Incoming_Description
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Attend court-mandated status conference | Attend status conference as required by the Court |
Telephone conference with C Zaba regarding brief factual background relating to Charge of Discrimination allegations | Telephone conference with C Zaba regarding brief factual background as to Charge of Discrimination allegations |
Review new charge of discrimination filed by Olivia Stapleton | Review new charge of discrimination filed by Olivia Stapleton |
Emails with C Zaba regarding information needed for response to Charge of Discrimination | Emails with C Zaba regarding information necessary for response to Charge of Discrimination |
Emails with investigator regarding extension of time to file position statement and response to RFI | Emails with investigator regarding extension of time for submission of position statement and response to RFI |
Attend Lambert mediation (Mediation approved by C Hamilton 8/9/22) | Attend by Zoom Lambert mediation Start Time: 10:30 AM End Time: 1:30 PM Total Time: 300 (Mediation approved by C Hamilton 8/9/22) |
Further preparation of initial case assessment | Further drafting initial case assessment for Travelers |
Email C Zaba following up on background information related to Charge of Discrimination allegations | Email C Zaba regarding follow-up on background information as to Charge of Discrimination allegations |
Prepare Release and Settlement Agreement, as approved by adjuster Judy Salcedo | Prepare Release and Settlement Agreement, as approved by adjuster Judy Salcedo on 8/10/2022 |
Email to adjuster Judy Salcedo regarding proposed Release and potential resolution of underlying claims | Email to adjuster Judy Salcedo regarding proposed Release and potential resolution of underlying claims, as approved by adjuster Judy Salcedo on 8/10/2022 |
Continue analyzing new e-discovery received from Kaba MAs | Continue analyzing new e-discovery received from Kaba MAs in preparation for E Elkins deposition |
Further preparation of initial case assessment | Further drafting initial case assessment for Travelers |
Travel to Lafayette to attend witness interviews | Travel to Lafayette, Indiana to attend witness interviews |
Attention to audio recording of interview with S Blake for information pertaining to affidavit and reply in support | Analyze audio recording of interview with S Blake for information pertaining to affidavit and reply in support |
Conduct witness interview of C Kulesza | Communicate by teams meeting with C Kulesza regarding witness interview |
Email client regarding status of pending Charge of Discrimination | Email client regarding update as to Charge of Discrimination |
Email J Wilhelm regarding status of settlement negotiations | Communicate by email to J Wilhelm regarding update as to settlement negotiations |
Prepare for outlining and drafting motion to dismiss by reviewing complaint, available claim materials, and prior work product re dismissal of KUCSPA claims under Mosley standard | Review complaint, available claim materials, and prior work product re dismissal of KUCSPA claims under Mosley standard in anticipation of motion to dismiss (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise detailed outline of motion to dismiss Whitaker KUCSPA claim | Draft and revise detailed outline of motion to dismiss Whitaker KUCSPA claim (Approved by J Salcedo on 8/10/2022) |
In the course of preparing motion to dismiss, research and analyze KUCSPA specific prohibitions and compare same to Plaintiffs allegations of unfair settlement conduct | Research the issue of KUCSPA specific prohibitions and compare same to Plaintiffs allegations of unfair settlement conduct in anticipation of motion to dismiss (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise argument for motion to dismiss that claim handlers alleged delays do not constitute bad faith | Draft and revise argument for motion to dismiss that claim handlers alleged delays do not constitute bad faith (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise argument in motion to dismiss that Plaintiff does not allege any compensable damages | Draft and revise argument in motion to dismiss that Plaintiff does not allege any compensable damages (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise argument in motion to dismiss that Plaintiff does not allege outrageous conduct under Mosley, Holloway, and Wittmer | Draft and revise argument in motion to dismiss that Plaintiff does not allege outrageous conduct under Mosley, Holloway, and Wittmer (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise argument in motion to dismiss that Plaintiff does not identify a particular statutory violation under KUCSPA | Draft and revise argument in motion to dismiss that Plaintiff does not identify a particular statutory violation under KUCSPA (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise factual background/ allegations section of motion to dismiss | Draft and revise factual background/allegations section of motion to dismiss (Approved by J Salcedo on 8/10/2022) |
Analyze, draft, and revise section of motion to dismiss with specific applicable legal standards | Draft and revise section of motion to dismiss with specific applicable legal standards (Approved by J Salcedo on 8/10/2022) |
