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Report: #71780

Complaint Review: International Profit Associates - Buffalo Grove Illinois

  • Submitted:
  • Updated:
  • Reported By: Racine Wisconsin
  • Author Not Confirmed What's this?
  • Why?
  • International Profit Associates 1250 Barclay Boulevard Buffalo Grove, Illinois U.S.A.

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Chronology of Experience with International Profit Associates

November 13, 2003

October 23, 2003
Was visited by Mr. Mark Anderson, Senior Area Manager for IPA. He recommended that I sign up for a no risk business analysis to see if they could help me with marketing. My sales are down substantially, and I was open to concrete suggestions.

October 27, 2003
Ms. Marcella Rogers of IPA spent the better part of the day talking to me and my employees. She concluded that IPA could be of help. When I protested that I couldn't afford their services, she told me that they would work with me, and that I could pay off their fees a dollar a week over the rest of my life. She also did a quick cash flow analysis and concluded that I was in trouble and needed their help.

I reluctantly agreed to let their people come in and gave her a check for $300.00.

October 29, 2003
Mr. Joseph Krzeminski and Edward Tyranski, Jr. showed up to begin work. Mr. Tyranski spent the morning loading some financial data into Excel spreadsheets while Mr. Krzeminski copied language from our flyers into Word documents.

In the afternoon, Mr. Krzeminski had me take part in a brainstorming session. After briefly going over who my customers are, Mr. Krzeminski told me that IPA's program could cause me to increase my sales 30% by the end of next year and double them in three years.

Their program consisted of giving generic forms and instructions to my people and having them cold call customers from lists that IPA would provide based on SIC codes.

Mr. Krzeminski then informed me that he needed payment in full before they left for the day in the amount of $5634.00. I informed him of Ms. Rogers statement about IPA working with me. Mr. Krzeminski became very demanding and insisted that he have payment, even if it was in the form of post dated checks.

Mr. Tyranski then produced a cash flow analysis spreadsheet that showed I could pay them the entire $15,000 cost of the engagement by the end of November. He also said I would be broke before the end of the year if I didn't accept their help! $15,000 is more than 1/3 of my typical monthly billings. If I had that kind of positive cash flow, I would be in absolutely no danger of going out of business.

My employees are shop workers, not sales people. It is up to me to make the sales calls. I am fully capable of buying the same prospect lists on my own. They are readily available on-line. It was obvious that they had nothing to offer me. This engagement began to appear to me to be nothing but a scam. I decided to thank them and end the engagement.

Mr. Krzeminski became extremely agitated. He had me talk to someone at the home office who tried to convince me to give Mr. Krzeminski post dated checks by threatening to turn me over to legal. Mr. Krzeminski told me he wouldn't get paid anything for the engagement unless he received payment immediately. I informed him that this was not my problem, but asked why he would work for a firm that had such a policy. He had no answer to that question, but continued to demand payment. This is not what I consider working with me.

I eventually gave them a check for $500 with a promise to pay when I could to get them out of my office.

November 6, 2003
I heard from their collections department this afternoon. It's the same demand, full payment now in post dated checks. I refused. They told me they would begin charging me interest at 19.5% on my balance.

My embarrassment at having been scammed has been overcome by anger. I believe I was fraudulently induced into signing up for their services. These services were of questionable value at best. I not only don't feel I should pay what they say I owe them, but I want my $800 back.

Joseph
Racine, Wisconsin
U.S.A.

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REBUTTALS & REPLIES:
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#2 UPDATE EX-employee responds

read about the EEOC v IPA

AUTHOR: Tom - (U.S.A.)

POSTED: Tuesday, February 10, 2004

Docket as of February 9, 2004 8:42 pm

U.S. District Court

Northern District of Illinois (Chicago)

CIVIL DOCKET FOR CASE #: 01-CV-4427

EEOC v. Intl Profit Assc Inc

Filed: 06/12/01
Assigned to: Hon. Joan B. Gottschall
Jury demand: Plaintiff
Referred to: Hon. Morton Denlow
Demand: $0,000
Nature of Suit: 442
Lead Docket: None
Jurisdiction: US Plaintiff
Dkt# in other court: None
Cause: 42:2000e Job Discrimination (Employment)



EQUAL EMPLOYMENT OPPORTUNITY John C. Hendrickson
COMMISSION [COR]
plaintiff Gregory M. Gochanour
[COR]
Jeanne B. Szromba
[COR LD NTC A]
Ethan M.M. Cohen
[COR]
Diane Ilene Smason
[COR]
United States Equal Employment
Opportunity Commission
500 West Madison Street
Suite 2800
Chicago, IL 60661
(312) 353-7568

John W. Cooley
[NTC]
Attorney at Law
2106 Orrington Avenue
Evanston, IL 60201
(312) 328-7285

Ann M Henry
[COR]
Equal Employment Opportunity
Commission
500 W. Madison Street
2800
Chicago, IL 60661
(312)353-7722

RHONDA PORTER
intervenor plaintiff

v.

INTERNATIONAL PROFIT Myron M. Cherry
ASSOCIATES, INC. [COR NTC]
defendant Myron M. Cherry & Associates
30 North LaSalle Street
Suite 2300
Chicago, IL 60602
(312) 372-2100

Jennifer Anne Naber
[COR LD NTC A]
Violet M. Clark
[COR]
Laner, Muchin, Dombrow, Becker,
Levin & Tominberg, Ltd.
515 North State Street
Suite 2800
Chicago, IL 60610-4798
(312) 467-9800

Ronald Lee Bell
[term 09/25/02]
[COR LD NTC A]
Ronald L. Bell & Associates
1250 Barclay Blvd.
#100
Buffalo Grove, IL 60089
(847) 495-6000

Cary Neal Goldberg
[COR]
Law Offices of Cary N. Goldberg
30 North LaSalle Street
Suite 2300
Chicago, IL 60602
(312) 853-0494

========================

MARIAN TOWNSON Edward J. Moran
intervenor plaintiff [NTC]
Attorney at Law
3 First National Plaza
Suite 5330
Chicago, IL 60602
(312) 759-0505





DOCKET PROCEEDINGS



DATE # DOCKET ENTRY


6/12/01 1 COMPLAINT; Jury demand - Civil cover sheet - Appearances of
John C. Hendrickson, Gregory M. Gochanour, Diane Ilene
Smason, Jeanne B. Szromba as attorneys for plaintiff (No
summonses issued) (Documents: 1-1 through 1-3). (eb)
[Entry date 06/13/01] [1:01cv4427]


7/9/01 -- SCHEDULE set on 7/9/01 by Hon. Joan B. Gottschall : Status
hearing set to 9:30 8/16/01. Plaintiff is directed to
advise the defendants of the status hearing forthwith.
Parties are directed to discuss settlement of case, consent
to proceed before the Magistrate Judge and a proposed
discovery plan. See Judge Gottschall's civil case
management packet for important information about pretrial
case management procedures. This information is also
located on the court's website:
http://www.ilnd.uscourts.gov. Mailed notice (rj)
[Entry date 07/09/01] [1:01cv4427]


7/11/01 2 MOTION by plaintiff-intervenor Marian Townson to
intervene; Notice. (cm) [Entry date 07/19/01]
[1:01cv4427]


7/18/01 3 MINUTE ORDER of 7/18/01 by Hon. Joan B. Gottschall : Motion
by plaintiff-intervenor - Marian Townson to intervene [2-1]
with respect to her claim under Title VII pursuant to Rule
24(a)(1) of the FRCP and Section 706(f)(1) of Title VII of
the Civil Rights Act of 1964, as amended, 42 U.S.C. Section
2000e-5(f)(1) is granted. Mailed notice (cm)
[Entry date 07/19/01] [1:01cv4427]


