IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION JUDGE KOCORAS

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

MAGISTRATE JUDGE LEVIN

)

CIVIL ACTION NO.

Plaintiff,

)

v.

) )

Ole

7037

)

OUTSOURCING SOLUTIONS

)

COMPLAINT

INCORPORATED and OSI COLLECTION )

SERVICES, INC.,

)

c

Defendants.

)

JURY TRIAL DEMAN:[

)

L

) )
NATURE OF THE ACTION

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This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil

Rights Act of 1991 to correct unlawful employment practices on the basis of retaliation, and to

provide appropriate relief to Katrina Malone ("Malone"), an employee of Defendants

Outsourcing Solutions Incorporated ("OSI") and OSI Collection Services, Inc. ("OSICS"), and a

class of employees who were adversely affected by such practices. As alleged with greater

particularity in paragraph nine (9) below, OSI and OSICS discriminated against Malone by

retaliating against her for her participation in Title VII litigation. OSI and OSICS also

discriminated against a class of employees by retaliating against them for their participation in

Title VII litigation or their opposition to violations of Title VII.

JURISDICTION AND VENUE

1. Jurisdiction of this court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,

1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(I) and (3) ("Title

VII").

2. The employment practices alleged to be unlawful were and are now being

committed within the jurisdiction ofthe United States District Court for the Northern District of

Illinois, Eastern Division.

PARTIES

3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is

the agency of the United States of America charged with the administration, interpretation and

enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1)

and (3) of Title VII, 42 U.S.c. § 2000e-5(f)(I) and (3).

4. At all relevant times, Defendant Outsourcing Solutions Incorporated ("OSI") has

continuously been and is now a Delaware corporation doing business in the State of Illinois and

the City of Schaumburg, and has continuously had at least 15 employees.

5.

At all relevant times, Defendant OSI Collection Services, Inc. ("OSICS") has

continuously been and is now doing business in the State of Illinois and the City of Schaumburg,

and has continuously had at least 15 employees.

6. At all relevant times, OSI has continuously been an employer engaged in an

industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42

U.S.c. § 2000e(b), (g) and (h).

7. At all relevant times, OSICS has continuously been an employer engaged in an

2

-.
industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.c. § 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 8. More than thirty days prior to the institution of this lawsuit, Malone filed a charge with the Commission alleging violations of Title VII by OS1. All conditions precedent to the institution of this lawsuit have been fulfilled. 9. Since at least August, 1999, OSI and OSICS have engaged in unlawful employment practices at their Schaumburg, Illinois facility, in violation of Section 704(a) of Title VII, 42 U.S.c. § 2000e-3(a). These practices include, but are not limited to, engaging in intentional discrimination against Malone and against a class of employees who participated in conduct protected by Title VII through a pattern of abuse and intimidation with the intent to force them to resign, in retaliation for their participation in Title VII litigation or their opposition to violations ofTitle VII, and by constructively discharging them. 10. The effect of the practices complained of in paragraph nine (9) above has been to deprive Malone and the class of employees retaliated against for their participation in conduct protected by Title VII of equal employment opportunities and otherwise adversely affect their status as employees because of their participation in conduct protected by Title VII. 11. The unlawful employment practices complained of in paragraph nine (9) above were and are intentionaL 10. The unlawful employment practices complained of in paragraph nine (9) above were and are done with malice or with reckless indifference to the federally protected rights of Malone and the class of employees retaliated against for their participation in conduct protected by Title VII.
3

-.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining OSI, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which retaliates against employees for their participation in conduct protected by Title VII; B. Grant a permanent injunction enjoining OSICS, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which retaliates against employees for their participation in conduct protected by Title VII; C. Order OSI to institute and carry out policies, practices, and programs which provide equal employment opportunities for employees who participate in conduct protected by Title VII, and which eradicate the effects of its past and present unlawful employment practices; D. Order OSICS to institute and carry out policies, practices, and programs which provide equal employment opportunities for employees who participate in conduct protected by Title VII, and which eradicate the effects of its past and present unlawful employment practices; E. Order OSI to make whole Malone and the class of employees retaliated against for their participation in conduct protected by Title VII by providing appropriate back pay with pre-j udgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices; F. Order OSICS to make whole Malone and the class of employees retaliated against for their participation in conduct protected by Title VII by providing appropriate back pay with pre-judgment interest, in amounts to be determined at trial, and other affirmative reliefnecessary to eradicate the effects of its unlawful employment practices;
4

-.

G. Order OSI to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future pecuniary losses resulting from the unlawful employment practices described in paragraph

nine (9) above, including, but not limited to, relocation and job search expenses, in amounts to be

determined at trial;

H. Order OSICS to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future pecuniary losses resulting from the unlawful employment practices described in paragraph

nine (9) above, including, but not limited to, relocation and job search expenses, in amounts to be

determined at trial;

I.

Order OSI to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future non-pecuniary losses resulting from the unlawful practices complained of in paragraph

nine (9) above, including emotional pain, suffering, inconvenience, loss of enjoyment oflife and

humiliation, in amounts to be determined at trial;

J.

Order OSICS to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future non-pecuniary losses resulting from the unlawful practices complained of in paragraph

nine (9) above, including emotional pain, suffering, inconvenience, loss of enjoyment oflife and

humiliation, in amounts to be determined at trial;

K. Order OSI to pay Malone and the class of employees retaliated against for their

participation in conduct protected by Title VII punitive damages for its malicious and/or reckless

conduct described in paragraph nine (9) above, in amounts to be determined at trial;

5

L. Order OSICS to pay Malone and the class of employees retaliated against for their participation in conduct protected by Title VII punitive damages for its malicious and/or reckless conduct described in paragraph nine (9) above, in amounts to be determined at trial;
M. Order OSI and its successors to provide training to its officers, managers and employees regarding retaliation for participation in conduct protected by Title VII in the workplace;
N. Order OSICS and its successors to provide training to its officers, managers and employees regarding retaliation for participation in conduct protected by Title VII in the workplace;
O. Grant such further relief as the Court deems necessary and proper in the public interest; and
P. Award the Commission its costs in this action.
JURy TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.
6

-----~---------------------------------I
Respectfully submitted, NICHOLAS M. INZEO Acting Deputy General Counsel A. JACY THURMOND, JR. Assistant General Counsel EQUAL EMPLOYMENT OPPORTUNITY
MISSION
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
500 West Madison Street, Suite 2800 Chicago, Illinois 60661 - (312)353-7526
7

Civil Cover Sheet

http://www.ilnd.uscourts.gov/_vti_binishtml.dIIlPUBLIC/Fonnslcvcover.h1
~ITED STATES DISTRICT coM
NORTHERN DISTRICT OF ILLINOIS JUDGE KOCORAS

Civil Cover Sheet MAGISTRATE JUDGE LEViN

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is authorized for use only in the Northern District of Il1inois.

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Defendant(s): OUTSOURCING SOLUTIONS, INC & OSI COLLECTION SERVICES, INC

County of Residence:

County of Residence:

Plaintiff's Atty: Diane I. Smason

Defendant's Atty:

Equal Employment Opportunity

Commission

500 W. Madison, Suite 2800

Chicago, IL 60661

312-353-7526

II. Basis of Jurisdiction:

1 U.S. Gov't Plaintiff

c

Beth T. Golub Seyfarth Shaw 55 E. Monroe, Suite 4200 Chicago, IL 60603-5803 312-269-8503

III. Citizenship of Principle Parties (Diversity Cases Only)
Plaintiff:- N/A Defendant:- N/A

IV. Origin:

1. Original Proceeding

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V. Nature of Suit: VI.Cause of Action:

442 Employment

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Title VII of the Civil Rights Act of 1964 and Title I ofThe CAliI Rights

Act of 1991 to correct unlawful employment practices on the basis of

retaliation

VII. Requested in Complaint

Class Action: No

Dollar Demand:

Jury Demand: Yes

VIII. This case Is NOT a refiling of a previously dismissed case. (If yes case number _ by Judge--.J

J.. biW ~ Signature:

(5Y\..

Date: ~~ \\ ) 'LoDt

i

'--'!TED STATES DISTRICT co0

NORTHERN DISTRICT OF ILLINOIS

In the Matter of
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
v. OUTSOURCING SOLUTIONS, INC. & OSI COLLECTION SERVICES, INC.