Analyze whether unique posture of Plaintiffs claims implicates first and second Wittmer elements | Analyze whether unique posture of Plaintiffs claims implicates first and second Wittmer elements (Approved by J Salcedo on 8/10/2022) |
Prepare for mediation, including analyzing prior settlement negotiations, email correspondence re: retirement plans, and drafts of employment agreements exchanged between the parties | Prepare for mediation (Preparation includes analyzing prior settlement negotiations, email correspondence re: retirement plans, and drafts of employment agreements exchanged between the parties) |
Continue drafting mediation statement | Further drafting mediation statement for upcoming mediation |
Follow up email to plaintiffs counsel noting (again) the failure to timely provide settlement demand | Communicate by follow-up email to plaintiffs counsel regarding the failure to timely provide settlement demand |
Review and revise Motion to Dismiss with additional research of, and discussion of, Kentucky bad faith law | Revise Motion to Dismiss with additional research of, and discussion of, Kentucky bad faith law (Approved by J Salcedo on 8/10/2022) |
Telephone calls to client regarding information needed for response to Charge of Discrimination | Telephone calls to client regarding information necessary for response to Charge of Discrimination |
Draft email to opposing counsel requesting supplemented discovery outlined in August 9 letter | Draft email to Plaintiffs counsel re request for additional discovery as provided in August 9 letter |
Respond to questions and feedback from client representatives re the confidential settlement statement and general case status | Communicate by email to client representatives re the confidential settlement statement and update as to the general case |
Continue preparing for mediation, including analyzing emails between S Mongrello and P Broderick re retirement plans and Plaintiff’s requests for accommodations | Further preparation for mediation (Preparation includes analyzing emails between S Mongrello and P Broderick re retirement plans and Plaintiff’s requests for accommodations) |
Continue drafting mediation statement, including making substantive revisions regarding facts, accommodations, and damages | Further drafting mediation statement, including making substantive revisions regarding facts, accommodations, and damages |
Finalize confidential settlement statement draft, in accordance with the Courts order, to include legal analysis of defenses in opposition to plaintiffs claims in order to email same to clients and S Samuel for approval | Revise confidential settlement statement, in accordance with the Courts order, regarding the legal analysis of defenses in opposition to plaintiffs claims |
Draft response correspondence to M Turner re status of offer to charging party | Email client re update as to offer to charging party |
Draft email correspondence to EEOC investigator re status of charging partys response to settlement demand | Email to EEOC investigator re update as to charging partys response to settlement demand |
Email from mediator J Tedesco regarding withdrawal form and requesting Settlement Agreement | Email from mediator J Tedesco regarding withdrawal form and request for Settlement Agreement |
Finalize proposed Protective Order based on email received from Plaintiffs attorney | Revised Protective Order based on email from Plaintiffs attorney |
Email from attorney B Ellis regarding defendants information needed for Case Management Plan | Communicate by email from attorney B Ellis regarding defendants information necessary for Case Management Plan |
Draft and revise Motion to Dismiss Plaintiffs bad faith claim | Draft and revise Motion to Dismiss Plaintiffs bad faith claim (Approved by J Salcedo on 8/10/2022) |
Draft and revise motion to dismiss to incorporate client comments and prepare for filing | Draft and revise motion to dismiss to incorporate client comments and attention to same (Approved by J Salcedo on 8/10/2022) |
Draft, revise, and finalize Motion to Dismiss for filing | Draft and revise Motion to Dismiss for the purpose of finalizing same (Approved by J Salcedo on 8/10/2022) |
Review factual background to prepare for mediation strategy meeting with client | Review factual background in preparation of mediation strategy meeting with client |
Draft email correspondence to M Grosswald re status of investigation, settlement, and position statement deadline based upon EEOC mediators comments | Email to M Grosswald re update as to investigation, settlement, and position statement deadline pursuant to EEOC mediators comments |
Email attorney D Fleischhacker responding to his question about status of response to settlement demand | Email attorney D Fleischhacker responding to his question about update as to response to settlement demand |
Continue drafting mediation statement | Further drafting mediation statement |
Review mediation statement based on information received during mediation strategy meeting with client | Review mediation statement regarding information received during mediation strategy meeting with client |
Prepare notice of substitution of A Kegley for T Powell as counsel; review recent pleadings to prepare service list for service to parties not registered to receive electronic service from the Court | Draft notice of substitution of A Kegley for T Powell as counsel including attention to recent pleadings for the purpose of developing service list for service to parties not registered to receive electronic service from the Court |
