE OF SERVICE of Plaintiffs' Second Requests for Admissions; Fourteenth Request for Production of Documents; and Thirteenth Interrogatories to Defendant by Shirley Williams. (Braud, Bert) (Entered: 02/28/2007)

02/28/2007 4578 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Noel Strong on March 16, 2007 at 10:00 a.m. (Dupont, Philip) (Entered: 02/28/2007)

03/02/2007 4579 AMENDED NOTICE by Defendant Sprint/United Management Company of taking deposition of Dr. John Ward on March 26, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 03/02/2007)

03/06/2007 4580 SUPPLEMENTAL BRIEF IN RESPONSE by Defendant Sprint/United Management Company re 3595 Second MOTION to Compel. (Dupont, Philip) (Document title modified on 3/7/2007. (mg)) (Entered: 03/06/2007)

03/06/2007 4581 MOTION For Voluntary Dismissal of Plaintiffs Dayna Bozille; Agus Budarjo; Daniel Byrne; Brenda Eversole; Deborah Hufnagel; Roger Hunt; Gary Nolte; and Kevin Shannon by Plaintiff Shirley Williams. (Meyers, Martin) (Motion title modified on

3/7/2007. (mg)) (Entered: 03/06/2007)

03/08/2007 4582 REPLY to Response to Motion by Plaintiff Shirley Williams re: 3595 Second MOTION to Declare Invalid Defendant Sprint's Assertions of Privilege Where Legal Counsel was not Involved. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Hubbard, Dirk) (Entered: 03/08/2007)

03/12/2007

4583

MOTION for Extension of Time to File Response as to 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for Sanctions by Defendant Sprint/United Management Company. (Costello, Robert) (Modified on 3/13/2007. (mg)) (Entered: 03/12/2007)

03/13/2007

4584

RESPONSE by Defendant Sprint/United Management Company re 4571 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on the Subject of Exhibit 1115; Motion for Sanctions. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F)(Costello, Robert) (Modified on 3/14/2007. (mg)) (Entered: 03/13/2007)

03/13/2007

4585

ORDER granting 4583 Defendants' MOTION for Extension of Time in Which to Respond to Plaintiffs' Motion to Compel 30(b)(6) Deposition and for Sanctions. Defendant is hereby granted an extension, up to and including 3/16/2007, in which to respond to 4574 Plaintiffs' Motion to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150 and for Sanctions, which is presently referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 3/13/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 03/13/2007)

03/13/2007 4586 RESPONSE by Defendant Sprint/United Management Company re 4576 MOTION to Compel Defendant to Produce Witness for Deposition. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Costello, Robert) (Entered: 03/13/2007)

03/14/2007 4587 MOTION for Leave to File Under Seal by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 03/14/2007)

03/16/2007

4588

ORDER granting 4587 Defendant's unopposed Motion for Leave to File Under Seal. Defendant is hereby granted leave to file its response to Plaintiffs Motion to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for Sanctions; and Memorandum in Support (doc. 4574) under seal. Entered by Magistrate Judge David J. Waxse on 3/16/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 03/16/2007)

03/16/2007 4589 SPECIAL MASTER ORDER denying as moot 4178 Motion for Protective Order; denying as moot 4198 Motion for Extension of Time to File Reply; and denying as moot 4202 Motion for Extension of Time to File Reply. Signed by John R. Phillips, Special Master on 03/16/07. (mg) (Entered: 03/16/2007)

03/16/2007 4590 SEALED RESPONSE by Defendant Sprint/United Management Company regarding 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for Sanctions. (Filed Under Seal.)(mg) (hw). (Entered: 03/16/2007)

03/19/2007 4591 ORDER granting in part and denying in part 3595 Plaintiffs' Second Motion to Declare Invalid Defendants Assertions of Privilege where Legal Counsel Was Not Involved and Motion to Compel such Documents. Signed by Magistrate Judge David J. Waxse on 03/19/2007 (mts). (Entered: 03/19/2007)

03/20/2007 4592 NOTICE by Defendant Sprint/United Management Company of taking deposition of Ken Steele on March 28, 2007 at 9:00 a.m. (Dupont, Philip) (Entered: 03/20/2007)

03/21/2007

4593

REPLY to Response to Motion by Plaintiff Shirley Williams re: 4571 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on the Subject of Exhibit 1115; Motion for Sanctions (Attachments: # 1 Exhibit A −− Part 1# 2 Exhibit A −− Part 2# 3 Exhibit A −− Part 3# 4 Exhibit A −− Part 4)(Hubbard, Dirk) (Entered: 03/21/2007)

03/21/2007 4594 MOTION to Intervene, and MOTION to Protective Order, and Memorandum in Support by Interested Party Cheryl Bolton. (Hubbard, Dirk) (Motion title modified on 4/3/2007. (mg)) (Entered: 03/21/2007)

03/23/2007 4595 CERTIFICATE OF SERVICE of Sprint's Supplemental Responses and Objections to Plaintiffs' Thirteenth Request for Production of Documents by Sprint/United Management Company. (Dupont, Philip) (Entered: 03/23/2007)

03/23/2007 4596 Consent MOTION for Extension of Time to File Response as to 4577 Certificate of Service by Defendant Sprint/United Management Company. (Dupont, Philip) (Entered: 03/23/2007)