Ole '7 i) sA7 Eastern Division

S II Jrlf;'iC UIlAf'AR l
,I,

Case Nwnber:

MAGISTRATE JUDGE LEVIN

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEY(S) FOR:

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

(A)
SI'flY";", 0 "JT.~Dyt

NAME
Diane I. Smason

FIRM
Eoual Emolovment Oooortunitv Commission

STREET ADDRESS
500 W. Madison Suite 2800

CITh~TATE/ZIP
C Icago, IL

60661

(3l2)N353~7526

c
en

-en-

//J p' f--17//
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Bet

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(JXO..,j... r1 /r.J~ "V '--0 ~~ -N-

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FIRM
Equal Employment Opportunity Commission

STREET ADDRESS
500 W. Madison, Suite 2800
CITY 1ST ATE/ZIP
Chicago,IL 60661
't3Y2)N3N53~7722

,K/;'.l'll".'"',,"'.U:IJ
l'~
vJ;.t 1 '12001

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

ARDC No. 0622613

MEMBER OF TRIAL BAR?

D 0 YES

NO

TRIAL ATTORNEY?

D J YES [01 NO

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 0603264
MEMBER OF TRIAL BAR?
TRIAL ATIORNEY?

0 YES 0 YES

NO D NO D

DESIGNATED AS ,/CA~OUNSEL? /

D D YES

NO

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E~~l Emplovrnent Opportunity Commission I

FIRM
Eoua Emolovrnent Oooortunity Commission

MEET ADDRESS
500 W. Madison, Suite 2800

'-... :~r~o~v?wRE.SMS adison, Suite 2800

CITY1STATElZIP
Chicago, IL 60661

CITY1STATElZIP
Chicago IL 60661

()LI2)N8 86~9i 24

I ;~L:;)N~~~~B~~ 'i 1

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 06210804

MEMBER OF TRIAL BAR?

0 YES

TRIAL ATTORNEY?

0 YES _I

DESIGNATED AS LOCAL COUNSEL?

0 YES

NO 0 NO 0
NO D

IDENTIFICATiON NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 01187589
MEMBER OF TRlAL BhR?
TRIAL ATIORNEY?
DESIGNATED AS LOCAL COUNSEL?

YES L~j
0 YES
D YES

NO 0 NO D
NO D

/.1

 
 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION JUDGE KOCORAS

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

MAGISTRATE JUDGE LEVIN

)

CIVIL ACTION NO.

Plaintiff,

)

v.

) )

Ole

7037

)

OUTSOURCING SOLUTIONS

)

COMPLAINT

INCORPORATED and OSI COLLECTION )

SERVICES, INC.,

)

c

Defendants.

)

JURY TRIAL DEMAN:[

)

L

) )
NATURE OF THE ACTION

~:;:.'"

rq

n

::;. : c"

C'J

C
;;u

-<

This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil

Rights Act of 1991 to correct unlawful employment practices on the basis of retaliation, and to

provide appropriate relief to Katrina Malone ("Malone"), an employee of Defendants

Outsourcing Solutions Incorporated ("OSI") and OSI Collection Services, Inc. ("OSICS"), and a

class of employees who were adversely affected by such practices. As alleged with greater

particularity in paragraph nine (9) below, OSI and OSICS discriminated against Malone by

retaliating against her for her participation in Title VII litigation. OSI and OSICS also

discriminated against a class of employees by retaliating against them for their participation in

Title VII litigation or their opposition to violations of Title VII.

JURISDICTION AND VENUE

1. Jurisdiction of this court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,

1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(I) and (3) ("Title

VII").

2. The employment practices alleged to be unlawful were and are now being

committed within the jurisdiction ofthe United States District Court for the Northern District of

Illinois, Eastern Division.

PARTIES

3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is

the agency of the United States of America charged with the administration, interpretation and

enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1)

and (3) of Title VII, 42 U.S.c. § 2000e-5(f)(I) and (3).

4. At all relevant times, Defendant Outsourcing Solutions Incorporated ("OSI") has

continuously been and is now a Delaware corporation doing business in the State of Illinois and

the City of Schaumburg, and has continuously had at least 15 employees.

5.

At all relevant times, Defendant OSI Collection Services, Inc. ("OSICS") has

continuously been and is now doing business in the State of Illinois and the City of Schaumburg,

and has continuously had at least 15 employees.

6. At all relevant times, OSI has continuously been an employer engaged in an

industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42

U.S.c. § 2000e(b), (g) and (h).

7. At all relevant times, OSICS has continuously been an employer engaged in an

2

-.
industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.c. § 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 8. More than thirty days prior to the institution of this lawsuit, Malone filed a charge with the Commission alleging violations of Title VII by OS1. All conditions precedent to the institution of this lawsuit have been fulfilled. 9. Since at least August, 1999, OSI and OSICS have engaged in unlawful employment practices at their Schaumburg, Illinois facility, in violation of Section 704(a) of Title VII, 42 U.S.c. § 2000e-3(a). These practices include, but are not limited to, engaging in intentional discrimination against Malone and against a class of employees who participated in conduct protected by Title VII through a pattern of abuse and intimidation with the intent to force them to resign, in retaliation for their participation in Title VII litigation or their opposition to violations ofTitle VII, and by constructively discharging them. 10. The effect of the practices complained of in paragraph nine (9) above has been to deprive Malone and the class of employees retaliated against for their participation in conduct protected by Title VII of equal employment opportunities and otherwise adversely affect their status as employees because of their participation in conduct protected by Title VII. 11. The unlawful employment practices complained of in paragraph nine (9) above were and are intentionaL 10. The unlawful employment practices complained of in paragraph nine (9) above were and are done with malice or with reckless indifference to the federally protected rights of Malone and the class of employees retaliated against for their participation in conduct protected by Title VII.
3

-.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining OSI, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which retaliates against employees for their participation in conduct protected by Title VII; B. Grant a permanent injunction enjoining OSICS, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which retaliates against employees for their participation in conduct protected by Title VII; C. Order OSI to institute and carry out policies, practices, and programs which provide equal employment opportunities for employees who participate in conduct protected by Title VII, and which eradicate the effects of its past and present unlawful employment practices; D. Order OSICS to institute and carry out policies, practices, and programs which provide equal employment opportunities for employees who participate in conduct protected by Title VII, and which eradicate the effects of its past and present unlawful employment practices; E. Order OSI to make whole Malone and the class of employees retaliated against for their participation in conduct protected by Title VII by providing appropriate back pay with pre-j udgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices; F. Order OSICS to make whole Malone and the class of employees retaliated against for their participation in conduct protected by Title VII by providing appropriate back pay with pre-judgment interest, in amounts to be determined at trial, and other affirmative reliefnecessary to eradicate the effects of its unlawful employment practices;
4

-.

G. Order OSI to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future pecuniary losses resulting from the unlawful employment practices described in paragraph

nine (9) above, including, but not limited to, relocation and job search expenses, in amounts to be

determined at trial;

H. Order OSICS to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future pecuniary losses resulting from the unlawful employment practices described in paragraph

nine (9) above, including, but not limited to, relocation and job search expenses, in amounts to be

determined at trial;

I.

Order OSI to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future non-pecuniary losses resulting from the unlawful practices complained of in paragraph

nine (9) above, including emotional pain, suffering, inconvenience, loss of enjoyment oflife and

humiliation, in amounts to be determined at trial;

J.

