Hirsch v. Cognizant Technology Solutions U.S. Corp.
| Christine Hirsch |
| Cognizant Technology Solutions U.S. Corp. |
| 1:2021cv00161 |
| January 11, 2021 |
| US District Court for the Northern District of Illinois |
| Edmond E Chang |
| Civil Rights: Jobs |
| 28 U.S.C. § 1441 |
| Plaintiff |
Docket Report
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| Filing 23 MINUTE entry before the Honorable Edmond E. Chang: The agreed extension motion on fact discovery #22 is granted to 12/28/2021. But no summary judgment schedule will be set yet. Instead, the parties must engage in settlement negotiations as the end of fact discovery approaches and after it ends. The tracking status hearing of 11/12/2021 is reset to 01/21/2022 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 01/14/2022, including a report on settlement negotiations. Emailed notice (mw, ) |
| Filing 22 MOTION by Plaintiff Christine Hirsch for extension of time to complete discovery JOINT Motion for Extension of Fact Discovery Schedule (DiOrio, Nicole) |
| Filing 21 MINUTE entry before the Honorable Edmond E. Chang: The joint extension motion #19 to file the Deposition Scheduling Report is granted, and the Report is accepted as filed. On review of the Report, R. 20, it appears that the parties will finish fact discovery on time. Emailed notice (mw, ) |
| Filing 20 Joint Deposition Scheduling Report by Christine Hirsch (DiOrio, Nicole) |
| Filing 19 MOTION by Plaintiff Christine Hirsch for extension of time Joint Motion for Extension to Submit Deposition Scheduling Report (Attachments: #1 Notice of Motion)(DiOrio, Nicole) |
| Filing 18 MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 17, the parties are working on deposition scheduling and are on track to finish fact discovery on time. The defense must promptly supply addresses of former employees so that the Deposition Scheduling Report, due on 09/14/2021, can have confirmed dates. The tracking status hearing of 08/27/2021 is reset to 11/12/2021 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 11/05/2021, confirming that fact discovery has closed and proposing the next step of the litigation. The parties also must initiate settlement discussions as the end of fact discovery approaches. Emailed notice (mw, ) |
| Filing 17 STATUS Report of Discovery by Cognizant Technology Solutions U.S. Corp. (Hays, John) |
| Filing 16 MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 15, written discovery is progressing. The tracking status hearing of 06/25/2021 is reset to 08/27/2021 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a discovery progress report by 08/20/2021. Emailed notice (mw, ) |
| Filing 15 STATUS Report Joint Discovery Status Report by Christine Hirsch (DiOrio, Nicole) |
| Filing 14 MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 13, written discovery responses have begun. The tracking status hearing of 04/16/2021 is reset to 06/25/2021 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a discovery progress report by 06/18/2021. Emailed notice (mw, ) |
| Filing 13 STATUS Report Joint Status Report by Christine Hirsch (DiOrio, Nicole) |
| Filing 12 MINUTE entry before the Honorable Edmond E. Chang: On review of the initial status report, R. 11, the following schedule is set. Rule 26(a)(1) disclosures due 02/12/2021. The first round of written discovery requests must be issued by 02/19/2021. Fact discovery, including any treating health care providers (if any), must be completed by 10/29/2021. Rule 26(a)(2)(C) summaries for treating health care providers (if any) must be disclosed 75 days in advance of the fact discovery deadline, and adjusts with any general extension of fact discovery deadline. Rule 16(b) deadline to add parties or amend pleadings is 08/02/2021.The deadline to serve subpoenas is 08/16/2021, absent good cause (e.g., genuine surprise despite due diligence). By 09/14/2021, the parties shall file a Deposition Scheduling Report listing the depositions already taken and (more importantly) the remaining deponents, all of whom must have ***confirmed*** deposition dates (not just proposed dates). Any person not on that Report will presumptively not be deposed without good cause (e.g., genuine surprise despite due diligence). If deponents are slow in confirming deposition dates, the parties should use the Report deadline to urge each other and non-parties to provide confirmed dates to avoid a motion to compel in advance of the deadline. The Court will set any retained-expert schedule later. The Court encourages the parties to advance discovery promptly so that productive settlement discussions can happen. The tracking status hearing of 02/05/2021 is reset to 04/16/2021 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a joint discovery status report by 04/07/2021 (by then, the parties should have responded to the first-round of written discovery requests). Emailed notice (mw, ) |
| Filing 11 STATUS Report Joint Initial Status Report by Christine Hirsch (Terna, Lucas) |
| Filing 10 MINUTE entry before the Honorable Edmond E. Chang: Scott McLaughlin's and John Hays' motions for leave to appear pro hac vice for Defendant #6 #7 are granted. Emailed notice (mw, ) |
| Filing 9 ATTORNEY Appearance for Plaintiff Christine Hirsch by Lucas Broderick Terna (Terna, Lucas) |
| Filing 8 ATTORNEY Appearance for Plaintiff Christine Hirsch by Nicole Elizabeth DiOrio (DiOrio, Nicole) |
| Filing 7 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17867704. (Hays, John) |
| Filing 6 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17867497. (Attachments: #1 Appendix A)(McLaughlin, Scott) |
| Filing 5 MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 02/05/2021 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the attached status report requirements by 01/28/2021. Plaintiff must still file the report even if Defendant has not responded to requests to craft a joint report. If not all Defendant(s) have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice (mw, ) (Attachment #1 status report requirements) |
| Filing 4 Defendant's ANSWER to Complaint by Cognizant Technology Solutions U.S. Corp. (Attachments: #1 Exhibit Defendant's L.R.3.2 Notification as to Affiliates)(McCaffrey, Timothy) |
| Filing 3 MAILED Notice of Removal letter to counsel of record. (bg, ) |
| CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment. (acm, ) |
| Filing 2 CIVIL Cover Sheet (McCaffrey, Timothy) |
| Filing 1 NOTICE of Removal from Cook County Circuit Court, IL, case number (2020L050502) filed by Cognizant Technology Solutions U.S. Corp. Filing fee $ 402, receipt number 0752-17817143. (Attachments: #1 Exhibit A-State Court Pleadings, #2 Exhibit B-Declaration of N. Kamka)(McCaffrey, Timothy) |
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