03/26/2007 4597 MOTION for Reconsideration and/or Clarification of Portions of the Court's March 19, 2007 Order (Doc #4591) by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1 − Part 1# 2 Exhibit 1 − Part 2# 3 Exhibit 2# 4 Exhibit 3) (Hubbard, Dirk) (Entered: 03/26/2007)

03/26/2007

4598

ORDER granting 4596 Defendant Sprint's Consent Motion for Extension of Time to File Defendant's Response to Plaintiffs' Second Request for Admission; Fourteenth Request for Production of Documents and Thirteenth Interrogatories. Defendant is granted an additional 30 days, up to and including April 30, 2007, to respond to Plaintiffs' discovery requests. Signed by Magistrate Judge David J. Waxse on 3/26/2007.(jm) (Entered: 03/26/2007)

03/27/2007 4599 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4576 MOTION to Compel Defendant to Produce Witness for Deposition. (Hubbard, Dirk) (Entered: 03/27/2007)

03/29/2007 4600 Unopposed MOTION for Extension of Time to File Reply as to 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for Sanctions by Plaintiff Shirley Williams. (Hubbard, Dirk) (Entered: 03/29/2007)

03/30/2007

4601

ORDER granting 4600 Plaintiffs' Unopposed MOTION to Extend Time to File Reply Memorandum. Plaintiffs are hereby granted an one−day extension, up to and including 4/2/2007, in which to file Plaintiffs Reply Memorandum In Support of 4574 Plaintiffs' Motion to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150 and for Sanctions, which is presently referred to the Special Master. Entered by Magistrate Judge David J. Waxse on 3/30/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (byk) (Entered: 03/30/2007)

04/02/2007 4602 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for Sanctions. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Hubbard, Dirk) (Entered: 04/02/2007)

04/02/2007 4603 MOTION to Reconsider Portions of 03/19/07 4591 Memorandum and Order and for Clarification Regarding Adverse Impact Analyses and Supporting Memorandum by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit B) (Yates, John) (Motion title modified on 4/3/2007. (mg)) (Entered: 04/02/2007)

04/03/2007

4604

NOTICE of Hearing on Motion 4594 MOTION to Intervene, and MOTION to Protective Order: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Motion Hearing by telephone conference is set for 4/10/2007 at 11:00 AM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call shall do so by calling the conference operator prior to 11:00 A.M. on 4/10/2007. The conference operator can be reached at 1−866−207−0261 and the conference ID number for this conference is 4861304.(ses) (Entered: 04/03/2007)

04/03/2007 4605 SPECIAL MASTER ORDER granting 4571 Motion to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on the Subject of Exhibit 1115. Plaintiff's 4571 Motion for Sanctions is denied. See this order for further information and direction. Signed by John R. Phillips, Special Master, on 04/03/07. (mg) (Entered: 04/03/2007)

04/03/2007 4606 SPECIAL MASTER ORDER granting 4576 Motion to Compel Defendant to Produce Witness for Deposition. Signed by John R. Phillips, Special Master, on 04/03/07.

(mg) (Entered: 04/03/2007)

04/03/2007 4607 ORDER granting 4581 MOTION For Voluntary Dismissal. Opt−in plaintiffs Dayna Bozille, Agus Budarjo, Daniel Byrne, Brenda Eversole, Deborah Hufnagel, Roger Hunt, Gary Nolte, and Kevin Shannon are dismissed without prejudice. Signed by Judge John W. Lungstrum on 04/03/07. (mg) (Entered: 04/03/2007)

04/04/2007

4608

ORDER − The telephone conference previously scheduled for 4/10/2007 is rescheduled for 4/5/2007 at 03:00 PM before Chief Judge John W. Lungstrum re (doc. 4594) MOTION to Intervene, and MOTION to Protective Order, and Memorandum in Support by Interested Party Cheryl Bolton. All counsel who wish to participate in this conference shall call the conference operator prior to 3:00 p.m. on 4/5/2007. The Conference Operator can be reached at 1−866−207−0261 and the conference ID number is 4861304. Signed by Judge John W. Lungstrum on 4/4/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 04/04/2007)

04/04/2007 4609 MEMORANDUM in Opposition by Defendant Sprint/United Management Company re 4594 MOTION to Intervene, and MOTION to Modify Protective Order. [Docket No. 4594] (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Yates, John) (Modified on 4/5/2007. (mg)) (Entered: 04/04/2007)

04/05/2007 4610 REPLY to Response to Motion by Plaintiff Shirley Williams re: 4594 MOTION to Intervene, and MOTION to Modify Protective Order. (Hubbard, Dirk) (Entered: 04/05/2007)

04/05/2007

4611

MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 4/5/2007 re 4594 MOTION to Intervene, and MOTION to Modify Protective Order filed by Cheryl Bolton. Written order to follow. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 04/05/2007)

04/05/2007 4612 ORDER granting 4594 Motion to Intervene and motion to modify protective order. SEE ORDER FOR DETAILS. Signed by Judge John W. Lungstrum on 4/5/2007. (ses) (Entered: 04/05/2007)