Order OSICS to make whole Malone and the class of employees retaliated against

for their participation in conduct protected by Title VII by providing compensation for past and

future non-pecuniary losses resulting from the unlawful practices complained of in paragraph

nine (9) above, including emotional pain, suffering, inconvenience, loss of enjoyment oflife and

humiliation, in amounts to be determined at trial;

K. Order OSI to pay Malone and the class of employees retaliated against for their

participation in conduct protected by Title VII punitive damages for its malicious and/or reckless

conduct described in paragraph nine (9) above, in amounts to be determined at trial;

5

L. Order OSICS to pay Malone and the class of employees retaliated against for their participation in conduct protected by Title VII punitive damages for its malicious and/or reckless conduct described in paragraph nine (9) above, in amounts to be determined at trial;
M. Order OSI and its successors to provide training to its officers, managers and employees regarding retaliation for participation in conduct protected by Title VII in the workplace;
N. Order OSICS and its successors to provide training to its officers, managers and employees regarding retaliation for participation in conduct protected by Title VII in the workplace;
O. Grant such further relief as the Court deems necessary and proper in the public interest; and
P. Award the Commission its costs in this action.
JURy TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.
6

-----~---------------------------------I
Respectfully submitted, NICHOLAS M. INZEO Acting Deputy General Counsel A. JACY THURMOND, JR. Assistant General Counsel EQUAL EMPLOYMENT OPPORTUNITY
MISSION
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
500 West Madison Street, Suite 2800 Chicago, Illinois 60661 - (312)353-7526
7

Civil Cover Sheet

http://www.ilnd.uscourts.gov/_vti_binishtml.dIIlPUBLIC/Fonnslcvcover.h1
~ITED STATES DISTRICT coM
NORTHERN DISTRICT OF ILLINOIS JUDGE KOCORAS

Civil Cover Sheet MAGISTRATE JUDGE LEViN

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is authorized for use only in the Northern District of Il1inois.

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Defendant(s): OUTSOURCING SOLUTIONS, INC & OSI COLLECTION SERVICES, INC

County of Residence:

County of Residence:

Plaintiff's Atty: Diane I. Smason

Defendant's Atty:

Equal Employment Opportunity

Commission

500 W. Madison, Suite 2800

Chicago, IL 60661

312-353-7526

II. Basis of Jurisdiction:

1 U.S. Gov't Plaintiff

c

Beth T. Golub Seyfarth Shaw 55 E. Monroe, Suite 4200 Chicago, IL 60603-5803 312-269-8503

III. Citizenship of Principle Parties (Diversity Cases Only)
Plaintiff:- N/A Defendant:- N/A

IV. Origin:

1. Original Proceeding

c::

(J)

CJ

vPl
c:::

V. Nature of Suit: VI.Cause of Action:

442 Employment

o "

c::

::0

N

Title VII of the Civil Rights Act of 1964 and Title I ofThe CAliI Rights

Act of 1991 to correct unlawful employment practices on the basis of

retaliation

VII. Requested in Complaint

Class Action: No

Dollar Demand:

Jury Demand: Yes

VIII. This case Is NOT a refiling of a previously dismissed case. (If yes case number _ by Judge--.J

J.. biW ~ Signature:

(5Y\..

Date: ~~ \\ ) 'LoDt

i

'--'!TED STATES DISTRICT co0

NORTHERN DISTRICT OF ILLINOIS

In the Matter of
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
v. OUTSOURCING SOLUTIONS, INC. & OSI COLLECTION SERVICES, INC.

Ole '7 i) sA7 Eastern Division

S II Jrlf;'iC UIlAf'AR l
,I,

Case Nwnber:

MAGISTRATE JUDGE LEVIN

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEY(S) FOR:

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

(A)
SI'flY";", 0 "JT.~Dyt

NAME
Diane I. Smason

FIRM
Eoual Emolovment Oooortunitv Commission

STREET ADDRESS
500 W. Madison Suite 2800

CITh~TATE/ZIP
C Icago, IL

60661

(3l2)N353~7526

c
en

-en-

//J p' f--17//
( I~

"

'" YJ t ~

~'E
Bet

h

'f,
A. M

i

l

l

er

._-
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(JXO..,j... r1 /r.J~ "V '--0 ~~ -N-

-r-'--
Ci
--; -
C-'' -10.

r /
V

FIRM
Equal Employment Opportunity Commission

STREET ADDRESS
500 W. Madison, Suite 2800
CITY 1ST ATE/ZIP
Chicago,IL 60661
't3Y2)N3N53~7722

,K/;'.l'll".'"',,"'.U:IJ
l'~
vJ;.t 1 '12001

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

ARDC No. 0622613

MEMBER OF TRIAL BAR?

D 0 YES

NO

TRIAL ATTORNEY?

D J YES [01 NO

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 0603264
MEMBER OF TRIAL BAR?
TRIAL ATIORNEY?

0 YES 0 YES

NO D NO D

DESIGNATED AS ,/CA~OUNSEL? /

D D YES

NO

.~

(C)

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lli~gijIrvQc£A anour

A-.

C>IJ1'J ') rII (D)

7'A~ / s'Wrrf7f/ 1.~

/U

/ ; ' k IAJrAoMhEnl ( . Hen IC son

E~~l Emplovrnent Opportunity Commission I

FIRM
Eoua Emolovrnent Oooortunity Commission

MEET ADDRESS
500 W. Madison, Suite 2800

'-... :~r~o~v?wRE.SMS adison, Suite 2800

CITY1STATElZIP
Chicago, IL 60661

CITY1STATElZIP
Chicago IL 60661

()LI2)N8 86~9i 24

I ;~L:;)N~~~~B~~ 'i 1

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 06210804

MEMBER OF TRIAL BAR?

0 YES

TRIAL ATTORNEY?

0 YES _I

DESIGNATED AS LOCAL COUNSEL?

0 YES

NO 0 NO 0
NO D

IDENTIFICATiON NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 01187589
MEMBER OF TRlAL BhR?
TRIAL ATIORNEY?
DESIGNATED AS LOCAL COUNSEL?

YES L~j
0 YES
D YES

NO 0 NO D
NO D

/.1

 
 Minute Order Form (06/97)

United States District Court, Northern District of Illinois

Name of Assigned Judge or Magistrate Judge

Charles P. Kocoras

Sitting Judge if Other than Assigned Judge

CASE NUMBER

01 C 7037

DATE

10/2312003

CASE TITLE
MOTION:

EEOC vs. Outsourcing Solutions, Inc. et al
[In the followlllg box (a) Ill(hcale the party filing the motIOn, c.g., plamtlff, defendant, 3rd party pIalnltfi, and (b) state bfleOy the nature of tile motion being presented.]

DOCKET ENTRY:

(I) o

Filed motion of [ usc listing in "Motion" box above.]

(2) o

Brief in support of motion due ~~_.

(3)

o

Answcr bricfto motion duc~~_. Rcply to answcr bricf duc~~_.

(4) o

Ruling/Hearing on ~~_ set for ~~_ at ~~_.

(5)

•

Status hearing set for 10/3012003 at 9:30 A.M..

(6) o

Pretrial conference[held/continued to] [set for/re-set for] on ~~_ set for ~~_ at ~~_.

(7) o

Trial[set forlre-set for] on ~~_ at ~~_.

(8) o

[Bench/Jury trial] [Hearing] held/continued to ~~_ at ~~_.

(9)

o

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 Local Rule 41.1 0 FRCP41(a)(1) 0 FRCP41(a)(2).

(10) • [Other docket entry] Ruling held. ENTER MEMORANDUM OPINION: Malone's motion (Doc 52-I) to remand or voluntarily dismiss, without prejudice, is denied .

• (11)

[For further detail sec order attached to the original minute ordeL]

f-f-f--
7
r-r--

No notices required, advised in open court. No notices required. Notices mailed by judge's staff. Notiried counsel by telephone. Docketing to mail notices. Mail ~450 form_
Copy t6~l\e/ll~istratcjudge.

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courtroom dcputy's initials

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY,

)

)

Plaintiff,

)

)

vs.

)

)

OUTSOURCING SOLUTIONS, INC. and OSI )

COLLECTION SERVICES, INC.,

)

)

Defendants.

