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

U.S. EQUAL EMPLOYMENT OPPORTUNITY

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Civil Action No.

BURNS INTERNATIONAL SECURITY SERVICES, d/b/a KANE SECURITY,
Defendant.

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Jury Trial Demand

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('"II' JUDGE COAR'

DOCKETEIJ
SEP 202000

- - - - - - - - - - - - - - - - - J \ : ' O O O MAGISTRATE JUDGE

COMPLAINT

GERALDINE SOAT BROWN

Nature ofthe Action

This is an action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §

2000e et seq. ("Title VII") and Title I ofthe Civil Rights Act of 1991,42 U.S.C. § 1981a, to correct

unlawful employment practices on the basis ofreligion and to provide appropriate reliefto Charging

Party, Marquesha Martin ("Martin"), who was adversely affected by such practices. Plaintiff, the

U.S. Equal Employment Opportunity Commission ("EEOC"), alleges that Defendant, Bums

International Security Services, doing business as Kane Security, violated Title VII by refusing to

allow Martin, a Muslim, a reasonable accommodation and by terminating her employment, because

she wore a hijab (head scarf) as a tenet of her religion.

Jurisdiction and Venue

1. Jurisdictionofthis Court is invoked pursuant to 28U.S.C. §§451, 1331, 1337, 1343

and 1345. This action is authorized and instituted pursuant to Sections 706(f)(1) and (3) ofTitle VII,

42 U.S.c. §§ 2000e-5(f)(I) and (3), and Section 102 ofthe Civil Rights Act of 1991, 42 U.S.c. §

1981a.

v
2. The employment practices hereafter alleged to be unlawful were and are now being committed within the jurisdiction of the United States District Court for the Northern District of Illinois, Eastern Division.
Parties 3. Plaintiff, the U.S. Equal Employment Opportunity Commission, is the agency ofthe United States of America charged with the administration, interpretation and enforcement of Title VII and is expressly authorized to bring this action by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. §§ 2000e-5(f)(I) and (3). 4. At all relevant times, Defendant has continuously been a Delaware corporation doing business in the State of Illinois and the City of Chicago and has had at least fifteen employees. 5. At all relevant times, Defendant has continuously been and is now 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).
Statement of Claims 6. More than thirty (30) days prior to the institution ofthis lawsuit, Marquesha Martin filed a charge of discrimination with EEOC, alleging violations of Title VII by Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least March 31, 1999, Defendant has engaged in unlawful employment practices in violation of Sections 7010) and 703(a) ofTitle VII, 42 U.S.C. §§ 2000eO) and 2(a). Such unlawful employment practices have included:
(a) the denial ofreasonable accommodation to Martin's sincere religious practice of wearing a hijab (head scarf) as a tenet of her religion; and
2

(b) the termination of Martin, a Muslim, because she wore a hijab (head scarf) as a tenet of her religion.
8. The effect of the practices complained of above has been to deprive Martin ofequal employment opportunities and otherwise adversely affect her status as an employee because of her religion.
9. The unlawful employment practices complained ofin Paragraphs 7 and 8 above were intentional.
10. The unlawful employment practices complained ofin Paragraphs 7 and 8 above were done with malice or with reckless indifference to the federally protected rights of Martin.
Prayer for Relief WHEREFORE, the U.S. Equal Employment Opportunity Commission respectfully requests that the Court: A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns
and all persons in active concert or participation with Defendant from engaging in any employment practice with discriminates because of religion; B. Order Defendant to institute and carry out policies, practices and programs which eradicate the effects of its past and present unlawful practices; C. Order Defendant to make whole Martin by providing appropriate back pay with prejUdgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices; D. Order Defendant to make whole Martin by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in Paragraphs 7 and 8 above, in amounts to be determined at trial;
3

- - - - - - " - - - - - - - - - - - - - - - - - - - -

--"------~--------

E. Order Defendant to make whole Martin by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices complained ofin Paragraphs 7 and 8 above, including emotional pain, inconvenience and humiliation, in amounts to be determined at trial;
F. Order Defendant to pay Martin punitive damages for its malicious and reckless conduct described in Paragraphs 7 and 8 above, in amounts to be determined at trial;
G. Grant such further relief as the Court deems necessary and proper in the public interest; and
H. Award EEOC its costs in this action. Jury Trial Demand
EEOC requests a jury trial on all questions of fact raised by its Complaint. Respectfully submitted, C. Gregory Stewart General Counsel Gwendolyn Young Reams Associate General Counsel EQUAL EMPLOYMENT OPPORTUNITY