04/09/2007 4613 RESPONSE by Defendant Sprint/United Management Company re 4597 MOTION for Reconsideration and/or Clarification of Portions of the Court's March 19, 2007 Order (Doc #4591). (Doc #4591) (Yates, John) (Entered: 04/09/2007)

04/11/2007 4614 CERTIFICATE OF SERVICE of Defendant's Sixth Request for Production of Documents Directed to Plaintiff by Sprint/United Management Company. (Gavin, Patrick) (Entered: 04/11/2007)

04/16/2007 4615 NOTICE by Plaintiff Shirley Williams of taking deposition of Vicki Kolb on 04/20/2007 at 9:00AM. (Klamann, John) (Entered: 04/16/2007)

04/16/2007 4616 NOTICE by Plaintiff Shirley Williams of taking deposition of David Bottoms on 04/20/2007 at 1:00PM. (Klamann, John) (Entered: 04/16/2007)

04/16/2007 4617 NOTICE by Plaintiff Shirley Williams of taking deposition of Vicki Kolb on 04/20/2007 at 11:00AM. (Klamann, John) (Entered: 04/16/2007)

04/16/2007 4618 Unopposed MOTION to Extend Time to File Response to Defendant's Motion to Reconsider Portions of 3/19/07 Order by Plaintiff Shirley Williams. (Hubbard, Dirk) (Motion title modified on 4/17/2007. (mg)) (Entered: 04/16/2007)

04/18/2007

4619

ORDER granting 4618 Plaintiffs' Unopposed MOTION to Extend Time to File Response to Defendant's Motion to Reconsider Portions of 3/19/07 Order. Plaintiffs are hereby granted an extension, up to and including 4/23/2007, in which to respond to 4603 Defendant's Motion to Reconsider Portions of 3/19/07 Order Regarding Adverse Impact Analyses. Entered by Magistrate Judge David J. Waxse on 4/18/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 04/18/2007)

04/19/2007 4620 SPECIAL MASTER ORDER granting, with limited inquiry, 4574 MOTION to Compel Defendant to Produce Rule 30(b)(6) Witness for Deposition on Document Bates Number SPRCS−000150; Motion for sanctions. Signed by John R. Phillips,

Special Master on 04/19/07. (mg) (Entered: 04/19/2007)

04/23/2007 4621 Unopposed MOTION for extension of time to file (1) Response to Defendant's Motion to Reconsider Portions of 3/19/07 Order and (2) Reply in Support of Plaintiffs' Motion to Reconsider Portions of 3/19/07 Order by Plaintiffs. (Hubbard, Dirk) (Entered: 04/23/2007)

04/23/2007 4622 LIST of Dispositive Motion Witnesses Pursuant to Third Amended Second−Phase Scheduling Order Witness List by Sprint/United Management Company.(Dupont, Philip) (Entered: 04/23/2007)

04/24/2007

4623

ORDER granting 4621 Plaintiffs' Motion for Extension of Time and Plaintiffs shall have an extension of time until May 7, 2007, in which to file (1) Plaintiffs' Response Memorandum to Defendant's Motion to Reconsider Portions of 3/19/07 Order Regarding Adverse Impact Analyses (Doc. #4603), and (2) Plaintiffs' Reply Memorandum in Support of Plaintiffs Motion to Reconsider 3/19/07 Order (4597). Entered by Magistrate Judge David J. Waxse on 4/24/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 04/24/2007)

04/25/2007 4624 NOTICE by Defendant Sprint/United Management Company of taking deposition of Jean Robinson on May 3, 2007 at 1:00 p.m. (Dupont, Philip) (Entered: 04/25/2007)

04/30/2007 4625 Consent MOTION for Ten Day Extension of Time to File Defendant's Responses to Plaintiffs' Second Request for Admissions; 14th Request for Production of Documents; 13th Interrogatories by Defendant Sprint/United Management Company. (Dupont, Philip) (Motion title modified on 5/1/2007. (mg)) (Entered: 04/30/2007)

04/30/2007

4626

ORDERED that the Special Masters February 13, 2007 Invoice for professional services rendered and costs advanced through January 31, 2007 in the amount of $4,515.00 is approved as reasonable and appropriate. IT IS FURTHER ORDERED that the Special Masters February 13, 2006 Invoice be apportioned as follows: $2,257.50 to be paid by Plaintiffs and $2,257.50 to be paid by Defendant. The parties shall tender payment to the Special Master by May 21, 2007. Signed by Magistrate Judge David J. Waxse on 4/30/2007.(jm) (Entered: 04/30/2007)

04/30/2007

4627

MEMORANDUM AND ORDER denying without prejudice 4300 Plainitffs' Motion to Compel Responses to Plaintiffs' Tenth Interrogatoris and Eleventh Requests for Production of Documents. For the reasons set forth herein, the motion is denied without prejudice for failure to confer prior to filing the motion. Signed by Magistrate Judge David J. Waxse on 4/30/2007.(jm) (Entered: 04/30/2007)

04/30/2007

4628

ORDER granting 4625 Defendant's Consent Motion for Ten−Day Extension of Time to File Defendant's Response to Plaintffs' Second Request for Admissions; Fourteenth Request for Production of Documents; and Thirteenth Interrogatories. Defendant shall have an extension of time until May 11, 2007, in which to serve its responses to the following: Plaintffs' Second Request for Admissions, Plaintiffs' Fourteenth Request for Production of Documents, and Plaintiffs' Thirteenth Interrogatories. Entered by Magistrate Judge David J. Waxse on 4/30/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 04/30/2007)