)

01 C 7037

MEMORANDUM OPINION CHARLES P. KOCORAS, Chief District Judge:
This matter comes before the court on Plaintiff-intervenor Katrina Malone's ("Malone") renewed motion to remand or voluntarily dismiss, without prejudice, her claim for intentional infliction of emotional distress. For the reasons set forth below, the motion is denied.
BACKGROUND Malone is a former employee ofDefendants Outsourcing Solutions, Inc. and OSI Collection Services, Inc. ("Defendants"). Malone had testified against her employer in an investigation relating the present case, a sexual harassment lawsuit filed by the EEOC on behalf oftwo ofher co-workers against Defendants. Malone alleges that she

was forced to resign as a result of her involvement in the sexual harassment investigation. Intervening in the case, Malone's four-part complaint contained two federal claims (retaliation in violation of Title VII, 42. U.S.c. § 2000e et seq., and conspiracy under 42 U.S.C. § 1985) and two claims brought under Illinois law (conspiracy and intentional infliction of emotional distress). This court had original jurisdiction over the federal claims and supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367. On October 23,2002, this court partially granted Defendants' motion for summary judgment, dismissing Malone's two federal claims and her Illinois conspiracy claim. Equal Employment Opportunity Commission v. Outsourcing Solutions. Inc., 2002 WL 31409584 (N.D. Ill. 2002).
Following the summary judgment ruling, on December 11,2002, Malone filed a motion to remand her intentional infliction of emotional distress claim to state court or to voluntarily dismiss the claim without prejudice. This court denied Malone's motion, without prejudice, to allow the various parties to attempt to resolve the lawsuit in its entirety through a global settlement. On April 2, 2003, the parties to this lawsuit participated in a settlement conference with the court, but did not reach a resolution.
On May 2, 2003, Defendants filed for Chapter II bankruptcy protection in the U.S. Bankruptcy Court for the Eastern District of Missouri. As a result, on May 12, 2003, Malone's litigation was automatically stayed pursuant to II U.S.C. § 362(a)(1).
-2-

On August 28, 2003, Bankruptcy Judge Scheill1er entered an order lifting the automatic stay for the "sole purpose" of allowing this court to enter a consent decree that all parties to this case had negotiated. In Ie Union Financial Services Group Inc., No. 03-45870-399 (Bankr. E.D. Mo. 2003) (order approving settlement agreement and granting a limited modification ofthe automatic stay) ("Order") at'17. The proposed consent decree sought to completely resolve all claims among the parties relating to this lawsuit. However, it appears that a total agreement between the parties could not be reached. On September 22, 2003, the parties appeared before this court and communicated that they could not resolve differences involving language to be included in a private settlement between Malone and Defendants. This court then reinstated Malone's motion for remand or for voluntary dismissal without prejudice.
DISCUSSION It is not necessary to reach the merits of Malone's motion because the granting of her request would constitute a violation of the automatic stay provision of the Bankruptcy Code, II U.S.C. § 362(a)(l). The automatic stay provision states that a petition for bankruptcy protection triggers a stay which prevents the "commencement or continuation ... of a judicial, administrative or other action or proceeding against the debtor." Id.; Middle Tennessee News Co., Inc v. Charnel of Cincinnati, Inc., 250 F.3d 1077, 1082 (7th CiT. 200 I). The automatic stay is "exceedingly broad," and
-3-

"prohibits any entity from taking certain actions, including commencing or continuing litigation affecting the estate." In re Lifschultz Fast Freight Corp., 174 B.R. 271,279 (N.D. Ill. 1994). One purpose ofthe automatic stay is "to preserve what remains ofthe debtor's insolvent estate and to provide a systematic equitable liquidation procedure for all creditors ... thereby preventing a 'chaotic and uncontrolled scramble for the debtor's assets in a variety of uncoordinated proceedings in different courts.'" In re Holtkamp, 669 F.2d 505, 508 (7th Cir. 1982) (citations omitted). To effectuate this purpose, "the automatic stay remains in effect until the bankruptcy court disposes of the case or grants relieffrom the stay [and] actions taken in violation of an automatic stay ordinarily are void." Middle Tennessee News at 1082.
If this court were to grant Malone's motion by dismissing her claim or remanding it to state court, it would clearly constitute "judicial action" in violation of 11 U.S.c. § 362(a)(1). Judge Schermer's order narrowly modified the automatic stay "for the sole purpose" of allowing this court to enter the proposed consent decree. Order at ~ 7. Judge Schermer explicitly ordered that the automatic stay "shall continue in force and effect/or all other purposes and with respect to all other matters." Id. (emphasis added). By dismissing or remanding Malone's claim, this court would certainly exceed the narrow scope of Judge Schermer's order and would frustrate the
-4-

automatic stay's purpose of channeling all pre-petition claims against the debtor into a unified proceeding before a bankruptcy court.
When Defendants filed for bankruptcy protection in May 2002, the Bankruptcy Court for the Eastern District of Missouri assumed jurisdiction over all pre-petition claims against Defendants. This includes Malone's Illinois claim for intentional infliction of emotional distress. Because this court does not have the authority to do what Malone requests, her motion must be denied.
CONCLUSION Based on the foregoing analysis, Malone's motion to remand or voluntarily dismiss, without prejudice, is denied.

Dated: ;OCT 23,003

Charles P. Kocoras Chief Judge United States District Court

-5-

 
 !.t7- United States District Court, Northern District of Illinois

$ ~ame J

of Assigned Judge

J or Magistrate Judge

Charles P. Kocoras

Sitting Judge if Other than Assigned Judge

CASE NUMBER

01 C 7037

DATE

1112012003

CASE TITLE
MOTION:

EEOC vs. Outsourcing Solutions, Inc. et al
[In the following box (a) mdlcate the party filing the motion, e.g., plam. .tIff, defendant, 3ed partyplamtlff, and (b) state bnefly thenalure
of the motion being presented.]

DOCKET ENTRY:

(1 ) o

Filed motion of [use listing in "Motion" box above.]

(2) o

Brief in support of motion due ___.

(3) o

Answer brief to motion due___. Reply to answer brief due___.

(4)

o

RulinglHearing on ___ set for ___ at _ __

(5) o

Status hearing[heldlcontinued to] [set for/re-set for] on _ _ _ set for _ _ _ at _ _ _.

(6) o

Pretrial conference[heldlcontinued to] [set for/re-set for] on ___ set for ___ at _ _ _.

(7) o

Trial[set for/re-set for] on _ _ _ at _ _ _.

(8) o

[Bench/Jury trial] [Hearing] heldlcontinued to ___ at ___.

(9) o
• (10)

This case is dismissed [with/without] prejUdice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 Local Rule 41.1 0 FRCP4J(a)(J) 0 FRCP4J(a)(2).
[Other docket entry] Enter Consent Decree.

• (11)

[For further detail see order attached to the original minute order.]

-

No notices required, advised in open court.

-

No notices required.

-

Notices mailed by judge's staff.

Notified counsel by telephone.

7 -

Docketing to mail notices.

-

Mail AO 450 form.
Copy to~c/magistratejUdge.

J..

~ .

courtroom

SeT ~ ~neft~~'s

~ ".-1
• 1\ : 'I
1~Pat~tirn'de9~v~,djn central Clerlr's Office

number of notices
dock ~l&'cputy initials
date m8ilcd notice mailing deputy inilinl~

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

and

)

)

KATRINA MALONE,

)

)

Plaintiff-Intervenor,

)

)

v.

)

)

OUTSOURCING SOLUTIONS

)

INCORPORATED and OSI COLLECTION )

SERVICES, INC.,

)

)

Defendants.

)

)

CIVIL ACTION NO. 01 C 7037
Judge Kocoras Magistrate Judge Levin
Dot't\tTL \
NOV 2 1 l003

CONSENT DECREE

THE LITIGATION

1. Plaintiff Equal Employment OpportUnity Commission ("EEOC" or

"Commission") filed this action alleging that Defendants Outsourcing Solutions Inc. and OSI

Collection Services, Inc. (collectively, "OSI") retaliated against Katrina Malone ("Malone") and a

class of two employees in violation of Title VII ofthe Civil Rights Act of 1964, 42 U.S.C.

§2000e et seq. , ("Title VII") for their participation in Title VII litigation or their opposition to

violations of Title VII. The class members are John Sheehan and Kimberly Shimanski. Malone

intervened in this case pursuant to Title VII by filing her own complaint alleging unlawful

retaliation under Title VII, conspiracy and intentional infliction of emotional distress.

Defendants filed an Answer to the EEOC and Intervenor's complaints denying any liability.