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EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
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Civil Cov~~ Sheet

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

Civil Cover Sheet

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in

:J. September 1974. The data is
information contained herein

required for the neither replaces

unsoerosfutphpeleCmleernktsotfhCe ofuilritngfoar tnhed(J' ijoe'etidaintgisn~te~ciaviPl d1osckeat~eqtu.irTehdeby

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Plaintiff(s): U.S EQUAL EMPLOYMENT OPPORTUNIY COMMISSION

Defendant(s): BURNS SECURITY SERVICES, SECURITY

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County of Residence:

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II. Basis of Jurisdiction:

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

IV. Origin:

2. Removed From State Court

V. Nature of Suit:

442 Employment

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Title VII of the Civil Rights Act of 1964, As amended, 42 U.S.c.

§2000E et seq. & Title I of the Civil Rights Act of 1991,42 U.S.c. §

1981A to correct unlawful practices on the basis of religion.

VII. Requested in Complaint

Class Action:

Dollar Demand:

Jury Demand: Yes

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

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VI_JED STATES DISTRICT COl T '-...-.
NORTHERN DISTRICT OF ILLINOIS

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In the Matter of:

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BURNS INTERNATIONAL SECURITY SERVICES, d/b/a KANE SECURITY

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APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNEgaCf(Ef~8NEY(s) FOR: Sfp '/(£T£O

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION SEP 1 9 2000 JI)Cc;& COAR 2 0 200n

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SIGNATURE t~n'\M.L ~4
I NAMEJE~B. SZROMBA

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FIRM U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION STREET ADDRESS 500 W. MADISON STREET, SUITE 2800

CITYISTATEIZIP CHICAGO, IL 60661 TELEPHONE NUMBER 312-353-7546
E-MAIL ADDRESS

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IDENTIFICATION NUMBER (SEE ITEM 40N REVERSE) ARDC # 06207846

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TELEPHONE NUMBER 312-353-8551

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IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE) ARDC# 01187589

MEMBER OF TRIAL BAR?

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E-MAIL ADDRESS

IFAX NUMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE) ARDe # 06203727

MEMBER OF TRIAL BAR?

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TRIAL ATIORNEY?

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DESIGNATED AS LOCAL COUNSEL? SIGNATURE

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 Minute Order Fonn (06/97)

United States District Court, Northern District of Illinois

Name of Assigned Judge or Magistrate Judge
CASE NUMBER

David H. Coar 00 C 5714

Sitting Judge IfOt~er than Assigned Jutlge
DATE

12/19/2000

CASE TITLE
MOTION:

EEOC, et al vs. Bums International Security
[In the followmg box (a) mdlcate the party fihng the motIOn, e.g., plamtlff, defendant, 3rd party plamtlff, and (b) state bnefly the nature of the motion being presented.]

DOCKET ENTRY:

(I) 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

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 General Rule 21 0 FRCP41(a)(I) 0 FRCP41(a)(2).

(10) •

[Other docket entry] This action is resolved by this consent dec~ee. Defendants are pennanentiy

enjoined from discriminating on the basis of religious beliefs by faili~g to accommodate those beliefs

Bums will modify its unifonn policy to accommodate religious beliefs, provided that such

accommodation does not impose an undue hardship on the company. Bums will pay attorneys fees and

damages year and

in the amount of$50,00.00 the Court retains jurisdiction

to Martin and her attorney. The solely for the purpose of enforcing

cth•oins

sent decree is in Consent Decree.

effect for ENTER

one

• (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. Docketing to mail notices. Mail AO 450 form. Copy to judge/magistrate judge.

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11

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courtroom deputy's initials

mailing deputy initials

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

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

and

)

)

MARQUESHA MARTIN,

)

)

Plaintiff-Intervener, )

)

v.

)

)

BURNS INTERNATIONAL SECURITY

)

SERVICE D/B/A KANE SECURITY,

)

)

Defendant.

)

)

Civil Action No. 00 C 5714 Judge Coar

CONSENT DECREE

Introductiou

1. Plaintiff, Equal Employment Opportunity Commission, ("EEOC") commenced this

action alleging that Defendant Burns International Security Service d/b/a Kane Security ("Burns

International") discriminated against Marquesha Martin ("Martin") in violation of Title VII of the

Civil Rights Act of 1964, as amended 42 U.S.C. Section 2000e et seq. ("Title VII"). Martin

subsequently intervened in the lawsuit. Specifically, EEOC alleged that Burns International refused

to allow Martin to wear her hijab (religious head scarf) pursuant to her religious beliefs, and

terminated her. Burns International denies the allegations.