7/18/01 4 WAIVER of service of summons as to defendant sent on
6/12/01. (cm) [Entry date 07/19/01] [1:01cv4427]


8/14/01 5 ATTORNEY APPEARANCE for defendant Intl Profit Assc Inc by
Ronald Lee Bell (rm) [Entry date 08/15/01] [1:01cv4427]


8/14/01 6 ANSWER by defendant Intl Profit Assc Inc to complaint
[1-1]; Notice (rm) [Entry date 08/15/01] [1:01cv4427]


8/16/01 -- SCHEDULE set on 8/16/01 by Hon. Joan B. Gottschall :
Status hearing held. Case is referred to Magistrate Judge
Denlow for discovery supervision and mediation. In court
notice (rj) [Entry date 08/16/01] [1:01cv4427]


8/16/01 7 EXPEDITED REFERRAL ORDER: Case referred to Hon. Morton
Denlow for discovery supervision, and mediation
Mailed notice. (rj) [Entry date 08/16/01] [1:01cv4427]


8/16/01 -- SCHEDULE set on 8/16/01 by Hon. Morton Denlow : Initial
status hearing set to 10:00 9/6/01 before Magistrate Judge
Morton Denlow in Courtroom 1350. Parties shall deliver a
copy of an initial status report to chambers, Room 1356, 3
business days before the initial status hearing. If the
parties have recently prepared and filed an initial status
report, the submission of the previously filed initial
status report is sufficient. Mailed notice (dmk)
[Entry date 08/16/01] [1:01cv4427]


8/31/01 8 JOINT INITIAL STATUS REPORT by plaintiff and defendant;
Notice (ip) [Entry date 09/04/01] [1:01cv4427]


9/4/01 -- SCHEDULE set on 9/4/01 by Hon. Morton Denlow : On request
of the parties, status hearing reset to 10:00 9/11/01.
Status hearing set for 9/6/01 is stricken. Mailed notice
(dmk) [Entry date 09/04/01] [1:01cv4427]


9/13/01 -- SCHEDULE set on 9/13/01 by Hon. Morton Denlow : Status
hearing reset to 10:00 9/25/01 . Mailed notice (dmk)
[Entry date 09/13/01] [1:01cv4427]


9/20/01 9 EMERGENCY MOTION by defendant for injunctive relief;
Affidavit by Ronald L. Bell (Attachments); Notice. (yp)
[Entry date 09/26/01] [1:01cv4427]


9/20/01 10 MINUTE ORDER of 9/20/01 by Hon. Joan B. Gottschall :
Defendant's motion for injunctive relief is denied [9-1] as
moot. All paties are to comply with the agreements set
forth on the record in open court. No notice (yp)
[Entry date 09/26/01] [1:01cv4427]


9/25/01 -- SCHEDULE set on 9/25/01 by Hon. Morton Denlow : Status
hearing H&C to 10:00 11/20/01 . Mailed notice (dmk)
[Entry date 09/25/01] [1:01cv4427]


9/26/01 11 JOINT MOTION by EEOC and plaintiff-intervenor Marian
Townson to reassign case 01 Cv 4428 (Attachments) ;
Notice (rm) [Entry date 10/04/01] [1:01cv4427]


10/3/01 12 MINUTE ORDER of 10/3/01 by Hon. Joan B. Gottschall :
Motion to reassign case 01 Cv 4428 [11-1] is taken under
advisement. This Court will issue an order detailing
procedural guidelines with reference to coordinating both
cases 01 C 4427 (Judge Gottschall) and 01 C 4428 (Judge
Castillo) for the purposes of coordinating discovery only.
Mailed notice (rm) [Entry date 10/04/01] [1:01cv4427]


10/10/01 13 MINUTE ORDER of 10/10/01 by Hon. Joan B. Gottschall :
Based upon the parties' statements to this court that they
do not wish to have the subject cases reassigned pursuant
to the court's relatedness rules, it appears that the
convenience of all parties will best be served by the entry
of a discovery coordination order. Judge Castillo has
before him a motion to transfer venue of this case. If the
motion is denied, this court and Judge Castillo will work
out such an order. If the motion is granted, this court
will, at the parties' request, initiate conversations with
the judge to whom the case is transferred to achieve the
same end. Mailed notice (rm) [Entry date 10/11/01]
[1:01cv4427]


10/15/01 14 AGREED MOTION by plaintiff and defendant for entry of
protective order; Notice (rm) [Entry date 10/17/01]
[1:01cv4427]


10/16/01 15 MINUTE ORDER of 10/16/01 by Hon. Morton Denlow : Agreed
motion for entry of protective order is granted [14-1].
(Entered stipulated protective order); Notice (rm)
[Entry date 10/17/01] [1:01cv4427]


11/1/01 16 MOTION by defendant for leave to file additional
appearance, instanter ; Notice. (lxs) [Entry date 11/08/01]
[1:01cv4427]


11/7/01 17 ATTORNEY APPEARANCE for defendant by Myron M. Cherry, Cary
Neal Goldberg. (lxs) [Entry date 11/08/01] [1:01cv4427]


11/7/01 18 MINUTE ORDER of 11/7/01 by Hon. Joan B. Gottschall : Motion
by International Profit Associates Inc. for leave to file
additional appearance of Myron M. Cherry and Cary Goldberg
is granted [16-1]. Mailed notice (lxs) [Entry date 11/08/01]
[1:01cv4427]


11/15/01 19 MOTION by plaintiff to compel interrogatory answers and
document production (Attachments); Notice (rm)
[Entry date 11/20/01] [1:01cv4427]


11/20/01 20 MINUTE ORDER of 11/20/01 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 a.m. on 12/20/01.,
Settlement conference held. Substantial progress made.
All pending motions are withdrawn without prejudide [11-1],
[19-1]. Notices mailed by judge's staff (rm)
[Entry date 11/20/01] [1:01cv4427]


11/20/01 21 MINUTE ORDER of 11/20/01 by Hon. Morton Denlow: Plaintiff
to submit written itemization of damages and settlement
demand by 12/11/01. Defendant to submit written settlement
offer by 12/18/01. Notices mailed by judge's staff (rm)
[Entry date 11/21/01] [1:01cv4427]


12/20/01 22 MINUTE ORDER of 12/20/01 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 1/15/02. Marian
Townson is granted leave to file an intervening complaint
on or before 1/18/02. The discovery schedule will be set
at the 1/15/02 status hearing. Notices mailed by judge's
staff (rm) [Entry date 12/21/01] [1:01cv4427]


12/26/01 24 MOTION by defendant Intl Profit Assc Inc to compel answers
to discovery requests; Notice (rm) [Entry date 01/10/02]
[1:01cv4427]


1/8/02 23 RESPONSE by plaintiff EEOC to defendant International
Profit Associates, Inc.'s motion to compel (Attachments);
Notice (rm) [Entry date 01/09/02] [1:01cv4427]