/
2. In the interest of resolving this matter, and as a result of comprehensive settlement negotiations, the parties have agreed that this action should be finally resolved by entry ofthis Consent Decree. This Consent Decree fully and finally resolves any and all issues and claims arising out of the Charge of Discrimination filed by Katrina Malone (EEOC Charge No. 21OAl0059) and the Complaints filed by the EEOC and by Malone in this action.
FINDINGS
3. Having carefully examined the terms and provisions of this Consent Decree, and based on the pleadings, records and stipulations of the parties, the Court finds the following:
a. This Court has jurisdiction of the subject matter of this action and of the parties.
b. The terms of this Consent Decree are adequate, fair and reasonable. The rights of the parties and the public interest are adequately protected by this Consent Decree.
c. This Consent Decree conforms with the Federal Rules of Civil Procedure and Title VII and is not in derogation of the rights or privileges of any person. The entry of this Consent Decree will further the objectives of Title VII and will be in the best interests of the parties and the public.
NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: INJUNCTION AGAINST RETALIATION
4. Outsourcing Solutions Inc. and OSI Collection Services, Inc., their officers, agents, employees, successors, assigns, and all persons acting in concert with them shall not engage in any form of retaliation against any person because such person has opposed any practice made unlawful under Title VII, filed a charge of discrimination under Title VII, testified

or participated in any manner in any investigation, proceeding, or hearing under Title VII, or asserted any rights under this Consent Decree.
EFFECT OF DECREE
5. This Consent Decree shall not constitute an admission by any party as to the claims or defenses of another party.
BANKRUPTCY FILING
6. On May 2, 2003, Union Financial Services Group, Inc., an affiliate of Outsourcing Solutions, Inc. and OSI Collection Services, Inc., filed a voluntary petition for relief under Chapter 11 of Title 11 ofthe United States Code (the "Bankruptcy Code") in the United States Bankruptcy Court for the Eastern District of Missouri, Eastern Division (the "Bankruptcy Court"), Case No. 03-45870-399. On May 12,2003, Outsourcing Solutions Inc. and OSI Collection Services, Inc. filed voluntary petitions under Chapter 11 of the Bankruptcy Code with the Bankruptcy Court, Case Nos. 03-46349-399 and 03-46327-399, respectively. The cases are being jointly administered, pursuant to order of the Bankruptcy Court, under Case No. 03-45870399 (collectively, the "Bankruptcy Case").
SETTLEMENT OF CLAIMS
7a. Outsourcing Solutions Inc. agrees to allow Katrina Malone a general, unsecured, prepetition claim against its bankruptcy estate in the gross amount of $112,500, 100% of which claim is designated as back-pay and from which the employee's share of all applicable deductions shall be made. Such claim shall be administered, satisfied and discharged in accordance with the terms and conditions of the plan of reorganization that is confirmed in the Bankruptcy Case, and pursuant to the prov;.sions and requirements of the Bankruptcy Code.

Such claim shall not enjoy any type of statutory or administrative priority over any other general, unsecured, prepetition claims in the Bankruptcy Case; however, this provision does not preclude Malone from seeking Bankruptcy Code Section 507(a)(3) or (4) priority for her prepetition claim in future proceedings in the Bankruptcy Court, nor preclude Outsourcing Solutions Inc. or any other party in interest from contesting that request for priority.
7b. Outsourcing Solutions Inc. agrees to allow Kimberly Shimanski a general, unsecured, prepetition claim against its bankruptcy estate in the gross amount of $26,250, 50% of which claim is designated as back-pay and from which the employee's share of all applicable deductions shall be made. Such claim shall be administered, satisfied and discharged in accordance with the terms and conditions of the plan of reorganization that is confirmed in the Bankruptcy Case, and pursuant to the provisions and requirements of the Bankruptcy Code. Such claim shall not enjoy any type of statutory or administrative priority over any other general, unsecured, prepetition claims in the Bankruptcy Case.
7c. Outsourcing Solutions Inc. agrees to allow John Sheehan a general, unsecured, prepetition claim against its bankruptcy estate in the gross amount of $11 ,250, 50% of which claim is designated as back-pay and from which the employee's share of all applicable deductions shall be made. Such claim shall be administered, satisfied and discharged in accordance with the terms and conditions of the plan of reorganization that is confirmed in the Bankruptcy Case, and pursuant to the provisions and requirements of the Bankruptcy Code. Such claim shall not enjoy any type of statutory or administrative priority over any other general, unsecured, prepetition claims in the Bankruptcy Case.
7d. Any and all other monetary claims described in or arising from this Consent Decree beyond those claims described in paragraphs 7-9 above, if any, shall be general,

unsecured, prepetition claims against Outsourcing Solutions Inc. in the Bankruptcy Case. All such claims shall be administered, satisfied and discharged in accordance with the terms and conditions of the plan of reorganization that is confirmed in the Bankruptcy Case, and pursuant to the provisions and requirements ofthe Bankruptcy Code. In addition, such claims shall not enjoy any type of statutory or administrative priority over any other general, unsecured, prepetition claims in the Bankruptcy Case.
7e. OSI has received a signed release from John Sheehan and Kimberly Shimanski (the form of which is attached hereto as Exhibit A); and has received a signed release from Katrina Malone (the form of which was negotiated privately between Malone and OSI). The parties have applied to the Bankruptcy Court for, and obtained an order authorizing the entry of this Consent Decree for the purpose of liquidating the parties' claims against OS!. In no event shall any of the parties request that the Bankruptcy Court grant relieffrom the automatic stay to allow any of the parties to enforce, collect, or otherwise receive payment on account oftheir claims against OSI, except in accordance with OSl's plan of reorganization; nor shall any of the parties take any further actions against OSI or any of its affiliated companies in respect of such claims without the prior authorization of the Bankruptcy Court.
POSTING OF NOTICE
8. Within ten (10) business days after entry ofthis Consent Decree, OSI shall post a same-size copy of the Notice attached as Exhibit B to this Consent Decree at its Schaumburg, Illinois facility in locations where notices to employees and applicants for employment at its facilities are normally posted. The Notice shall remain posted for two (2) years from the date of entry of this Consent Decree. OS1 shall take all reasonable steps to ensure that the posting is not

altered, defaced or covered by any other material. OSI shall certify to the EEOC in writing within fifteen (15) days after entry of this Consent Decree that the copy of the Notice has been properly posted. OSI shall permit a representative of the EEOC to enter the Schaumburg, Il1inois facility for purposes of verifying compliance with this Paragraph at any time during normal business hours without prior notice.
RECORD KEEPING
9. For a period oftwo (2) years following entry ofthis Consent Decree, OSI shall maintain and make available for inspection and copying by the EEOC records (including name, social security number, address, telephone number, details of complaint of retaliation, details of all actions taken in response to the complaint of retaliation) of each person who complains of Title VII retaliation occurring at OS!' s Schaumburg, Illinois facility.
10. OSI shall make all documents or records referred to in paragraph 9, above, available for inspection and copying within ten (10) business days after the EEOC so requests. In addition, OSI shall make available all persons within its employ whom the EEOC requests for purposes of verifying compliance with this Consent Decree and shall permit a representative of the EEOC to enter their respective premises for such purposes on five (5) business days' advance notice by the EEOC.
II. Nothing in this Consent Decree shall be construed to limit any obligation OSI may otherwise have to maintain records under Title VII or any other law or regulation.
REPORTING
12. OSI shall furnish to the EEOC the following written reports semi-annually for a period oftwo (2) years following entry of this Consent Decree. The first report shall be due six

(6) months after the entry ofthis Consent Decree. The final report shall be due twenty-three (23) months after entry of this Consent Decree. Each such report shall contain (a) the information required to be maintained pursuant to paragraph 9, above, and (b) a certification by OSl that the Notice required to be posted pursuant to paragraph 8, above, remained posted during the entire six (6) month period preceding the report.
TRAINING
13. Within three (3) months of the entry ofthis Consent Decree, OSI shall provide training to all their current management, supervisory and hourly employees at their Schaumburg, Illinois facility relating to the anti-retaliation provisions of the anti-discrimination laws, rules, and regulations. An outside party approved by the Commission shall conduct the training. Within twenty (20) days of the entry of the Consent Decree, OSI shall submit to the Commission the name and credentials of the person whom it recommends to conduct the training, a description of the training to be provided, and a copy of any training materials to be used in connection with the proposed training. Within ten (10) days of the Commission's receipt of OSI's recommendations, the Commission will advise OSl whether or not it approves ofOSI's recommendations. lithe Commission does not approve of any of OSl's recommendations, the parties will make good faith efforts to resolve their differences, and if necessary, seek resolution by the Court pursuant to paragraph 14, below. Within ten (10) days of the completion ofthe training, OSI shall notify the EEOC of the dates the training was conducted, and the name and job title of each person who received the training.
DISPUTE RESOLUTION
14. In the event that either party to this Consent Decree believes that the other party

has failed to comply with any provision(s)ofthe Consent Decree, the complaining party shall notify the other party of the alleged non-compliance and shall afford the alleged non-complying party ten (10) business days to remedy the non-compliance or to satisfy the complaining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged non-compliance or satisfied the complaininlS party that it has complied within ten (10) business days, the complaining party may apply to the Court for appropriate relief; provided that appropriate notice of a dispute, between the parties is provided to Bankruptcy Court.
DURATION OF DECREE AND RETENTION OF JURISDICTION
15. All provisions ofthis Consent Decree shall be in effect (and the Court shall retain jurisdiction of this matter to enforce this Consent Decree) for a period oftwo (2) years immediately following entry ofthe Consent Decree, provided, however, that if, at the end ofthe two (2) year period, any disputes under paragraph 14, above, remain umesolved, the term of the Consent Decree shall be automatically extended (and the Court will retain jurisdiction ofthis matter to enforce the Consent Decree) until such time as all such disputes have been resolved.
MISCELLANEOUS PROVISIONS
16. Each party to this Consent Decree shall bear its own expenses, costs and attorneys' fees, including, but not limited to, the expenses, costs and attorneys' fees related to this litigation and to Malone's charge of discrimination.
17. The terms of this Consent Decree are and shall be binding upon all parties to this lawsuit and upon the present and future representatives, agents, directors, officers, assigns, and successors of all parties.