2. As a result oftheir having engaged in comprehensive settlement discussions, EEOC,

Martin, and Burns International have agreed that this action should be finally resolved by this

Consent Decree. This Consent Decree is intended to and does fully and finally resolve any and all
II

issues and any and all claims arising out of the Complaint filed by EEOC in this action. Nothing contained in this Consent Decree shall be construed as an admission with respect to any ofthe claims of the suit.
Findings Having carefully examined the terms and provisions of this Consent Decree, and based on the pleadings, record, and stipulations of the parties, the Court finds the following: 3. This Court has jurisdiction over the subject matter in this action and of the parties. 4. The terms and provisions ofthis Consent Decree are fair, reasonable, equitable and just. The rights of the parties and the public interest are protected adequately by this Consent Decree. 5. The Consent Decree conforms with the Federal Rules of Civil Procedure and Title VII, and is not in derogation of the rights and privileges of any person. The entry of this Consent Decree will further the objectives of Title VII and will be in the best interest of the parties and the public. NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:
Non-Discrimination 6. Bums International, its officers, agents, successors, and assigns are permanently enjoined from discriminating on the basis of religious beliefs by failing to accommodate those beliefs. 7. Bums International will modify its uniform policy to reasonably accommodate the sincerely held religious beliefs of its employees, providing that such accommodation does not impose an undue hardship on the company.
2

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~..- .. ~-~-.~-~~

Non-Retaliation

8. Bums International, its officers, agents, employees, successors, and assigns shall not

engage in reprisal or retaliation of any kind against any person because ofsuch person's opposition

to any practice made unlawful under Title VII; or because of filing a charge, testifying or

participating in any manner in any investigation, proceeding or hearing under Title VII; or because

an individual was identified as a possible witness for EEOC; or because of any assertion of rights

under this Consent Decree.

Monetary Relief

9.

Bums International will pay attorneys fees and damages in the amount of$50,000.00

to Martin and her attorney as follows: Within five (5) calendar days ofBums International's receipt

of a release executed by Martin after consultation with her attorney, Bums International will send

(1) a certified check for damages in the amount ofFIFTEEN THOUSAND DOLLARS ($15,000.00)

made out to Marquesha Martin to 1411 Division Street, Apt. 407, Baltimore, MD 21217; and (2) a

certified check for attorneys fees in the amount ofTWENTY THOUSAND DOLLARS ($20,000.00)

made out to Kamran Memon to 200 South Michigan Avenue, Suite 1240, Chicago, IL 60604. On

April3, Bums International will send a final certified check to Martin at her address in the amount

ofFIFTEEN THOUSAND DOLLARS ($15,000.00). Within five (5) calendar days of the mailing

of each check, Bums International shall certify to EEOC that the check was mailed and the date on

which it was mailed.

Posting of Notice

10. Within ten (10) calendar days of entry of this Consent Decree, Burns International

shall conspicuously post the Notice of Non-Discrimination attached hereto as Exhibit 1 at both of

Kane Security's facilities in Illinois, in a location or locations readily accessible to and commonly

3

frequented by Kane Security employees. The Notice shall remain posted during the term of this Consent Decree. Bums International shall certify to EEOC within ten (10) calendar days ofthe entry of this Consent Decree that the Notice has been properly posted.
Training 11. Bums International shall provide training concernmg the prohibitions against religious discrimination to all cnrrent Kane Security personnel who are involved in employee assigmnents for Kane Security's facilities in Illinois. Bums International shall provide the training within ninety (90) calendar days ofthe entry ofthe Consent Decree. Within ten (10) calendar days ofthe completion ofthe training, Bums International shall notify the Commission of the dates the training was conducted, the name and job title of the person(s) who conducted the training, and the name and job title of each person who received the training. Bums International shall have the option either to utilize its own employees to conduct this training or to utilize outside consultants.
Record Keeping 12. Bums International shall maintain and keep available for inspection and copying by the Commission for the duration ofthis Consent Decree the following records for Kane Security's facilities in Illinois: A. Documents relating to all persons employed by Kane Security who sought an
accommodation from Kane Security or from Bums International because they could not comply forreligious reasons with Bums International's dress/uniform code or the dress/uniform code of a customer of Bums International, including but not limited to records identifying the employee's name, social security number, home address and telephone number, the accommodation sought, the accommodation provided, if any, or the reason no accommodation was provided;
4