1/9/02 25 MINUTE ORDER of 1/9/02 by Hon. Morton Denlow : Status
hearing reset for 10:00 2/28/02. Motion hearing held.
Defendant International Profit Associates, Inc.'s motion
to compel answers to discovery requests is granted in part
and denied in part [24-1]. The EEOC is required to file
supplemental answers on or before 2/13/02 which: 1)
itemizes any out-of-pocket damages; and 2) provides a
general description of the nature of the emotional
distress, if any, caused by defendants conduct. (e.g.,
headaches, loss of sleep, loss of concentration) The EEOC
is not required to provide a dollar quantification of the
emotional distress damages. The EEOC shall also identify
5-10 representatives class members by 2/13/02. Status
hearing set for 1/15/02 is stricken. Notices mailed by
judge's staff (rm) [Entry date 01/10/02] [1:01cv4427]


1/17/02 26 COMPLAINT by intervenor plaintiff Marian Townson (rm)
[Entry date 01/18/02] [1:01cv4427]


1/22/02 27 MOTION by defendant Intl Profit Assc Inc to compel
plaintiff to produce certain documents (Attachments);
Notice (rm) [Entry date 01/29/02] [1:01cv4427]


1/28/02 28 MINUTE ORDER of 1/28/02 by Hon. Morton Denlow: Answer
brief to motion to compel plaintiff to produce certain
documents [27-1] due 2/19/02. Reply to answer brief due
3/1/02. Oral argument on motion to compel plaintiff to
produce certain documents [27-1] set for 10:30 3/14/02.
Plaintiff to give to Judge Denlow a copy of each type of
document that they are withholding for an in camera
insepction. Notices mailed by judge's staff (rm)
[Entry date 01/29/02] [1:01cv4427]


2/11/02 29 ANSWER by defendant Intl Profit Assc Inc and affirmative
defenses to plaintiff-intervenor's complaint; Notice.
[26-1] (hb) [Entry date 02/12/02] [1:01cv4427]


2/14/02 31 MOTION by plaintiff EEOC for an extension of time to
produce to defendant International Profit Associates, Inc.
summaries of class members' emotional damages ; Notice (rm)
[Entry date 02/21/02] [1:01cv4427]


2/19/02 30 RESPONSE by plaintiff to motion to defendant, International
Profit Associates, Inc.'s to compel plaintiff to produce
certain documents [27-1] (Attachments); Notice (rm)
[Entry date 02/20/02] [1:01cv4427]


2/20/02 32 MINUTE ORDER of 2/20/02 by Hon. Morton Denlow: Plaintiff
Equal Employment Opportunity Commission's motion for an
extension of time to 3/15/02 to produce to defendant
International Profit Associates, Inc. summaries of class
members' emotional damages is granted [31-1]. Notices
mailed by judge's staff (rm) [Entry date 02/21/02]
[1:01cv4427]


2/27/02 33 MOTION by defendant Intl Profit Assc Inc to compel in
camera documents (Attachment) ; Notice (rm)
[Entry date 03/01/02] [1:01cv4427]


2/28/02 34 MINUTE ORDER of 2/28/02 by Hon. Morton Denlow : Status
hearing held. Motion hearing held. Defendant's motion to
compel in camera documents to be produced to the court by
3/4/02 is granted [33-1]. Oral argument on motion to compel
plaintiff to produce certain documents [27-1] is reset for
8:45 3/13/02. Oral argument set for 3/14/02 is stricken.
Notices mailed by judge's staff (rm) [Entry date 03/01/02]
[1:01cv4427]


3/1/02 35 REPLY by defendant Intl Profit Assc Inc in support of its
motion to compel notes of interviews [27-1](Attachments);
Notice (rm) [Entry date 03/04/02] [1:01cv4427]


3/8/02 36 ATTORNEY APPEARANCE for plaintiff by Ethan M.M. Cohen, Ann
M Henry; Notice (rm) [Entry date 03/11/02] [1:01cv4427]


3/8/02 37 MOTION by defendant to amend protective order
(Attachments); Notice (ip) [Entry date 03/14/02]
[1:01cv4427]


3/12/02 38 MOTION by plaintiff for leave to file sur-reply instanter;
Notice (ip) [Entry date 03/14/02] [1:01cv4427]


3/13/02 39 MINUTE ORDER of 3/13/02 by Hon. Morton Denlow : Status
hearing set to 5/16/02 at 10:00 a.m. Oral argument held.
EEOC's motion for leave to file sur-reply instanter [38-1]
is granted. Defendant's motion to compel plaintiff to
produce certain documents [27-1] is taken under advisement.
Written ruling by mail on or by 3/27/02. Defendant's motion
to amend protective order [37-1] is granted to the extent
the parties agree and submit an amended protective order.
Mailed notices by judge's staff (ip) [Entry date 03/14/02]
[1:01cv4427]


3/13/02 40 SUR-REPLY by plaintiff in support of its opposition to
IPA's motion to compel plaintiff to produce certain
documents [27-1]; Declaration of Diane L. Smason (ip)
[Entry date 03/14/02] [1:01cv4427]


3/27/02 41 MINUTE ORDER of 3/27/02 by Hon. Morton Denlow: Defendant's
motion to compel plaintiff's production of interview notes
is denied [27-1]. Entered Memorandum Opinion and Order.
Notices mailed by judge's staff (rm) [Entry date 04/03/02]
[1:01cv4427]


4/25/02 42 MOTION by plaintiff to compel production of documents
prior to deposition (Attachments); Notice. (vj)
[Entry date 05/02/02] [1:01cv4427]


4/30/02 45 MOTION by EEOC to compel answers to EEOC's second set of
interrogatories (Attachments); Notice (rm)
[Entry date 05/09/02] [1:01cv4427]


5/1/02 43 MINUTE ORDER of 5/1/02 by Hon. Morton Denlow: Motion
hearing held. EEOC's motion to compel production of
documents prior to deposition is denied [42-1] except to
written policies, procedures and guidelines previously
submitted. Notices mailed by judge's staff (vj)
[Entry date 05/02/02] [1:01cv4427]


5/3/02 46 MOTION by defendant Intl Profit Assc Inc for protective
order (Attachments); Notice (rm) [Entry date 05/09/02]
[1:01cv4427]


5/7/02 44 RESPONSE by defendant Intl Profit Assc Inc to EEOC's motion
to compel answers to EEOC's second set of interrogatories
(Attachments). (rm) [Entry date 05/08/02] [1:01cv4427]


5/8/02 47 MINUTE ORDER of 5/8/02 by Hon. Morton Denlow: Motion
hearing held. EEOC's motion to compel answers to EEOC's
second set of interrogatories [45-1] is denied because
Interrogatory No. 12 was inartfully drafted. Defendant has
until May 29, 2002 to supplement Interrogatory No. 8.
Defendant's motion for a protective order [46-1] is denied
subject to the clarification made in open court. The
Parties shall each be allowed to take in excess of ten
depositions. The parties shall meet to agree on a number.
Notices mailed by judge's staff (rm) [Entry date 05/09/02]
[1:01cv4427]


5/16/02 48 MINUTE ORDER of 5/16/02 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 7/25/02. Ross Peters,
counsel for plaintiff in case 02 C 2790, is allowed to
become party to the current existing protective order in
this case. Fact discovery cutoff in case 02 C 2790 is
09/30/02. Rhonda Porter's deposition to be taken on or by
06/03/02. Time for defendant to supplement Interrogatory
No. 8 is extended to 06/10/02. Deendant to supplement
Interrogatory No. 8 with respect to deponent Williams by
05/20/02. Notices mailed by judge's staff (rm)
[Entry date 05/17/02] [1:01cv4427]


6/10/02 51 MOTION by defendant to compel more specific answers to
defendants first set of interrogatories four and five and
for attorney fees (Attachment) (RESTRICTED) (rm)
[Entry date 06/18/02] [1:01cv4427]