18. When this Consent Decree requires the submission by OSI ofreports, certifications, notices, or other materials to the EEOC, they shall be mailed to: OSI Settlement, c/o Diane 1. Smason, Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, IL 60661. When this Consent Decree requires submission by the EEOC of materials to OSI they shall be mailed to: Peter Pugal, Outsourcing Solutions Inc., 2520 South 170th Street, New Berlin, Wisconsin 53151.

For the EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-752_6 _ _~

For OUTSOURCING SOLUTIONS INCORPORATED:
For OSI COLLECTION SERVICES, INC.:

I
'c-.:-\// \\~_\(\~ '\----'\ ~O~
Katrina Malone
ENTER:
C.f.,~f~~o
U.S. District Court Judge Charles P. Kocoras
.i~O\J 2 0 2003
Date: _ _ _ _ _ __

9
CHI 10558504.3

EXHIBIT A

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

and

)

)

KATRINA MALONE,

)

)

Plaintiff-Intervenor,

)

)

v.

)

)

OUTSOURCING SOLUTIONS

)

INCORPORATED and OSI COLLECTION )

SERVICES, INC.,

)

)

Defendants.

)

)

CIVIL ACTION NO. 01 C 7037
Judge Kocoras Magistrate Judge Levin

RELEASE AGREEMENT

For and in consideration of payment to be made from Outsourcing Solutions Inc. and OSI

Collection Services, Inc. (collectively, "OSI") as determined by the Bankruptcy Court in respect

of my $

claim, pursuant to a consent decree ("Consent Decree") entered by the Court

in EEOC and Malone v. Outsourcing Solutions Incorporated and OSI Collection Services, Inc.,

Civil Action No. 01 C 7037 (N.D. Ill.), I, [Kimberly Shimanski/John Sheehan], hereby release

and forever discharge OSI, its successors, parent, related corporate entities, affiliates, their

assigns, directors, officers, employees and representatives from all claims, demands and causes

of action which the undersigned now has or has had against OSI under Title VII of the Civil

Rights Act of 1964, as amended, as a result of or arising from the subject matter and claims

asserted by the EEOC in EEOC and Malone v. Outsourcing Solutions Incorporated and OSI

Collection Services, Inc., Civil Action No. 01 C 7037 (N.D. Ill.), or which could have been raised

by EEOC therein. I also agree that I am waiving any claims for attorneys' fees or costs

associated with the claims I am waiving by this agreement. Provided however, nothing in this

Release Agreement shall be construed as a waiver of any rights or claims I may have arising after

the date of the Consent Decree.

Date: _ _ _ _ __

Signed: _ _ _ _ _ _ __
Print Name: - - - - - -

EXHIBITB

NOTICE TO ALL EMPLOYEES AND APPLICANTS OF OSI COLLECTION SERVICES. INC.

This Notice is being posted pursuant to a Consent Decree entered by the federal court in EEOC, et al. v. OSI Collection Services, Inc., et al. ("OSI"), 01 C 7037 (N.D. Illinois), settling a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC").

In its suit, the EEOC alleged that OSI retaliated against certain employees in violation of Title VII of the Civil Rights Act of 1964 ("Title VII") for their participation in Title VII litigation or their opposition to violations of Title VII. OSI denied all of the allegations made against it in the lawsuit and does not admit any liability in the lawsuit.

The parties agreed to enter into a Consent Decree which requires OSI to:

1) provide monetary relief to certain former employees;

2) not retaliate against any person in violation of Title VII;

3) provide periodic reports to the EEOC of any complaints of retaliation; and

4) provide training to its employees at the Schaumburg, Illinois facility regarding retaliation.

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE D• EFACED BY ANYONE

This Notice must remain posted for two (2) years from the date below and must not be altered, defaced or covered by any other material. Any questions about this Notice or compliance with its terms may be directed to: OSI Settlement, EEOC, 500 West Madison Street, Suite 2800, Chicago, IL 60661. The EEOC enforces the federal laws against discrimination in employment on the basis of disability, race, color, religion, national origin, sex, and age. If you believe you have been discriminated against, you may contact the EEOC at (312) 353-2713. The EEOC charges no fees and has employees who speak languages other than English.

NOV 202003
Date: _ _ _ _ _ _ _ _ _ __

CPo.. *wOO 4 f. [I"3(:::~" ~ •
U.S. District Judge Charles P. Kocoras

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...
LEVIN, PROTO, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-07037

EEOC, et al v. Outsourcing, et al Assigned to: Hon. Charles P. Kocoras Demand: $0 Cause: 42:1983 Civil Rights (Employment Discrimination)

Date Filed: 09/11/2001 Date Terminated: 11/20/2003 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Gregory M. Gochanour United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 886-9124 Email: gregory.gochanour@eeoc.gov ATTORNEY TO BE NOTICED

John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED

V. Defendant Outsourcing Solutions, Inc.

represented by David J. Rowland Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 346-8000 Email: drowland@seyfarth.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Beth Golub Joffe

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Defendant OSI Collection Services, Inc.
Intervenor Plaintiff Katrina Malone

Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 460-5000 Email: bjoffe@seyfarth.com ATTORNEY TO BE NOTICED
represented by David J. Rowland (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Beth Golub Joffe (See above for address) ATTORNEY TO BE NOTICED

Date Filed 09/11/2001
09/24/2001 09/25/2001 10/02/2001
10/05/2001 10/17/2001 10/17/2001

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of Diane I. Smason, Beth A. Miller, Gregory M. Gochanour, John C. Hendrickson as attorney(s) for plaintiff ( No summons(es) issued.) ( Documents: 1-1 through 1-3) (ar) (Entered: 09/14/2001)
2 WAIVER of service of summons as to defendants sent on 9/19/01. (cem) (Entered: 09/25/2001)
3 MOTION by Katrina Malone for leave to intervene as a plaintiff-intervenor (Attachments); Notice (rmm) (Entered: 10/03/2001)
4 MINUTE ORDER of 10/2/01 by Hon. Charles P. Kocoras : Answer brief to Katrina Malone's motion for leave to intervene as a plaintiff-intervenor [3-1] due 10/16/01. Reply to answer brief due 10/23/01. Status hearing set for 9:30 a.m. on 11/13/01. Defendants are given to 11/13/01 to answer plaintiff's complaint and the complaint of Katrina Malone. Mailed notice (rmm) (Entered: 10/03/2001)
5 ATTORNEY APPEARANCE for Outsourcing, OSI Collection Svc by David J. Rowland, Beth Tracey Golub (rmm) (Entered: 10/09/2001)
6 LETTER from defendants' attorney to Clerk Office dated 10/16/01 (rmm) (Entered: 10/18/2001)
7 MINUTE ORDER of 10/17/01 by Hon. Charles P. Kocoras : Motion by Katrina Malone for leave to intervene as a plaintiff-intervenor is granted [3-1]. Mailed notice (rmm) (Entered: 10/18/2001)

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10/25/2001 11/13/2001 11/13/2001 11/14/2001 01/24/2002 01/29/2002 01/30/2002
03/25/2002 03/25/2002 03/27/2002 03/28/2002
04/05/2002 04/09/2002 04/09/2002 04/15/2002