05/02/2007 4629 ORDER STAYING CASE 60 DAYS. All proceedings and deadlines in this case are hereby stayed for 60 days, until July 2, 2007. Entered by Magistrate Judge David J. Waxse on 5/2/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(jm) (Entered: 05/02/2007)

05/15/2007 4630 NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Status Conference set for 5/16/2007 at 09:30 AM before Chief Judge John W. Lungstrum in Courtroom #427. (ses) (Entered: 05/15/2007)

05/16/2007 4635 MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Status Conference held on 5/16/2007 re: preliminary approval of settlement. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 05/22/2007)

05/18/2007 4631 Joint MOTION for Preliminary Approval of Collective Action Settlement Agreement by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit Ex 1 − Master Settlement Agreement# 2 Exhibit A−1 − Sperling List# 3 Exhibit A−2 −

Named and Opt−In Plaintiffs# 4 Exhibit B−1 − General Release# 5 Exhibit B−2 − Individual Opt−in Release# 6 Exhibit C − Stipulation and Order# 7 Exhibit D − Notice# 8 Exhibit 2 − Settlement Matrix# 9 Exhibit 3 − Distributions to Opt−in Plaintiffs# 10 Exhibit 4 − Settlement Amounts for Named Plaintiffs# 11 Exhibit 5 − Notice# 12 Exhibit 6A − General Release# 13 Exhibit 6B − Opt−in Release) (Yates, John) (Motion title modified on 5/21/2007. (mg)) (Entered: 05/18/2007)

05/18/2007

4632

BRIEF IN SUPPORT of 4631 Joint MOTION for Preliminary Approval of Collective Action Settlement Agreement (Brief in Support of Stipulation of Proposed Settlement and [Proposed] Order of Preliminary Confirmation of Settlement Agreement) by Defendant Sprint/United Management Company.(Yates, John) (Document title modified on 5/21/2007. (mg)) (Entered: 05/18/2007)

05/21/2007 4633 ORDER re 4631 Joint MOTION for Preliminary Approval of Collective Action Settlement Agreement. Telephone Conference set for 5/22/2007 at 10:30 AM before Chief Judge John W. Lungstrum. Signed by Judge John W. Lungstrum on 5/21/2007.(ses) (Entered: 05/21/2007)

05/21/2007

4634

NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Telephone Conference set for 5/22/2007 at 10:30 AM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call are instructed to call the conference operator prior to 10:30 AM on 5/22/2007. The conference operator can be reached at 1−866−207−0261 and the conference ID #1579505.(ses) (Entered: 05/21/2007)

05/24/2007

4636

NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Telephone Conference set for 5/24/2007 at 03:00 PM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call are directed to contact the conference operator prior to 3:00 p.m. The conference operator can be reached at 1−866−207−0261 and the conference ID number is 2305209.(ses) (Entered: 05/24/2007)

05/24/2007 4642 MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Telephone Conference held on 5/24/2007. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 06/01/2007)

05/25/2007

4637

CONSENT to the Amendment of the Master Full and Final Settlement Agreement of All Claims and Related Pleadings by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit 1 − Amended Master Agreement# 2 Exhibit 2 − Notice# 3 Exhibit 3 − Amended Stipulation# 4 Exhibit A − Joint Proposed Order) (Yates, John) (Document title modified on 5/29/2007 to reflect this is NOT a motion. (mg)) (Entered: 05/25/2007)

05/25/2007 4638 Amended STIPULATION of Proposed Settlement and Proposed Order of Preliminary Confirmation of Proposed Settlement by Sprint/United Management Company. (Attachments: # 1 Exhibit Ex A − Joint Proposed Order)(Yates, John) (Entered: 05/25/2007)

05/25/2007

4639

ORDER OF PRELIMINARY CONFIRMATION OF PROPOSED SETTLEMENT granting 4631 Joint MOTION for Preliminary Approval of Collective Action Settlement Agreement. Signed by Judge John W. Lungstrum on 5/25/2007. (Attachments: # 1 Exhibit 1 − Amended Settlement Agreement# 2 Exhibit 2 − Notice# 3 Exhibit 3A − General Release# 4 Exhibit 3B − individual opt−in release document) (ses) (Entered: 05/25/2007)

05/30/2007 4640 ORDER re 4639 Order of preliminary confirmation of proposed settlement. Signed by Judge John W. Lungstrum on 5/30/2007.(ses) (Entered: 05/30/2007)

05/30/2007

4641

AMENDED ORDER OF PRELIMINARY CONFIRMATION OF PROPOSED SETTLEMENT. Signed by Judge John W. Lungstrum on 5/30/2007. (Attachments: # 1 Exhibit 1 − Amended Settlement Agreement # 2 Exhibit 2 − Notice # 3 Exhibit 3A − General Release # 4 Exhibit 3B − Individual Opt−In Release Document)(ses) (Entered: 05/30/2007)