6/13/02 52 MOTION by plaintiff for order to show cause why defendant
should not be held in contempt (RESTRICTED) (rm)
[Entry date 06/18/02] [1:01cv4427]


6/13/02 53 MOTION by plaintiff EEOC for an order to show cause why
defendant should not be held in contempt (RESTRICTED) (rm)
[Entry date 06/18/02] [1:01cv4427]


6/14/02 49 RESPONSE by plaintiff EEOC to defendant International
Profit Associates, Inc.'s motion to compel more specific
answers to defenant's first set of interrogatories four and
five and for attorney fees (Attachments); Notice (rm)
[Entry date 06/17/02] [1:01cv4427]


6/14/02 50 Document Sealed (pursuant to Court Order) (RESTRICTED) (rm)
[Entry date 06/17/02] [1:01cv4427]


6/14/02 54 REPLY by defendant Intl Profit Assc Inc in support of
motion to compel more specific answers to defendants first
set of interrogatories four and five [51-1] (rm)
[Entry date 06/18/02] [1:01cv4427]


6/14/02 55 RESPONSE by Intl Profit Assc Inc to EEOC's motion for
order to show cause why defendant should not be held in
contempt [52-1] [53-1] (rm) [Entry date 06/18/02]
[1:01cv4427]


6/17/02 56 MINUTE ORDER of 6/17/02 by Hon. Morton Denlow: Motion
hearing held. Oral motion to extend the time to take the
deposition of Ms. Porter's on or by 7/31/02 is granted. Mr.
Cherry is to proceed first. Parties to complete deposition
in one sitting, if possible, subject to her physical
limitations. Defendant International Profit Associates,
Inc.'s motion to compel more specific answers to defendants
first set of interrogatories four and five [51-1] and for
attorney fees [51-2] is denied. Plaintiff EEOC's motion for
an order to show cause why defendant should not be held in
contempt [52-1], [53-1] is denied, however, defendant is to
supplement responses to Interrogatory #8 and Rule 26(a)
production on or before 7/1/02 with respect to no less than
20 claims. Enter agreed order sealing defendant's motion to
compel. (Entered agreed order.) Notices mailed by judge's
staff (rm) [Entry date 06/18/02] [1:01cv4427]


6/19/02 57 TRANSCRIPT of proceedings for the following date(s):
05/08/02 Before Honorable Morton Denlow (nf)
[Entry date 06/20/02] [1:01cv4427]


6/24/02 58 OBJECTIONS by defendant Intl Profit Assc Inc to Magistrate
Judge's Order, dated June 17, 2002 (Attachments); Notice (rm)
[Entry date 06/25/02] [1:01cv4427]


7/1/02 59 MOTION by plaintiff for an order holding defendant in
violation of the 10/16/01 protective order (RESTRICTED) (rm)
[Entry date 07/03/02] [Edit date 07/10/02] [1:01cv4427]


7/1/02 60 MOTION by plaintiff EEOC for an order holding defendant in
violation of the 10/16/01 protective order (Attachments);
Notice (rm) [Entry date 07/10/02] [1:01cv4427]


7/1/02 61 MOTION by plaintiff EEOC for an order holding defendant
in violation of the 10/16/01 protective order; Notice
(RESTRICTED) (rm) [Entry date 07/10/02] [1:01cv4427]


7/3/02 62 MOTION by EEOC for entry protective order (Attachments);
Notice (rm) [Entry date 07/10/02] [1:01cv4427]


7/3/02 63 MOTION by EEOC for entry of a protective order;
(RESTRICTED) (rm) [Entry date 07/10/02] [1:01cv4427]


7/3/02 64 EXHIBIT F by EEOC to motion for entry protective order
[62-1], [63-1] (RESTRICTED) (rm) [Entry date 07/10/02]
[1:01cv4427]


7/3/02 67 RESPONSE by plaintiff EEOC to defendant International
Profit Association Inc.'s objections to Magistrate Judge's
order, dated 6/17/02 [58-1] (Attachments); Notice (rm)
[Entry date 07/12/02] [1:01cv4427]


7/3/02 72 Document Sealed (pursuant to Court Order) (RESTRICTED) (rm)
[Entry date 07/16/02] [1:01cv4427]


7/9/02 65 MINUTE ORDER of 7/9/02 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 7/30/02. EEOC's motion
for entry protective order [62-1], [63-1] is granted in
part and denied in part. Defendant is only allowed to ask
deponents questions regarding drug use related to the
workplace. Defendant is only allowed to ask questions
regarding arrests and convictions admissible for
impeachment purposes. EEOC's motion limiting the time of
deposition of EEOC class members is denied without
prejudice. Plaintiff's motion for holding defendant in
violation of the 10/16/01 protective order [59-1] [60-1]
[61-1] is denied as stated in open court. Defendant is to
supplement responses to Interrogatory #8 with another 20
claims on or by 9/10/02. (Entered order sealing the
defendant IPA's response to EEOC's motion regarding
contempt.) Notices mailed by judge's staff (rm)
[Entry date 07/10/02] [1:01cv4427]


7/10/02 66 REPLY by Intl Profit Assc Inc to objections to Magistrate's
order of 6/17/02 [58-1] (rm) [Entry date 07/11/02]
[1:01cv4427]


7/10/02 68 MINUTE ORDER of 7/10/02 by Hon. Joan B. Gottschall: Enter
order on reverse side of original minute order. Defendant
Profit Associates, Inc. has timely filed objections to the
magistrate judge's order [56-1] denying defendant's motion
to compel more specific answers to defendant's first of
interrogatories four and five [51-1], and for attorney fees
[51-2]. For the reasons on the reverse of this minute
order, this court holds that the magistrate judge's order
is not clearly erroneous or contrary to law. The court
declines to modify or set aside the magistrate judge's
order. (See reverse of minute order.) Mailed notice (rm)
[Entry date 07/12/02] [1:01cv4427]


7/12/02 69 REDACTED OBJECTIONS by Intl Profit Assc Inc to Magistrate
Judge's order, dated 06/17/02 [56-1] (Attachments); Redacted
notice of filing; Notice of filing (ar)
[Entry date 07/15/02] [Edit date 07/15/02] [1:01cv4427]


7/12/02 70 REDACTED response by Intl Profit Assc Inc to EEOC's motion
regarding contempt [52-1] [53-1]; Notice (ar)
[Entry date 07/15/02] [1:01cv4427]


7/12/02 71 MOTION by Intl Profit Assc Inc to compel more specific
answers to defendant's first set for interrogatories Four
and five, and for attorney's fees (Attachment); Redacted
notice of motion; Notice of motion (ar)
[Entry date 07/15/02] [1:01cv4427]


7/16/02 73 EMERGENCY MOTION by EEOC for an order to show cause why
IPA should not be held in contempt (RESTRICTED) (rm)
[Entry date 07/18/02] [1:01cv4427]


7/17/02 74 EMERGENCY MOTION by plaintiff EEOC for and order to show
cause why defendant should not be held in contempt
(Attachments); Notice [Redacted] (rm) [Entry date 07/18/02]
[1:01cv4427]


7/17/02 75 RESPONSE by Intl Profit Assc Inc to plaintiff's emergency
motion regarding (Attachments); Restricted documents
pursuant to LR26.2 (Attachments) [Redacted} (rm)
[Entry date 07/18/02] [1:01cv4427]