8 INTERVENOR'S COMPLAINT by intervenor plaintiff Katrina Malone (rmm) (Entered: 10/25/2001)
SCHEDULE set on 11/13/01 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 4/15/02 . Fact discovery ordered closed on 4/15/02 . Mailed notice (sct) (Entered: 11/13/2001)
10 ANSWER and affirmative defenses by defendants to complaint [1-1] (rmm) (Entered: 11/15/2001)
9 ANSWER and affirmative defenses by defendants to plaintiff-intervenor's complaint [8-1] (rmm) (Entered: 11/15/2001)
12 MOTION by defendants to compel purported "class member" John Sheehan to attend his deposition or, in the alternative, to dismiss his claims (Attachments); Notice (rmm) (Entered: 01/31/2002)
11 RESPONSE by plaintiff EEOC to defendants' motion to compel; Notice (rmm) (Entered: 01/30/2002)
13 MINUTE ORDER of 1/30/02 by Hon. Charles P. Kocoras: Defendants' motion to compel purported "class member" John Sheehan to attend his deposition is granted [12-1]. So Ordered. Defendants' alternative motion to dismiss his claims [12-2], is moot. Mailed notice (rmm) (Entered: 01/31/2002)
15 MOTION by intervenor plaintiff Katrina Malone for time to depose Cahty Kozial and Marla Lumpkins ; Notice (rmm) (Entered: 03/29/2002)
16 JOINT MOTION by plaintiff EEOC and intervenor plaintiff Katrina Malone to compel production of documents (Attachments); Notice (rmm) (Entered: 03/29/2002)
14 RESPONSE by defendants to plaintiff-intervenor's motion to compel time to depose Cathy Kozial and Marla Lumpkins (Attachments) (rmm) (Entered: 03/28/2002)
17 MINUTE ORDER of 3/28/02 by Hon. Charles P. Kocoras : Motion by plaintiff-intervenor for time to depose Cahty Kozial and Marla Lumpkins is granted [15-1]. Said depositions to be taken by telephone, and each is limited to one (1) hour. Plaintiffs' joint motion to compel production of documents [16-1] is denied without prejudice. Counsel are ordered to meet fact-to-fact to resolve all outstanding discovery disputes. Mailed notice (rmm) (Entered: 03/29/2002)
19 MOTION by defendants for protective order to bar the deposition of defendants' counsel, Beth T. Golub (Attachments); Notice (rmm) (Entered: 04/15/2002)
18 JOINT RESPONSE by plaintiffs to defendants' motion for a protective order to bar deposition of Beth Golub (Attachments) (rmm) (Entered: 04/10/2002)
20 JOINT MOTION plaintiffs to compel testimony or, in the alternative, to bar certain evidence (Attachments); Notice (rmm) (Entered: 04/15/2002)
21 MINUTE ORDER of 4/15/02 by Hon. Charles P. Kocoras : Status hearing held. Defendants' motion for protective order to bar the deposition of defendants' counsel, Beth T. Golub [19-1] is granted without prejudice. Plaintiffs' joint motion to compel testimony [20-1] and to bar certain evidence [20-2] is denied.

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...

05/15/2002 05/15/2002 05/15/2002 05/15/2002 05/15/2002 06/14/2002 06/14/2002 06/14/2002 06/14/2002 06/14/2002 06/21/2002 06/24/2002 06/25/2002 06/27/2002 06/27/2002

Defendants are given to 5/15/02 to file motion for summary judgment. Answer to said motion due 6/14/02. Reply due 6/28/02. Ruling set for 9:45 at 7/18/02. Mailed notice (rmm) (Entered: 04/15/2002)
22 MOTION by defendants for summary judgment on all claims ; Notice (rmm) (Entered: 05/16/2002)
23 MEMORANDUM by defendant in support of their motion for summary judgment on all plaintiffs' Title VII Claims [22-1] (Attachments) (rmm) (Entered: 05/16/2002)
24 MEMORANDUM by defendants in support of their motion for summary judgment on Katrina Malone's conspiracy claims [22-1] (Attachments) (rmm) (Entered: 05/16/2002)
25 STATEMENT of material facts about which there is no genuine issue by defendants (rmm) (Entered: 05/16/2002)
26 APPENDIX filed by defendants of materials in support of defendants' motion for summary judgment [22-1] (2 vols: 261-1, 26-2). (rmm) (Entered: 05/16/2002)
27 APPENDIX of materials of plaintiffs' response to defendants' motions for summary judgment by plaintiff (Attachments) (1 vol). (rmm) (Entered: 06/17/2002)
28 JOINT RESPONSE by plaintiff to defendants' memorandum of law in support of their motion for summary judgment on all plaintiffs' Title VII Claims [23-1] (Attachments) (rmm) (Entered: 06/18/2002)
29 JOINT RESPONSE by plaintiff to defendants' statement of material facts [25-1] (rmm) (Entered: 06/18/2002)
30 ADDITIONAL facts justifying the denial of summary judgment by plaintiff and intervenor-plaintiff (rmm) (Entered: 06/18/2002)
31 RESPONSE by intervenor plaintiff to defendants' motion for summary judgment on Malone's conspiracy claims [22-1] (Attachments) (rmm) (Entered: 06/18/2002)
32 JOINT MOTION by plaintiffs EEOC and Katrina Malone to amend plaintiffs' joint response to defendants' statement of facts ; Notice (rmm) (Entered: 06/24/2002)
33 UNOPPOSED MOTION by defendants for extension of time to file reply in support of motion for summary judgment ; Notice (rmm) (Entered: 06/28/2002)
SCHEDULE set on 6/25/02 by Hon. Charles P. Kocoras : Ruling set for 7/18/02 is stricken. The Court will rule by mail. Mailed notice (sct) (Entered: 06/25/2002)
34 AMENDMENT by plaintiff to plaintiffs' joint response to defendants' statement of facts [29-1] (rmm) (Entered: 06/28/2002)
35 MINUTE ORDER of 6/27/02 by Hon. Charles P. Kocoras: Plaintiffs' joint motion for leave to amend plaintiffs' joint response to defendants' statement of facts is granted [32-1]. Defendants' unopposed motion for extension of time to 7/8/02 to file reply in support of motion for summary judgment, is granted [33-1].

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...

07/08/2002 07/08/2002 07/08/2002 07/08/2002 07/08/2002 07/08/2002 07/08/2002 07/15/2002
07/17/2002
07/24/2002 09/09/2002 09/12/2002 10/23/2002

Mailed notice (rmm) (Entered: 06/28/2002)
36 REPLY by defendants to plaintiffs' joint response to defendants' statement of material facts about which there is no genuine issue [29-1] (Attachments) (rmm) (Entered: 07/09/2002)
37 REPLY by defendants to plaintiff EEOC's and plaintiff-intervenor's joint statement of additinal facts justifying the denial of summary judgment [30-1] (rmm) Modified on 07/09/2002 (Entered: 07/09/2002)
38 REPLY brief by defendants in support of their motion for summary judgment on all plaintiffs' Title VII Claims [22-1] (rmm) (Entered: 07/10/2002)
39 REPLY brief by defendants in support of their motion for summary judgment on Malone's conspiracy claims [22-1] (Attachments) (rmm) (Entered: 07/10/2002)
40 REPLY by defendants to plaintiffs' joint response to defendants' statement of material facts about which there is no genuine issue [29-1] (Attachments) (rmm) (Entered: 07/10/2002)
41 REPLY APPENDIX by defendants of materials in support of defendants' motion for summary judgment [22-1] (Attachments) (rmm) (Entered: 07/10/2002)
42 REPLY by defendants to plaintiff EEOC's and plaintiff-intervenor's joint statement of additional facts justifying the denial of summary judgment [30-1] (rmm) (Entered: 07/10/2002)
43 MOTION by plaintiff EEOC and plaintiff-intervenor Katrina Malone to strike 1) defendants' reply to plaintiffs' joint response to defendants' Statement of Material Facts About Which There is No Genuine Issue in its entirety and defendants' Exhibit 33; 2) defendants' reply to Plaintiff EEOC's and Plaintiff-Intervenors' Joint Statement of Additional Facts Justifying the denial of Summary judgment in its entirety or strike the offending portions identified above; and 3) Exhibit 41 of defendants' Reply Appendix of Materials in Support of defendants' Motion for summary judgment ; Notice (rmm) (Entered: 07/18/2002)
44 MINUTE ORDER of 7/17/02 by Hon. Charles P. Kocoras: Defendant is given leave to amend its response to Plaintiff and Plaintiff-Intervenor's joint statement of additional facts. Plaintiff and Plaintiff-Intervenor wish to stand on the previous submissions. The Court will rule on all pending motions by mail. Mailed notice (rmm) (Entered: 07/18/2002)
45 REVISED REPLY by defendant to plaintiff EEOC's and Plaintiff-Intervenor's joint statement of additional facts justifying the denial of summary judgment [30-1]; Notice (rmm) (Entered: 07/25/2002)
46 MOTION by plaintiff and intervenor plaintiff to file supplemental authority (Attachments); Notice (rmm) (Entered: 09/13/2002)
47 MINUTE ORDER of 9/12/02 by Hon. Charles P. Kocoras : Plaintiff and Plaintiff-Intervenor's motion to file supplemental authority is granted [46-1]. No notice (rmm) (Entered: 09/13/2002)
48 MINUTE ORDER of 10/23/02 by Hon. Charles P. Kocoras: Defendants' motion for summary judgment is granted in part and denied in part [22-1]. Defendants'