06/08/2007 4643 ORDER − In light of the proposed settlement pending before this Court, all deadlines are hereby vacated and the following Motions are terminated but may be refiled if the

settlement is not finalized: 4597 MOTION for Reconsideration and/or Clarification of Portions of the Court's March 19, 2007 Order (Doc #4591) filed by Shirley Williams, 4352 MOTION for Reconsideration of 9/25/06 Order (Court Doc. 4326) Granting, In Part, Plaintiffs' Motion to Compel Responses to Plaintiffs' Eighth and Ninth Requests for Production filed by Sprint/United Management Company, 4364 MOTION to Compel Defendant to Produce Documents filed by Shirley Williams, 4402 MOTION for Sanctions filed by Sprint/United Management Company, 4603 MOTION to Reconsider Portions of 03/19/07 4591 Memorandum and Order and for Clarification Regarding Adverse Impact Analyses filed by Sprint/United Management Company, 4472 MOTION to Compel Production of "Due Diligence" Documents Previously Withheld by Defendant as Privileged filed by Shirley Williams, 4535 SEALED MOTION filed by Shirley Williams, 4471 MOTION to Compel Production of John Shannon Documents filed by Shirley Williams. Signed by Judge John W. Lungstrum on 6/8/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Duplicate text removed on 6/11/2007. (mg)) (Entered: 06/08/2007)

07/02/2007 4644 NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Final Approval hearing set for 9/10/2007 at 10:30 AM before Chief Judge John W. Lungstrum. (ses) (Entered: 07/02/2007)

07/03/2007

4645

ORDERED that the Special Masters March 13, 2007, April 13, 2007, and May 15, 2007 Invoices for professional services rendered and costs advanced for the months of February, March, and April 2007 in the total amount of $7,471.48 is approved as reasonable and appropriate.IT IS FURTHER ORDERED that the total amount of $7,471.48 for the Special Masters March 13, 2007, April 13, 2007, and May 15, 2007 Invoices be apportioned as follows: $3,735.74 to be paid by Plaintiffs and $3,735.74 to be paid by Defendant. The parties shall tender payment to the Special Master by July 23, 2007. Signed by Magistrate Judge David J. Waxse on 7/3/2007.(jm) (Entered: 07/03/2007)

07/16/2007

4646

NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)Telephone Conference set for 7/17/2007 at 12:30 PM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call shall call the conference operator prior to 12:30 p.m on 7/17/2007. The conference operator can be reached by dialing 1−866−207−0261 and the conference ID number is 10113019.(ses) (Entered: 07/16/2007)

07/17/2007 4647 MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Telephone Conference held on 7/17/2007. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 07/17/2007)

07/23/2007 4648 NOTICE of Objection by Shirley Williams of Phil Bodine. (Attachments: # 1 Exhibit Objection, Phil Bodine)(DeFrain, Brian) (Entered: 07/23/2007)

07/24/2007 4649 ORDER − re correspondence from Stephen Homan. Telephone Conference set for 7/25/2007 at 03:00 PM before Chief Judge John W. Lungstrum. Signed by Judge John W. Lungstrum on 7/24/2007. (Attachments: # 1 Attachment)(ses) (Entered: 07/24/2007)

07/24/2007

4650

NOTICE of Hearing: (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) Telephone Conference set for 7/25/2007 at 03:00 PM before Chief Judge John W. Lungstrum. All counsel who wish to participate in this conference call shall contact the conference operator prior to 3:00 PM on 7/25/2007. The conference operator can be reached by dialing 1−866−207−0261 and the conference ID number is 10999015.(ses) (Entered: 07/24/2007)

07/25/2007 4651 MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Telephone Conference held on 7/25/2007. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 07/25/2007)

08/01/2007 4652 MOTION to Be Included as a Plaintiff to the Case by Interested Party John H. Poehlman. (mg) (Entered: 08/02/2007)

08/01/2007 4653 MEMORANDUM IN SUPPORT of 4652 MOTION to Be Included as a Plaintiff to the Case by Interested Party John H. Poehlman. (Attachments: #(1) Exhibit A; #(2) Exhibit B; and #(3) Exhibit C)(mg) (Entered: 08/02/2007)

08/07/2007 4654 RESPONSE by Plaintiff Shirley Williams re 4652 MOTION to Be Included as a Plaintiff to the Case. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Braud, Bert) (Entered: 08/07/2007)

08/07/2007 4655 ORDER re 4652 MOTION to Be Included as a Plaintiff to the Case filed by John H. Poehlman − Response deadline 8/10/2007 and the Motion is set for Hearing on 8/14/2007 at 01:30 PM before Chief Judge John W. Lungstrum. Signed by Judge John W. Lungstrum on 8/7/2007.(ses) (Entered: 08/07/2007)

08/14/2007

4656

MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 8/14/2007 re 4652 MOTION to Be Included as a Plaintiff to the Case filed by John H. Poehlman. The court orders that the 4652 MOTION to Be Included as a Plaintiff to the Case shall be taken under advisement and a Motion Hearing is set for 8/24/2007 at 09:00 AM before Chief Judge John W. Lungstrum. (Court Reporter Becky Ryder.) (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 08/17/2007)