7/17/02 76 MINUTE ORDER of 7/17/02 by Hon. Morton Denlow: Oral
argument held. Plaintiff EEOC's emergency motion for an
order to show cause why defendant should not be held in
contempt [73-1] [74-1] is denied, however, defendant is
required to explain its position in response to allegations
of paragraphs 10a thru 10g 13, 14, 15, and 16 of Rhonda
Porters complaint. Case No. 02 C 2790, ad discovery. Such
answer to be delivered to plaintiff's counsel and EEOC by
fax on or before the close of business 7/19/02. Notices
mailed by judge's staff (rm) [Entry date 07/18/02]
[1:01cv4427]


7/24/02 77 TRANSCRIPT of proceedings for the following date(s):
6/17/02 before Honorable Magistrate Judge Morton Denlow (rm)
[Entry date 07/25/02] [1:01cv4427]


7/25/02 78 MOTION by plaintiff EEOC to compel defendant IPA to
supplement its response to EEOC interrogatory No. 2
(Attachments); Notice (rm) [Entry date 07/31/02]
[1:01cv4427]


7/30/02 79 MINUTE ORDER of 7/30/02 by Hon. Morton Denlow : Status
hearing held and continued to 10:09 12/5/02. Motion
hearing held. For reasons stated in open court, plaintiff,
EEOC's motion to compel defendant IPA to supplement its
response to EEOC interrogatory No. 2 is denied [78-1].
Deendant is to supplement responses to Interrogatory No. 8
with another 20 claims on or by 11/12/02. Notices mailed by
judge's staff (rm) [Entry date 07/31/02] [1:01cv4427]


8/7/02 80 MOTION by defendant for protective order; Notice. (air)
[Entry date 08/13/02] [1:01cv4427]


8/12/02 81 TRANSCRIPT of proceedings for the following date(s):
05/16/02 Before Honorable Morton Denlow. (air)
[Entry date 08/13/02] [1:01cv4427]


8/12/02 82 MINUTE ORDER of 8/12/02 by Hon. Morton Denlow: Motion
hearing held. Defendant's motion for protective order
[80-1] is entered and continued to 9:15 a.m. on 8/21/02.
All attorneys are to read the Seventh Circuit Standard for
Professional Conduct, in particular, Lawyers Duty to other
Counsel. All counsel are to certify in writing on or by
8/21/02 that they have read the Standards for Professional
Conduct and believe that their conduct in the discovery
phase of this case complies with the requirements of the
Seventh Circuit. Notice mailed by judge's staff (air)
[Entry date 08/13/02] [1:01cv4427]


8/19/02 83 CERTIFICATION OF COUNSEL by defendant's counsel; Notice.
(air) [Entry date 08/20/02] [1:01cv4427]


8/19/02 84 MINUTE ORDER of 8/19/02 by Hon. Morton Denlow: Defendant's
motion for protective order [80-1] filed 8/7/02 is
withdrawn. Hearing on defendant's motion for protective
order [80-1] set for 8/21/02 is stricken. (Entered Order.)
Notice mailed by judge's staff (air) [Entry date 08/20/02]
[1:01cv4427]


8/21/02 85 CERTIFICATION by Jeanne B Szromba (rm) [Entry date 08/22/02]
[1:01cv4427]


8/21/02 86 CERTIFICATION by Ann Henry (rm) [Entry date 08/22/02]
[1:01cv4427]


8/21/02 87 CERTIFICATION by Diane I Smason; Notice (rm)
[Entry date 08/22/02] [1:01cv4427]


9/9/02 88 MOTION by defendant Intl Profit Assc Inc to withdraw as
counsel the law firm of Ronald L. Bell & Associates, P.C.;
Notice (rm) [Entry date 09/26/02] [1:01cv4427]


9/25/02 89 MINUTE ORDER of 9/25/02 by Hon. Joan B. Gottschall: Filed
motion by plaintiff to intervene and other relief.
Plaintiff's reply to IPA's opposition to plaintiff's motion
to intervene is due 10/9/02. Motion of the law firm of
Ronald L. & Associates, P.C. for leave to withdraw as
attorney for the defendant, International Profit
Associates, Inc., is granted [88-1]. Mailed notice (rm)
[Entry date 09/26/02] [1:01cv4427]


9/27/02 92 MOTION by Intl Profit Assc Inc for leave to file a
supplemental opposition to plaintiff's motion to intervene
(Attachments); Notice (rm) [Entry date 10/08/02]
[1:01cv4427]


10/3/02 90 RESPONSE by plaintiff EEOC in support of Rhonda Porter's
motion to intervene (Attachments); Notice (rm)
[Entry date 10/04/02] [1:01cv4427]


10/4/02 93 MINUTE ORDER of 10/4/02 by Hon. Joan B. Gottschall :
Motion by defendant, International Profit Association, Inc.
for leave to file a supplemental opposition to plaintiff's
motion to intervene is granted [92-1]. Mailed notice (rm)
[Entry date 10/08/02] [1:01cv4427]


10/7/02 91 REPLY brief by Rhonda Porter in support of the motion to
intervene (Attachments); Notice (rm) [Entry date 10/08/02]
[1:01cv4427]


10/7/02 94 LETTER from Ross J Peters to Judge Gottschall dated 10/7/02
(rm) [Entry date 10/08/02] [1:01cv4427]


10/16/02 95 TRANSCRIPT of proceedings for the following date(s):
7/30/02 before Honorable Morton Denlow. (rm)
[Entry date 10/17/02] [1:01cv4427]


10/21/02 97 MOTION by EEOC to compel production of certain pre-1997
documents, and to supplement to its earlier production of
personnel files (Attachments); Notice (rm)
[Entry date 10/29/02] [1:01cv4427]


10/21/02 98 MOTION by EEOC to set a discovery cutoff date; Notice (rm)
[Entry date 10/29/02] [1:01cv4427]


10/22/02 99 AMENDED NOTICE by EEOC of motion to set a discovery cutoff
date [98-1] (rm) [Entry date 10/29/02] [1:01cv4427]


10/22/02 100 AMENDED NOTICE by EEOC of motion to compel production of
certain pre-1997 documents [97-1] and to supplement to its
earlier production of personnel files [97-2] (rm)
[Entry date 10/29/02] [1:01cv4427]


10/25/02 96 ATTORNEY APPEARANCE for unknown Phyllis Lopez by Ross J.
Peters (rm) [Entry date 10/28/02] [1:01cv4427]


10/28/02 101 MINUTE ORDER of 10/28/02 by Hon. Morton Denlow: Plaintiff's
motion to compel [71-1] is granted as follows: Defendant
to provide an affidavit on or before 11/14/02 confirming
that no documents have been removed from the personnel
files of the alleged harassers. Defendants to produce
updated personnel files on the alleged harassers 14 days
prior to their deposition or one date prior to the close of
discovery in event that their depositions are to be taken.
Plaintiff's motion to set discovery cutoff is granted
[98-1]. The discovery cut-off date is set for 12/31/03.
Expert disclosures and expert report to be produced by
10/31/03. Expert depositions by 12/31/03. Defendant is to
supplement responses to interrogatorrry #8 with another 20
claims on or by 1/31/03 [97-2]. Firm dates. Mailed notice
(rm) [Entry date 10/29/02] [1:01cv4427]


11/12/02 102 OBJECTIONS by plaintiff EEOC to Magistrate Judge's order
setting a discovery cutoff date (Attachments); Notice (rm)
[Entry date 11/13/02] [1:01cv4427]


11/15/02 103 RESPONSE by Intl Profit Assc Inc to plaintiff EEOC's
objection to Magistrate Judge's order setting a discovery
cut-off date [102-1]; Notice (rm) [Entry date 11/15/02]
[1:01cv4427]