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...

12/05/2002 12/06/2002 12/11/2002
12/20/2002 12/26/2002 12/31/2002 01/10/2003 02/10/2003 02/18/2003 03/06/2003

motion for summary judgment on plaintiff's claims of retaliation and constructive discharge is granted in part and denied in part. Plaintiffs may go forward only with their claim that defendants retaliated against Shimanski when they passed her for promotion in February 2000. Defendants' motion for summary judgment as to Intervenor-Plaintiff Malone's Conspiracy claims is granted. All other pending motions are moot [43-1]. Parties are given to 12/13/02 to file a joint final pretrial order. Entered Memorandum Opinion. Mailed notice (rmm) (Entered: 10/24/2002)
49 MOTION by intervenor plaintiff Katrina Malone to remand claim for intentional infliction of emotional distress to state court or, in the alternative, to grant plaintiff-intervenor leave to voluntarily dismiss claim, without prejuice ; Notice (rmm) (Entered: 12/12/2002)
50 JOINT MOTION by plaintiff and defendant for extension of time to file joint final pretrial order ; Notice (rmm) (Entered: 12/12/2002)
51 MINUTE ORDER of 12/11/02 by Hon. Charles P. Kocoras : Status hearing set for 9:30 1/10/03. Defendants and plaintiff EEOC's joint motion for extension of time to 1/24/03, to file joint final pretrial order is granted [50-1]. Pretrial order deadline 1/24/03. Plaintiff-intervenor's motion to remand claim for intentional infliction of emotional distress to state court [49-1] or, alternatively, to grant plaintiff-intervenor leave to voluntarily dismiss claim, without prejuice [49-2] is denied without prejudice. Mailed notice (rmm) (Entered: 12/12/2002)
52 RENEWED MOTION by plaintiff-intervenor to remand claim for intentional infliction of emotional distress to state court or alternatively, to grant plaintiff-intervenor leave to voluntarily dismiss claim, without prejudice. ; Notice. (gcy) Modified on 10/10/2003 (Entered: 12/27/2002)
53 MINUTE ORDER of 12/26/02 by Hon. Charles P. Kocoras : Plaintiff-Intervenor's renewed motion to remand claim, or alternatively, for leave to voluntarily dismiss her claim without prejudice [52-1] is entered and continued to 01/10/03 at 9:30 a.m. Mailed notice (gcy) (Entered: 12/27/2002)
54 RE-NOTICE by intervenor plaintiff Katrina Malone of motion to remand claim for intentional infliction of emotional distress to state court [52-1], motion to grant plaintiff-intervenor leave to voluntarily dismiss claim, without prejudice [52-2] (rmm) (Entered: 01/13/2003)
55 MINUTE ORDER of 1/10/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 2/12/03. All pending motions [52-1] [52-2] are denied without prejudice. The Court hereby vacates the date for submission of the pretrial order. Mailed notice (rmm) (Entered: 01/13/2003)
SCHEDULE set on 2/10/03 by Hon. Charles P. Kocoras : Status hearing set for 2/12/03 is stricken. Telephone notice (sct) (Entered: 02/10/2003)
SCHEDULE set on 2/18/03 by Hon. Charles P. Kocoras : Status hearing set to 9:30 3/6/03 . Mailed notice (sct) (Entered: 02/18/2003)
SCHEDULE set on 3/6/03 by Hon. Charles P. Kocoras : Status hearing held. Pretrial conference set to 10:00 4/2/03 Mailed notice (sct) (Entered: 03/06/2003)

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...

04/02/2003 04/21/2003 05/09/2003 05/13/2003 05/22/2003 05/28/2003 05/29/2003 06/18/2003 06/24/2003 07/09/2003 08/07/2003 09/08/2003 09/22/2003
09/26/2003 10/23/2003
10/30/2003

SCHEDULE set on 4/2/03 by Hon. Charles P. Kocoras : Pretrial conference held. Status hearing set to 9:30 4/21/03 . No notice (sct) (Entered: 04/02/2003)
SCHEDULE set on 4/21/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 5/9/03 . No notice (sct) (Entered: 04/21/2003)
SCHEDULE set on 5/9/03 by Hon. Charles P. Kocoras : Status hearing held. Pretrial order to be submitted on 6/19/03 . Mailed notice (sct) (Entered: 05/09/2003)
58 UNOPPOSED MOTION by defendant to strike pre-trial order due date ; Notice (rmm) (Entered: 06/19/2003)
56 SUGGESTION of Bankruptcy (Attachments). (gcy) (Entered: 05/23/2003)
57 RESPONSE by plaintiff to defendants' suggestion of bankruptcy [56-1] ; Notice (las) (Entered: 05/29/2003)
SCHEDULE set on 5/29/03 by Hon. Charles P. Kocoras : Status hearing set to 9:30 6/24/03 . Mailed notice (sct) (Entered: 05/29/2003)
59 MINUTE ORDER of 6/18/03 by Hon. Charles P. Kocoras : Defendants' unopposed motion to strike pre-trial order due date is granted [58-1]. Telephoned notice (rmm) (Entered: 06/19/2003)
SCHEDULE set on 6/24/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 7/9/03 . No notice (sct) (Entered: 06/24/2003)
SCHEDULE set on 7/9/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 8/7/03 . Mailed notice (sct) (Entered: 07/09/2003)
SCHEDULE set on 8/7/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 9/8/03 . No notice (sct) (Entered: 08/07/2003)
SCHEDULE set on 9/8/03 by Hon. Charles P. Kocoras : Status hearing held and continued to 9:30 9/22/03 . No notice (sct) (Entered: 09/08/2003)
60 MINUTE ORDER of 9/22/03 by Hon. Charles P. Kocoras : Status hearing held. Defendant is given to September 26, 2003 to answer plaintiff-intrevenor's motion to remand claim for intentional infliction of emotional distress to state court [Doc 52-1]. Reply due October 8, 2003. Ruling on motion to remand claim for intentional infliction of emotional distress to state court [52-1] set for October 23, 2003 at 9:30 a.m. Mailed notice (rmm) (Entered: 09/23/2003)
61 RESPONSE by defendants to Malone's motion to remand or voluntarily dismis her IIED claim (Attachment) (rmm) (Entered: 10/06/2003)
62 MINUTE ORDER of 10/23/03 by Hon. Charles P. Kocoras : Status hearing set for 9:30 a.m. on 10/30/03. Ruling held. Malone's motion to remand [52-1] or voluntarily dismiss, without prejudice [52-2] is denied Entered Memorandum Opinion. Mailed notice (rmm) (Entered: 10/24/2003)
SCHEDULE set on 10/30/03 by Hon. Charles P. Kocoras : Status hearing held. Parties to submit their consent judgment within 2 weeks. Mailed notice (sct) (Entered: 10/30/2003)

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?105629106123183-L_35...

11/20/2003

63 MINUTE ORDER of 11/20/03 by Hon. Charles P. Kocoras : (Entered Consent Decree (Attachments)). terminating case Mailed notice (rmm) (Entered: 11/21/2003)

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