08/17/2007

4657

ORDER − The motion hearing previously scheduled for 8/24/2007 as to 4652 MOTION to Be Included as a Plaintiff to the Case filed by John H. Poehlman, is continued to 9/10/2007 at 10:30 AM before Chief Judge John W. Lungstrum. Signed by Judge John W. Lungstrum on 8/17/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 08/17/2007)

08/20/2007 4658 Joint MOTION for Final Approval of Settlement and Memorandum in Support by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3) (Hubbard, Dirk) (Entered: 08/20/2007)

08/28/2007 4659 MOTION for Attorney Fees by Plaintiff Shirley Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 3−A# 5 Exhibit 3−B# 6 Exhibit 3−C# 7 Exhibit 3−D# 8 Exhibit 3−E) (Hubbard, Dirk) (Entered: 08/28/2007)

09/05/2007 4660 ENTRY OF APPEARANCE by Mark V. Bodine on behalf of Phil Bodine. (Bodine, Mark) (Entered: 09/05/2007)

09/07/2007 4661 NOTICE of Objection to the Settlement Agreement (redacted) by Ruby J. Harvey−Burgin. (Obection received by Express Mail on 09/07/07.) (mg) (Entered: 09/07/2007)

09/10/2007

4662

MINUTE ENTRY for proceedings held before Judge John W. Lungstrum: Motion Hearing held on 9/10/2007 re 4658 Joint MOTION for Final Approval of Settlement filed by Shirley Williams, 4659 MOTION for Attorney Fees filed by Shirley Williams. (Court Reporter Becky Ryder.) (Attachments: # 1 Exhibit list) (ses) (Entered: 09/11/2007)

09/11/2007 4663 ORDER OF FINAL APPROVAL OF SETTLEMENT. Signed by Judge John W. Lungstrum on 9/11/2007.(ses) (Entered: 09/11/2007)

09/11/2007 4664 ORDER − Based upon the final order approving settlement, the Court overrules as moot the 4652 Motion by John Poehlman to be included as plaintiff to case. Signed by Judge John W. Lungstrum on 9/11/2007.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (ses) (Entered: 09/11/2007)

09/11/2007

***Civil Case Terminated. See 4663 Order of Final Approval of Settlement. (mg) (Entered: 09/12/2007)

09/18/2007 4665 MOTION to Withdraw Brian D. DeFrain as attorney for all plaintiffs by Plaintiff Shirley Williams. (DeFrain, Brian) (Entered: 09/18/2007)

10/03/2007 4666 ORDER granting 4665 Motion to Withdraw. Attorney Brian D. DeFrain is withdrawn as counsel of record for all plaintiffs. Signed by Magistrate Judge David J. Waxse on 10/3/07. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (mh) (Entered: 10/03/2007)

12/10/2007 4667 REPORT OF THE PARTIES on Status of the Settlement by Sprint/United Management Company. (Yates, John) (Entered: 12/10/2007)

12/17/2007

RETURN E−mail received addressed to Thomas McCarthy: Contacted and he is no longer with this firm. Not resent, noticing turned off. (This is a text only entry.) (daw) (Entered: 12/17/2007)

01/28/2008 4668 MOTION for extension of time to file an appeal regarding error in the final settlement agreement by Plaintiff Ruby J. Harvey−Burgin. (Upon direction of the Court, voluminous exhibits in support of this motion are filed conventionally and maintained in the Clerk's Office.)(mg) (Entered: 01/29/2008)

01/30/2008

4669

ORDER re 4668 MOTION for extension of time filed by Ruby J. Harvey−Burgin − The Plaintiffs shall have until 2/14/2008 to file a response to Ms. Harvey−Burgin's motion and she in turn shall have until 2/29/2008 to file a reply thereto. Signed by District Judge John W. Lungstrum on 1/30/2008.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 01/30/2008)

02/12/2008 4670 RESPONSE by Plaintiff Shirley Williams re 4668 MOTION for extension of time to file an appeal regarding error in the final settlement agreement. (Braud, Bert) (Entered: 02/12/2008)

02/29/2008 4671 REPLY to Response to Motion by Plaintiff Ruby J. Harvey−Burgin regarding 4668 MOTION for extension of time to file an appeal regarding error in the final settlement agreement. (mg) (Entered: 02/29/2008)

03/05/2008 4672 MOTION to Withdraw as Attorney by Plaintiffs Shirley Williams, Shirley Williams(Molteni, Claudio) (Entered: 03/05/2008)

03/06/2008 4673 ORDER granting 4672 Motion to Withdraw as Attorney. Attorney Claudio E. Molteni terminated. Signed by Magistrate Judge David J. Waxse on 3/6/08. (mh) (Entered: 03/06/2008)

03/07/2008 4674 MEMORANDUM AND ORDER denying 4668 Ms. Harvey−Burgin's Motion for Extension of Time to File an appeal. Signed by District Judge John W. Lungstrum on 3/7/2008. (ses) (Entered: 03/07/2008)

04/04/2008 4675 NOTICE OF APPEAL by Plaintiff Ruby J. Harvey−Burgin. Filing fee $455.00; not paid. (mg) (Entered: 04/11/2008)

04/04/2008 4676 (NOTE: Access to document is restricted pursuant to the Courts privacy policy.)

