On Tuesday, Magistrate Judge Francis issued a Report and Recommendation to Judge Torres in which he recommended  denying class certification in a gender bias case against Goldman Sachs.  The plaintiffs allege that Goldman’s practices of “360 Reviews” (employee reviews by peers, subordinates and superiors) and “quartiling” (requiring managers to rank their employees by placing them in groups, or “quartiles,” from best to worst performers) discriminate against women. Judge Francis found that individualized causation and damages issues were too predominate for classwide treatment:…
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