Finalize Requests for Admissions to submit to nexAir and prepare/file Notice of Service; prepare correspondence to counsel re same | Revise Requests for Admissions to submit to nexAir for the purpose of finalizing same and draft Notice of Service and attention to same |
Proofread and revise Requests for Admissions propounded to nexAir | Revise Requests for Admissions propounded to nexAir |
Email from C Zaba regarding factual background information relating to Charge of Discrimination allegations | Email from C Zaba regarding factual background information as to Charge of Discrimination allegations |
Telephone conference with J Garry regarding factual background information relating to O Stapleton employment | Telephone conference with J Garry regarding factual background information as to O Stapleton employment |
Telephone conference with T Antonetti regarding factual background information needed for response to Charge of Discrimination | Telephone conference with T Antonetti regarding factual background information necessary for response to Charge of Discrimination |
Draft email correspondence to M Grosswald and A VonFeldt with copy of letter to EEOC requesting 9/30 deadline to submit position statement and requesting video of incident | Email to M Grosswald and A VonFeldt regarding letter to EEOC with request for 9/30 deadline for submission of position statement and for video of incident |
Email from M Kozimor regarding status of pending Charge of Discrimination | Communicate by email from M Kozimor regarding request for update as to pending Charge of Discrimination |
Email M Kozimor responding to his question about the status of the pending Charge of Discrimination | Communicate by email to M Kozimor in response to his question regarding update as to the pending Charge of Discrimination |
Emails with adjuster Judy Salcedo regarding communications with client and status update on settlement discussions with Plaintiffs counsel | Emails with adjuster Judy Salcedo regarding communications with client and update as to settlement discussions with Plaintiffs counsel |
Emails with D McCreary regarding K Hatton email to S Mongrello outlining offered employment options | Emails with D McCreary regarding K Hatton email to S Mongrello providing potential employment options |
Calls (x2) to Third-Party Plaintiffs Attorney - Discuss His "Loss of Contact" with Client and What That Means Moving Forward | Calls (x2) to Third-Party Plaintiffs Attorney - Discuss His "Loss of Contact" with Client and What That Means Moving Forward |
Email attorney C Asay regarding employment and Social Security Disability information needed for damages analysis | Email attorney C Asay regarding employment and Social Security Disability information necessary for damages analysis |
Email and phone call with Plaintiffs counsel regarding proposed release, further extension for Mr Bradburn and Conduent to respond to the Complaint, and potential resolution of underlying claims | Communicate by email and phone call with Plaintiffs counsel regarding proposed release, further extension for Mr Bradburn and Conduent to respond to the Complaint, and potential resolution of underlying claims |
Prepare Affirmation relating to R Montgomerys compliance with paragraph 11 of the Settlement Agreement pursuant to request from client | Draft Affirmation relating to R Montgomerys compliance with paragraph 11 of the Settlement Agreement pursuant to request from client |
Email client regarding next steps based on receipt of settlement checks | Email client regarding next steps pursuant to receipt of settlement checks |
Email client regarding revisions to Settlement Agreement requested by client during phone calls on August 25th and 26th | Email client regarding revisions to Settlement Agreement requested by client during phone calls on August 25th and 26th |
Email client regarding Settlement Agreement received from attorney M Parker with revisions | Email client regarding Settlement Agreement received from attorney M Parker with revisions |
Emails with J Goldman regarding the status of the signed Settlement Agreement | Emails with J Goldman regarding update as to signed Settlement Agreement |
Telephone conference with A Wicke regarding proposed revisions to the Settlement Agreement | Telephone conference with A Wicke regarding proposed revisions to the Settlement Agreement |
Email attorney M Parker regarding discussion about Kieslers proposed revisions to the Settlement Agreement | Email attorney M Parker regarding discussion about Kieslers proposed revisions to the Settlement Agreement |
Review Kentucky Civil Rights Commission no probable cause Dismissal Order | Review Kentucky Civil Rights Commission no probable cause Dismissal Order |
Email client regarding Kentucky Commission on Human Rights no probable cause Dismissal Order | Email client regarding Kentucky Commission on Human Rights no probable cause Dismissal Order |
Add additional documents S Steller provided to bates-labeled production and update responses accordingly | Revise document production regarding additional documents from S Steller and attention to responses accordingly |
Draft correspondence to opposing counsel containing discovery responses and production | Communicate by email to Plaintiffs counsel re discovery responses and production |