MOTION for Leave to Appeal in forma pauperis by Plaintiff Ruby J. Harvey−Burgin.(mg) (Entered: 04/11/2008)
04/04/2008 4677 MOTION to Appoint Counsel by Plaintiff Ruby J. Harvey−Burgin.(mg) (Forwarded to 10CCA for ruling; see 4684 .) (Entered: 04/11/2008)
04/04/2008 4678 (NOTE: Access to document is restricted pursuant to the courts privacy policy.)

AFFIDAVIT regarding 4677 MOTION to Appoint Counsel by Plaintiff Ruby J. Harvey−Burgin.(mg) (Entered: 04/11/2008)
04/11/2008 4679 PRELIMINARY RECORD ON APPEAL transmitted to 10CCA re 4675 Notice of Appeal − Final Judgment. (Attachments: # 1 Preliminary Record Part 1, # 2 Preliminary Record Part 2)(kao) (Entered: 04/11/2008)
04/11/2008 4680 ORDER REFERRING MOTION to Magistrate Judge Waxse re 4676

(NOTE: Access to document is restricted pursuant to the Courts privacy policy.)

MOTION for Leave to Appeal in forma pauperis filed by Ruby J. Harvey−Burgin. Signed by District Judge John W. Lungstrum on 04/11/2008.(This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)(ses) (Entered: 04/11/2008)
04/21/2008 4681 (PRO SE) MOTION to Stay Pending Appeal by Plaintiff Ruby J. Harvey−Burgin. (Fax Filed.)(mg) (Entered: 04/22/2008)
04/25/2008 4682 APPEAL DOCKETED in 10CCA on 4/24/2008 and assigned Appeal No. 08−3103 re 4675 Notice of Appeal − Final Judgment filed by Ruby J. Harvey−Burgin. (kao) (Entered: 04/25/2008)

04/28/2008 4683 ORDER granting 4676 Motion for Leave to Appeal in forma pauperis. The Clerk of the District Court shall forward Plaintiff Harvey−Burgins motion to appoint counsel for the purpose of appeal (doc. 4677) to the Tenth Circuit Court of Appeals for ruling. Signed by Magistrate Judge David J. Waxse on 4/28/08. (mh) (Entered: 04/28/2008)

04/28/2008 4685 LETTER to 10CCA: Forwarding additional documents to 10CCA. (Appeal No. 08−3103) (kao) (Entered: 04/28/2008)

04/28/2008 4686 LETTER from 10CCA to appellant re opening brief. (Appeal No. 08−3103) (kao) (Entered: 04/28/2008)

04/28/2008 4687 RESPONSE by Defendant Sprint/United Management Company re 4681 MOTION to Stay Case by Opt−in Plaintiff Ruby Harvey−Burgin. (Yates, John) (Entered: 04/28/2008)

04/28/2008

NOTICE: Doc. 4683 sent to opt−in plaintiff Ruby Harvey−Burgin by regular United States mail and by certified mail, return receipt requested, on 4/28/08. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (mh) (Entered: 04/28/2008)

05/07/2008 4688 CERTIFIED MAIL RECEIPT returned regarding 4683 Order on Motion for Leave to Appeal in forma pauperisaddressed to Ruby J. Harvey−Burgin. (mg) (Entered: 05/07/2008)

06/02/2008 4689 RECORD ON APPEAL transmitted to 10CCA (Volume One) re 4675 Notice of Appeal − Final Judgment. (Appeal No. 08−3103) (kao) (Entered: 06/02/2008)

06/24/2008

4690

MEMORANDUM AND ORDER granting opt−in plaintiff Ruby Harvey−Burgin's 4681 Motion to Stay Pending Appeal. It is further ordered that, Ms. Harvey−Burgin shall be permitted to negotiate her settlement check within 90 days of the final termination of her case and defendant shall be required to honor the check within that time period. Signed by District Judge John W. Lungstrum on 06/24/08. (mg) (Entered: 06/24/2008)

06/30/2008 4691 APPEAL MANDATE from 10CCA: VACATING the District Court order and REMANDING to the District Court for further proceedings re 4675 Notice of Appeal. (Appeal No. 08−3103) (Attachment: # 1 Transmittal Letter)(kao) (Entered: 06/30/2008)

07/21/2008 4692 NOTICE OF APPEAL as to 4663 Order by Plaintiff Ruby J. Harvey−Burgin. (kao) (Entered: 07/21/2008)

07/21/2008

APPEAL FEE STATUS: Filing fee waived re: Notice of Appeal − Final Judgment 4692 . (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (kao) (Entered: 07/21/2008)

07/21/2008 4693 PRELIMINARY RECORD ON APPEAL transmitted to 10CCA re 4692 Notice of Appeal − Final Judgment. (Attachment: # 1 Preliminary Record)(kao) (Entered: 07/21/2008)

07/23/2008 4694 ORDER of 10CCA as to 4692 Notice of Appeal − Final Judgment filed by Ruby J. Harvey−Burgin. Proceedings abated awaiting a disposition of the case on remand. See order for further details. (Appeal No. 08−3196) (kao) (Entered: 07/23/2008)

07/25/2008 4695 MEMORANDUM AND ORDER GRANTING 4668 Ms. Harvey−Burgin's MOTION for extension of time to file an appeal.. Signed by District Judge John W. Lungstrum on 7/25/2008.(ses) (Entered: 07/25/2008)