11/19/02 108 MOTION by defendant Intl Profit Assc Inc to compel EEOC to
produce all tapes and other documents; Notice (rm)
[Entry date 12/02/02] [1:01cv4427]


11/19/02 109 MOTION by defendant Intl Profit Assc Inc to strike new
class members identified in interogatory answer supplements
; Notice (rm) [Entry date 12/02/02] [1:01cv4427]


11/19/02 110 MOTION by defendant Intl Profit Assc Inc for protective
order (rm) [Entry date 12/02/02] [1:01cv4427]


11/21/02 104 REPLY by plaintiff EEOC in support of its objections to
Magistrate Judge's order setting a discovery cutoff date
[102-1]; Notice (rm) [Entry date 11/25/02] [1:01cv4427]


11/21/02 111 AMENDED NOTICE by defendant of motion to compel EEOC to
produce all tapes and other documents [108-1] (rm)
[Entry date 12/02/02] [1:01cv4427]


11/21/02 112 AMENDED NOTICE by defendant Intl Profit Assc Inc of motion
for protective order [110-1] (rm) [Entry date 12/02/02]
[1:01cv4427]


11/21/02 113 AMENDED NOTICE by defendant Intl Profit Assc Inc of motion
to strike new class members identified in interogatory
answer supplements [109-1] (rm) [Entry date 12/02/02]
[1:01cv4427]


11/25/02 105 RESPONSE by plaintiff EEOC to defendant International
Profit Associates, Inc.'s motion for protective order (rm)
[Entry date 11/26/02] [1:01cv4427]


11/25/02 106 RESPONSE by plaintiff EEOC to IPA's motion to strike new
class members (rm) [Entry date 11/26/02] [1:01cv4427]


11/25/02 107 RESPONSE by plaintiff EEOC to International Profit
Associates, Inc.'s motion to compel (Attachments); Notice
(rm) [Entry date 11/26/02] [1:01cv4427]


11/27/02 114 MINUTE ORDER of 11/27/02 by Hon. Morton Denlow : Status
hearing reset for 10:00 1/16/03. Defendant's motion to
compel EEOC to produce all tapes and other documents not
produced is granted. motion for protective order is denied
[108-1]. Plaintiff No. 111 is ordered to produce any tapes
in her possession arising out of her employment on or by
12/4/02. Defendant's request for fees and costs is denied.
Defendant's motion for protective order is denied [110-1].
Defendant's motion to strike new class members identified
in interogatory answer supplements of 11/13/02 [109-1] is
granted without prejudice. EEOC is no longer permitted to
add any new class members. Status hearing set for 12/5/02
is stricken. Notices mailed by judge's staff (rm)
[Entry date 12/02/02] [1:01cv4427]


12/5/02 115 MOTION by defendant Intl Profit Assc Inc to compel
plaintiff to immediately produce all transcripts and tapes
, and for other relief (Attachments); Notice (rm)
[Entry date 12/10/02] [1:01cv4427]


12/6/02 116 RESPONSE by plaintiff, EEOC to IPA"s motion to compel
plaintiff to immediately produce all transcripts and tapes
[115-1], and for other relief [115-2] (Attachments) (rm)
[Entry date 12/10/02] [1:01cv4427]


12/9/02 117 MINUTE ORDER of 12/9/02 by Hon. Morton Denlow: Motion
hearing held on defendant Internatinal Profit Associates,
Inc.'s motion to compel plaintiff to immediately produce
all transcripts and tapes [115-1] and for other relief
[115-2]. Defendant's motion to compel seeking immediate
production is denied as moot. Defendant's motion for other
relief is denied. Notices mailed by judge's staff (rm)
[Entry date 12/10/02] [1:01cv4427]


12/9/02 119 MOTION by EEOC for reconsideration of this court's
11/27/2002 order (Attachments); Notices (rm)
[Entry date 12/17/02] [1:01cv4427]


12/11/02 118 RESPONSE by Intl Profit Assc Inc., to EEOC's motion for
reconsideration of the 11/27/02 order; Notice (rm)
[Entry date 12/12/02] [1:01cv4427]


12/12/02 120 MOTION by EEOC to compel defendant to respond to discovery
requests (Attachments); Notice (rm) [Entry date 12/17/02]
[1:01cv4427]


12/12/02 121 REPLY by EEOC in support of its motion for reconsideration
of this court's 11/27/2002 order [119-1] (Attachments) (rm)
[Entry date 12/17/02] [1:01cv4427]


12/16/02 122 MINUTE ORDER of 12/16/02 by Hon. Morton Denlow : Status
hearing set for 10:00 on 3/25/2003. Motion hearing held
on plaintiff's motion for reconsideration and plaintiff's
motion to compel. For reasons stated in open court,
Plaintiff's motion for reconsideration of this court's
11/27/2002 order is granted [119-1]. EEOC is to identy all
alleged class members to defendant on or by 6/30/2003.
EEOC's motion to compel [120-1] is granted in part and
denied in part as follows: Plaintiff's motion to compel
production of relevant information about sex harassment
allegation in response to EEOC Interrogatory Nos. 4,5, and
8 is denied based on defense counsel's representation.
EEOC's motion for production of complaint of sex harassment
since May, 2002 is granted. Complaints of sex harassment
Since May 2002 are to be produced on a quarterly basis with
the first production to start 1/6/2003. EEOC's motion to
produce John Burgess for his deposition is granted. John
Burgess to be produced for his deposition no later than
3/17/2003. Deposition date to be agreed upon by 12/20/2002.
Status hearing set for 1/16/2003 is stricken. Notices
mailed by judge's staff (rm) [Entry date 12/17/02]
[1:01cv4427]


1/2/03 123 MINUTE ORDER of 1/2/03 by Hon. Joan B. Gottschall: The
order to which plaintiff EEOC has objected is a discovery
scheduling order, setting a discovery cutoff date of
12/31/03, rather than 3/28/03, as plaintiff requested, or
3/28/04, as defendant requested. This order may be
reconsidered only if it is shown to be "clearly erroneous or
contrary to law." 28 U.S.C. Section 636(b)(1)(A). It is
neither. It is rather a careful adjustment of the parties'
competing needs and demands. The objections are overruled.
(See reverse of minute order.) Mailed notice (rm)
[Entry date 01/06/03] [Edit date 01/22/03] [1:01cv4427]


1/22/03 124 TRANSCRIPT of proceedings for the following date(s):
12/16/02 before Honorable Morton Denlow (rm)
[Entry date 01/23/03] [1:01cv4427]


1/31/03 129 MOTION by defendant to strike alleged class member and for
other relief; Notice (cdy) [Entry date 02/13/03]
[1:01cv4427]


1/31/03 130 MOTION by defendant to compel verified interrogatory
answers (cdy) [Entry date 02/13/03] [1:01cv4427]


1/31/03 131 MOTION by defendant to compel affidavits of compliance
with request for documents, and other items (cdy)
[Entry date 02/13/03] [1:01cv4427]


1/31/03 133 MOTION by defendant to strike four alleged class members
and for other relief (cdy) [Entry date 02/13/03]
[1:01cv4427]


1/31/03 134 MOTION by defendant to compel deposition (cdy)
[Entry date 02/13/03] [1:01cv4427]


1/31/03 135 MOTION by defendant to close alleged class (cdy)
[Entry date 02/13/03] [1:01cv4427]


2/4/03 132 MOTION by defendant to strike alleged class member no. 45
; Notice (cdy) [Entry date 02/13/03] [1:01cv4427]