Create Request upload Sharefile folder Provide access link to J Kaiser for delivery to client to receive data | Create Request upload Sharefile folder Provide access link to J Kaiser for delivery to client to receive data |
Encrypt document production and upload to Sharefile Provide distribution link to L Ferone for delivery to counsel | Encrypt document production and upload to Sharefile Provide distribution link to L Ferone for delivery to counsel |
Email from attorney A Dutkanych regarding executed Settlement Agreement | Email from attorney A Dutkanych regarding executed Settlement Agreement |
Review factual background information received from A Royer | Review factual background information from A Royer |
Email C Zaba regarding additional information needed for response to charge of discrimination | Email C Zaba regarding additional information necessary for response to charge of discrimination |
Email client regarding initial information needed for response to Charge of Discrimination | Email client regarding initial information necessary for response to Charge of Discrimination |
Email from J Garry regarding additional factual background information relating to O Stapletons employment | Email from J Garry regarding additional factual background information as to O Stapletons employment |
Telephone conference with A Royer regarding additional factual background information relating to O Stapletons Charge of Discrimination allegations | Telephone conference with A Royer regarding additional factual background information as to O Stapletons Charge of Discrimination allegations |
Additional email with client regarding mediation strategy based on the mediators calendar and the clients availability | Additional email with client regarding mediation strategy pursuant to mediators calendar and the clients availability |
Email client regarding mediation strategy based on need to reschedule and mediators availability | Email client regarding mediation strategy pursuant to mediators availability |
Email client regarding new mediation strategy based on telephone call from Plaintiffs attorney regarding rescheduling mediation | Email client regarding new mediation strategy (The new mediation strategy is pursuant to telephone call from Plaintiffs attorney regarding rescheduling mediation) |
Telephone conference with attorney C Asay regarding rescheduling mediation due to hospitalization of Plaintiff | Telephone conference with attorney C Asay regarding hospitalization of Plaintiff |
Continue preparation for mediation, including analyzing Plaintiffs current employment and compensation | Further preparation for mediation, including attention to Plaintiffs current employment and compensation |
Strategize regarding mediation based on Plaintiffs inability to participate in currently scheduled mediation | Strategize regarding mediation due to Plaintiff being unavailable for scheduled mediation |
Prepare fact section of position statement responding to Charge of Discrimination | Draft fact section of position statement in response to Charge of Discrimination |
Email A Royer requesting clarification of date she met with O Stapleton for fact section of position statement | Email A Royer regarding request for clarification of date she met with O Stapleton for fact section of position statement |
Review letter to EEOC prepared by assistant entering Appearance and requesting extension of time | Review letter to EEOC (as drafted by assistant) regarding Appearance and request for extension of time |
Draft status update email to client and Travelers claims counsel recommending strategy for next steps given that Motion to Dismiss remains pending in order to best protect insured while minimizing legal costs | Email to client and Travelers claims counsel re recommendation as to strategy for next steps given that Motion to Dismiss is pending before the Court |
Email C Asay responding to his question about potential mediation dates | Email C Asay responding to his question about potential mediation dates |
Email D Mason regarding next steps based on Settlement Agreement signed by R Evans | Email D Mason regarding next steps pursuant to Settlement Agreement signed by R Evans |
Review letter to attorney A Dutkanych prepared by assistant regarding settlement checks | Review letter to attorney A Dutkanych prepared by assistant regarding settlement checks |
Further preparation of fact section of position statement responding to Charge of Discrimination containing allegations in 40 numbered paragraphs | Further preparation of fact section of position statement in response to Charge of Discrimination (containing allegations in 40 numbered paragraphs) |
Prepare legal argument section of position statement responding to Charge of Discrimination containing allegations in 40 numbered paragraphs | Prepare legal argument section of position statement in response to Charge of Discrimination (containing allegations in 40 numbered paragraphs) |
Email client regarding draft position statement responding to Charge of Discrimination containing 40 numbered paragraphs | Email client regarding draft position statement in response to Charge of Discrimination (containing 40 numbered paragraphs) |
Email client regarding fact section of position statement responding to Charge of Discrimination | Email client regarding fact section of position statement in response to Charge of Discrimination |
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