07/28/2008

4696

ORDER of 10CCA as to 4692 Notice of Appeal − Final Judgment filed by Ruby J. Harvey−Burgin. The previously ordered abatement in this appeal is lifted. The record filed in appeal 08−3103 is transferred to this appeal. Ms. Harvey−Burgin and attorneys for parties must complete and file an entry of appearance form. The district court shall supplement the record on appeal with the filings that were made after 6/2/08. (Appeal No. 08−3196) (kao) (Entered: 07/29/2008)

07/31/2008 4697 SUPPLEMENTAL RECORD ON APPEAL transmitted to 10CCA via email consisting of one volume re 4692 Notice of Appeal − Final Judgment. (Appeal No. 08−3196) (kao) (Entered: 07/31/2008)

11/10/2008 4698 TRANSCRIPT of Settlement Hearing held 9/10/2007 before Judge Lungstrum. Court Reporter B. Ryder, Telephone number 913−551−5645. Transcript purchased by: Bert Braud.

NOTICE RE REDACTION OF TRANSCRIPTS: Within 7 calendar days of this filing, each party shall inform the Court, by filing a Notice of Intent to Redact, of the party's intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ksd.uscourts.gov. Please read this policy carefully. If no Notice of Intent to Redact is filed within the allotted time, this transcript will be made electronically available on the date set forth below.

Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Release of Transcript Restriction set for 2/9/2009. (br) (Entered: 11/10/2008)
12/02/2008 4699 ORDER of 10CCA to Supplement Record as to 4692 Notice of Appeal − Final Judgment filed by Ruby J. Harvey−Burgin. (Order received from 10CCA on 12/2) () (kao) (Entered: 12/02/2008)
12/02/2008 4700 SUPPLEMENTAL RECORD ON APPEAL transmitted to 10CCA re 4692 Notice of Appeal. (Appeal No. 08−3196) (kao) (Entered: 12/02/2008)
12/02/2008 4701 MOTION to Correct the Transcript of the Final Approval Hearing by Plaintiff Ruby J. Harvey−Burgin. (Attachments: #(1) Exhibit)(mg) (Entered: 12/02/2008)
12/12/2008 4702 RESPONSE by Defendant Sprint/United Management Company re 4701 MOTION to Correct the Transcript of the Final Approval Hearing. (Yates, John) (Entered: 12/12/2008)
12/19/2008 4703 TRANSCRIPT of Corrected & Recertified Transcript of Proceedings held 9/10/07 before Judge Lungstrum. Court Reporter B. Ryder, Telephone number 913−551−5645. Transcript purchased by: John Yates.

NOTICE RE REDACTION OF TRANSCRIPTS: Within 7 calendar days of this filing, each party shall inform the Court, by filing a Notice of Intent to Redact, of the party's intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ksd.uscourts.gov. Please read this policy carefully. If no Notice of Intent to Redact is filed within the allotted time, this transcript will be made electronically available on the date set forth below.

Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Release of Transcript Restriction set for 3/19/2009. (br) (Entered: 12/19/2008)

12/19/2008

4704

MEMORANDUM AND ORDER granting in part and denying in part 4701 Motion to correct the trascript of the final approval hearing. It is granted to the extent that line 15 on page 8 of the transcript erroneously contains the word should (an error that has been corrected in the amended certified transcript) and is otherwise denied. Signed by District Judge John W. Lungstrum on 12/19/2008. (ses) (Entered: 12/19/2008)

07/02/2009 4705 APPEAL MANDATE from 10CCA: AFFIRMING decision of the District Court. (Appeal No. 08−3196) (Attachment: # 1 Transmittal letter)(kao) (Entered: 07/07/2009)

08/18/2009 4706 Joint MOTION to Terminate the Qualified Settlement Fund and Disburse Remaining Funds by Defendant Sprint/United Management Company. (Yates, John) (Entered: 08/18/2009)

08/18/2009 4707 MEMORANDUM IN SUPPORT of 4706 Joint MOTION to Terminate the Qualified Settlement Fund and Disburse Remaining Funds by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit Declaration of Mark Patton)(Yates, John) (Entered: 08/18/2009)

08/24/2009 4708 ORDER TERMINATING QUALIFIED SETTLEMENT FUND AND DISBURSING REMAINING FUNDS granting 4706 Motion for Disbursement of Funds (e−mail to Finance). Signed by District Judge John W. Lungstrum on 08/24/2009. (ses) (Entered: 08/24/2009)

10/12/2009

4709

REPORT TO THE COURT AND COUNSEL REGARDING FINAL DISTRIBUTION OF FUNDS FROM THE SETTLEMENT FUND AND MOTION AND SUGGESTIONS FOR THE COURT'S FINAL ORDER OF DISMISSAL WITH PREJUDICE by Defendant Sprint/United Management Company. (Attachments: # 1 Exhibit)(Yates, John) (Modified on 10/23/2009. (mg)) (Entered: 10/12/2009)

10/15/2009 4710 ORDER Accepting Report of Final Termination of Qqualified Settlement Fund and Dismissing Cause With prejudice. Signed by District Judge John W. Lungstrum on 10/15/09. (mm) (Entered: 10/16/2009)