2/10/03 126 JOINT RESPONSE by plaintiff EEOC and intervenor plaintiff
Marian Townson to IPA's motion to compel deposition
(Attachments); Notice (rm) [Entry date 02/12/03]
[1:01cv4427]


2/10/03 127 MOTION by plaintiff EEOC to terminate Class Member 111's
deposition with response (Attachments) (rm)
[Entry date 02/12/03] [1:01cv4427]


2/10/03 127 RESPONSE by plaintiff EEOC to defendant IPA's motion to
strike class member 111 with motion (Attachments) (rm)
[Entry date 02/12/03] [1:01cv4427]


2/10/03 128 EXHIBIT B by plaintiff EEOC to motion to terminate Class
Member 111's deposition [127-1] and response to defendant
IPA's motion to strike Class Member 111 [127-1]
(RESTRICTED) (rm) [Entry date 02/12/03] [1:01cv4427]


2/11/03 125 TRANSCRIPT of proceedings for the following date(s):
11/27/02 before Honorable Morton Denlow (2 vols: 125-1,
125-2) (rm) [Entry date 02/12/03] [1:01cv4427]


2/12/03 136 MINUTE ORDER of 2/12/03 by Hon. Morton Denlow: Motion
hearing held. For reasons stated in open court: IPA's
[129-1], is denied. EEOC's motion to terminate Class Member
111's deposition [127-1], is granted. EEOC's motion for
protective order is granted. IPA's motion to compel
verified interrogatory answers [130-1], is denied. IPA's
motion to compel affidavits of compliance with request for
documents [131-1] and other items [131-2], is denied. EEOC
request for protective order of class member #105 is
denied. IPA's motion to strike four alleged class members
#33, 37, 73 and 141 [133-1], is denied. Defendant IPA's
motion to strike alleged class member no. 45 [132-1], is
denied. Defendant IPA's motion to compel deposition
[134-1], is denied. Defendant IPA's motion to close alleged
class [135-1], is denied. (See reverse of minute order.)
Notices mailed by judge's staff (cdy) [Entry date 02/13/03]
[1:01cv4427]


2/18/03 138 MOTION by defendant Intl Profit Assc Inc to strike alleged
class members Nos. 13 and 16 (Attachments); Notice (rm)
[Entry date 02/26/03] [1:01cv4427]


2/19/03 139 MOTION by defendant Intl Profit Assc Inc to strike alleged
class member No. 84 and for other relief; Notice (rm)
[Entry date 02/26/03] [1:01cv4427]


2/20/03 137 RESPONSE by plaintiff to defendant's motion to strike
alleged class members nos. 13 and 16 and response
(Attachment). (air) [Entry date 02/21/03] [1:01cv4427]


2/20/03 137 RESPONSE by plaintiff to defendant's motion to strike
alleged class member no. 84 and response (Attachment). (air)
[Entry date 02/21/03] [1:01cv4427]


2/24/03 140 MINUTE ORDER of 2/24/03 by Hon. Morton Denlow : Motion
hearing held on defendant's motion to strike alleged class
member Nos. 13 and 16 and defendant's motion to strike
alleged class member No. 84 and for other relief.
Defendant's motion to strike alleged class members Nos. 13
is granted in part and denied in part [138-1]. Class member
No. 13 is dismissed from the class for failure to appear
for deposition. Plaintiff to be reinstated to class upon
reimbursement to defendant of $750.00 in attorney fees by
3/14/03 and a date certain is set for the deposition.
Defendant's motion to strike alleged class member No. 16 is
denied. Defendant's motion to strike alleged class member
No. 84 is granted in part and denied in part [139-1].
Class member No. 84 is dismissed from the class for failure
to appear for deposition. Plaintiff to be reinstated to
class upon reimbursement to defendant of $300.00 in
attorney fees by 3/14/03 and a date certain is set for the
deposition. Plaintiff to pay the court reporter fees for
Class members No. 13 and No. 84 cancelled deposition.
Notices mailed by judge's staff (rm) [Entry date 02/26/03]
[1:01cv4427]


2/26/03 142 LETTER from defendant Intl Profit Assc Inc to Judge Denlow
dated 2/26/03 (rm) [Entry date 03/04/03] [1:01cv4427]


2/26/03 143 MOTION by defendant Intl Profit Assc Inc to quash subpoena
(Attachments); Notice (rm) [Entry date 03/04/03]
[1:01cv4427]


2/27/03 141 RESPONSE by plaintiff EEOC to IPA's motion to quash
subpoena (Attachments) (rm) [Entry date 02/28/03]
[1:01cv4427]


3/3/03 144 MINUTE ORDER of 3/3/03 by Hon. Morton Denlow: Motion
hearing held on defendant's motion to quash subpoena. For
the reasons stated in open Court, defendant's motion to
quash subpoena is denied [143-1]. No notice (rm)
[Entry date 03/04/03] [1:01cv4427]


3/17/03 145 MOTION by EEOC to compel response to 13th request for
production of documents ; (Attachments) (rm)
[Entry date 03/26/03] [Edit date 03/26/03] [1:01cv4427]


3/19/03 149 RESPONSE by defendant to EEOC's motion to compel production
of certain pre-1997 documents [97-1]; Notice. (jmp)
[Entry date 04/01/03] [1:01cv4427]


3/20/03 146 MOTION by EEOC to compel production of James Colello
documents (Attachments); Notice (rm) [Entry date 03/26/03]
[Edit date 03/26/03] [1:01cv4427]


3/24/03 147 EMERGENCY MOTION by plaintiff EEOC for a protective order
(Attachment); Notice (rm) [Entry date 03/26/03]
[Edit date 03/26/03] [1:01cv4427]


3/25/03 148 MINUTE ORDER of 3/25/03 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 6/26/03. Motion
hearing held on EEOC's motion to compel, EEOC's motion to
compel production of James Coiello documents and EEOC's
emergency motion for a protective order. EEOC's motion to
compel [145-1] is granted as follows: Defendant to produce
any additional sexual harassment complaints and
dispositions thereof found in the 15 personal files
referred to in the thirteenth request for production of
documents. EEOC's motion to compel James Coiello documents
[146-1] is denied based on counsel's representation that
all documents related to the sexual harassment complaint
and problems in the human resources department relating to
the sexual harassment complaint have been produced. For
reasons stated in open Court, EEOC's emergency motion for a
protective order [147-1] is denied. Mailed notice (rm)
[Entry date 03/26/03] [1:01cv4427]


4/1/03 150 OBJECTIONS by plaintiff EEOC to Magistrate Judge's denial
of emergency motion for a protective order (Attachments);
Notice (rm) [Entry date 04/02/03] [1:01cv4427]


4/3/03 151 RESPONSE by defendant Intl Profit Assc Inc to EEOC's
objections to denial of emergency motion for protective
order [150-1]; Notice (rm) [Entry date 04/04/03]
[1:01cv4427]


4/18/03 153 MOTION by Intl Profit Assc Inc for protective order;
Notice (rm) [Entry date 04/24/03] [1:01cv4427]


4/21/03 152 RESPONSE by EEOC to defendant's motion for protective order
(Attachments); Notice (rm) [Entry date 04/22/03]
[1:01cv4427]


4/23/03 154 MINUTE ORDER of 4/23/03 by Hon. Morton Denlow : Motion
hearing held on defendant's motion for protective order.
For reasons stated in open court, Defendant's motion for
protective order is denied [153-1]. No notice (rm)
[Entry date 04/24/03] [1:01cv4427]


4/23/03 155 MINUTE ORDER of 4/23/03 by Hon. Joan B. Gottschall : This
court sets aside Magistrate Judge Denlow's ruling denying
EEOC's motion for a protective order and grants the motion
for a protective order [147-1]. (Entered order.) Mailed
notice (rm) [Entry date 04/24/03] [1:01cv4427]


5/22/03 156 TRANSCRIPT of proceedings for the following date(s):
03/25/03 Before Honorable Morton Denlow (gy)
[Entry date 05/23/03] [1:01cv4427]


6/2/03 158 MOTION by defendant to strike two alleged class members
(Attachments); Notice (ls) [Entry date 06/10/03]
[1:01cv4427]


6/5/03 157 RESPONSE by plaintiff to defendant International Profit
Associates, Inc.'s motion to strike two alleged class
members (Attachment). (km) [Entry date 06/09/03]
[1:01cv4427]


6/9/03 159 MINUTE ORDER of 6/9/03 by Hon. Morton Denlow : Status
hearing held and continued to 7/15/03 at 10:00 a.m. Motion
hearing held on defendant's motion to strike two alleged
class members. For reasons stated in open court,
defendant's motion to strike two alleged class members is
denied [158-1]. Status hearing set for 6/26/03 is stricken.
Mailed notice (ls) [Entry date 06/10/03] [1:01cv4427]


6/10/03 160 TRANSCRIPT of proceedings for the following date(s): Held
on 9/25/02 before Honorable Morton Denlow. (cm)
[Entry date 06/11/03] [1:01cv4427]


7/15/03 -- SCHEDULE set on 7/15/03 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 10/9/03. Mailed notice
(dmk) [Entry date 07/15/03] [1:01cv4427]


9/2/03 161 MOTION by intervenor plaintiff Rhonda Porter to spread the
death of recording Rhonda Porter, and to appoint Antonio
Porter as administrator of her estate for the purposes of
this lawsuit pursuant to Federal Rule of Civil Procedure 25
(Attachments); Notice (rm) [Entry date 09/09/03]
[1:01cv4427]


9/5/03 162 MINUTE ORDER of 9/5/03 by Hon. Joan B. Gottschall: Motion
by counsel for Intervenor Rhonda Porter to spread the death
of recording Rhonda Porter [161-1] and to appoint Antonio
Porter as administrator of her estate for the purposes of
this pursuant to Federal Rule of Civil Procedure 25 [161-2]
is granted. Mailed notice (rm) [Entry date 09/09/03]
[1:01cv4427]


10/9/03 -- SCHEDULE set on 10/9/03 by Hon. Morton Denlow : Status
hearing held and continued to 10:00 1/6/04. Defendants
counsel to notify Plaintiffs counsel on or by 10/31/03 on
whether they intend to retain experts. Expert report due on
or by 12/15/03. Plaintiff to submit written itemization of
damages and settlement demand by 11/28/03. Defendant to
submit written settlement offer by 12/15/03. Mailed notice
(dmk) [Entry date 10/09/03] [1:01cv4427]


10/15/03 163 TRANSCRIPT of proceedings for the following date(s):
10/9/03 before Honorable Morton Denlow. (rm)
[Entry date 10/16/03] [1:01cv4427]


10/17/03 164 MOTION by defendant Intl Profit Assc Inc to reconsider
(Attachments); Notice (rm) [Entry date 10/30/03]
[1:01cv4427]


10/29/03 165 MINUTE ORDER of 10/29/03 by Hon. Morton Denlow: Motion
hearing held on defendant's motion to reconsider.
Defendant's motion to reconsider is denied as stated in
open court [164-1]. Notices mailed by judge's staff (rm)
[Entry date 10/30/03] [1:01cv4427]


11/5/03 166 OBJECTIONS by defendant Intl Profit Assc Inc to Magistrate
Judge's orders dated October 9 and October 29, 2003 [165-1]
(Attachments); Notice (rm) [Entry date 11/06/03]
[1:01cv4427]


11/10/03 167 EMERGENCY MOTION by defendant Intl Profit Assc Inc for rule
to show cause (Attachments); Notice (rm)
[Entry date 11/13/03] [Edit date 11/13/03] [1:01cv4427]


11/12/03 168 MINUTE ORDER of 11/12/03 by Hon. Morton Denlow: Motion
hearing held on Defendant IPA's emergency motion for rule
to show cause. Defendant IPA's emergency motion for rule to
show cause is granted [167-1]. Mr. James F. Colello is
ordered to appear for his deposition on or by 11/21/03. If
James F. Colello fails to appear for his deposition by
11/12/03, James F. Colello will be barred from testifying
at trial and will be barred from submitting any affidavits
in connection with motions that may be filed. Notices
mailed by judge's staff (rm) [Entry date 11/13/03]
[1:01cv4427]


11/13/03 169 RESPONSE by EEOC to Defendant International Profit
Associates, Inc.'s objections to Magistrate Judge's orders
dated October 9 and October 29, 2003 [166-1] (Attachments)
(rm) [Entry date 11/14/03] [1:01cv4427]


11/17/03 170 MINUTE ORDER of 11/17/03 by Hon. Morton Denlow : Motion
hearing held on defendant's emergency motion regarding
subpoenaed witness James Colello. Defendant's emergency
motion regarding subpoenaed witness James Colello is
granted. James Colello is ordered to appear for his
deposition on 11/23/03 at 9;30 a.m. at the offices of Myron
M. Cherry & Associates, LLC, 30 North LaSalle Street, Suite
2300, Chicago, IL 60602. Mailed notice by judge's staff (eav)
[Entry date 11/18/03] [1:01cv4427]


11/17/03 171 MOTION by defendant to compel more specific answers to
defendant's interrogatories (Attachments); Notice (rm)
[Entry date 11/20/03] [1:01cv4427]


11/17/03 172 MOTION by Intl Profit Assc Inc to compel documents from
James F. Colello (Attachments); Notice (rm)
[Entry date 11/20/03] [Edit date 11/20/03] [1:01cv4427]


11/18/03 173 MOTION by EEOC to compel information related to IPA's
expert witnesses, and for additional time for the
completion of expert discovery (Attachments); Notice (rm)
[Entry date 11/20/03] [1:01cv4427]


11/18/03 184 SUPPLEMENT by EEOC to motion for entry of protective order
(Attachments); Notice (rm) [Entry date 12/04/03]
[1:01cv4427]


11/19/03 174 MINUTE ORDER of 11/19/03 by Hon. Morton Denlow : Motion
hearing held. Defendant's motion to compel documents

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#1 Consumer Suggestion

literally hundreds of reports of Businesses that were Ripped off By this Company

AUTHOR: T - (U.S.A.)

POSTED: Friday, February 06, 2004

I do not know how International Profit Associates has managed to stay in business, I have found literally hundreds of reports of Businesses that were Ripped off By this Company. I think there should be a Federal investigation into this company and their claims and maybe interviewing their supposed 100,000 clients. I am having a hard time figuring out how to go about that. Most their clients are probably out of business, as I would be close to if I had not caught on to their lies. Now they are demanding payment of expenses. But will not supply any receipts or anything.
They have all my company information, and I worry how this kind of company might use this to further cheat me and my employees. Hopefully enough people will be able to report them that something will be done. they have 450 BBB reports , and the Illinois Attorney General's Office has at least 99 filed complaints against this company, and I am looking into other reports that many people responded to the INC 500 June report with Complaints, and greivances.

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