B. Documents relating to all persons who were involuntarily removed from their

positions (i.e., demoted, transferred, or terminated) by Burns International because

they could not comply for religious reasons with Bums International's dress/uniform

code or the dress/uniform code of a customer of Bums International, including but

not limited to records identifYing the employee's name, social security number,

home address and telephone number, date ofremoval from position, name ofposition

from which he/she was removed, and facility at which he/she was employed.

C. All non-privileged documents created, maintained, or utilized by Bums International

in performing or administering the terms ofthis Consent Decree.

13. For the duration of this Consent Decree, Burns International shall make all records

referred to in Paragraph 12 available for inspection and copying by EEOC within a reasonable period

of time after EEOC so requests. For purposes of allowing EEOC to verify Burns International's

compliance with this Consent Decree, Burns International shall make available any agents andlor

employees whom the Commission reasonably asks to interview, accompanied by counsel where

appropriate.

Reporting

14. Every six (6) months for the duration of this Consent Decree, Bums International

shall provide EEOC with a written report containing:

A. A summary ofthe information collected pursuant to Paragraph 12, above, during the

preceding six months; and

B.

A certification by Bums International that the Notice required to be posted in

Paragraph 10, above, remained posted during the entire six month period preceding the report.

5

,
Dispute Resolution 15. Ifthe EEOC has reasonable cause to believe that Bums International has violated any ofthe tenus ofthis Consent Decree, the EEOC shall notify Bums International in writing and Bums International will then have ten (10) business days in which to satisfy the EEOC that there has not been a violation or that the violation has been corrected. If at the expiration ofsuch time period, the dispute has not been resolved to the mutual satisfaction of the EEOC and Bums International, then either party may immediately resort to the Court for a detenuination regarding whether or not any further action or reliefis required under the Consent Decree, and ifso, to seek any appropriate relief.
Duration of Consent Decree and Retention of Jurisdiction 16. The Consent Decree shall be in effect for a period ofone (1) year commencing on the date of entry of this Consent Decree, during which the Court will retain jurisdiction of this matter solely for the purpose of enforcing this Consent Decree.
Miscellaneous Provisions 17. The tenus of the Consent Decree shall be binding and enforceable upon EEOC, Martin, and Bums International and all present and future successors, representatives and assigns of each of them. 18. Bums International shall provide any successor with a copy of this Consent Decree within a reasonable time prior to the conclusion of negotiations for acquisition or assumption of control of Bums International and shall infonu the EEOC of its compliance with this section in writing within five (5) days of such compliance. 19. When this Consent Decree requires submission by Bums International ofreports, certifications, notices, or other materials to the EEOC, they shall be mailed to: Bums International Settlement, c/o Jeanne B. Szromba, Trial Attorney, Equal Employment Opportunity Commission,
6

, .
500 West Madison Street, Suite 2800, Chicago, Illinois, 60661. When this Consent Decree requires submission by the EEOC of materials to Burns International, they shall be mailed to John M. Stephen, PORTER, WRIGHT, MORRIS & ARTHUR, 41 South High Street, Columbus, Ohio 43215.
7

• •

For the Equal Employment Opportunity Commission:
C. Gregory Stewart General Counsel Gwendolyn Young Reams Associate General Counsel Equal Employment Opportunity
Commission Washington, D.C. 20507
~VM\U~FZ nne B. Szromb Trial Attorney Equal Employment Opportunity
Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312)353-7456
Date._D_EC_1_9_2000

For Bums International:
,

ROTHSCHILD BARRY & MYERS 55 West Monroe Suite 3900 Chicago, IL 60603 (312) 372-2345

For Marquesha Martin

~~M ~~ l~"z. h a)TIra A. i4mon

'

Counsel for Plaintiff-Intervener

200 South Michigan Avenue Suite 1240 Chicago, IL 60604 (312) 786-0200

~~(l ~ SO ORDERED
-----+--+-"'-vv Hon. David H. Coar United States District Judge
8

·

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

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

)

Plaintiff,

)

)

and

)

)

MARQUESHA MARTIN,

)

Plaintiff-Intervener, )

v.

)

)

BURNS INTERNATIONAL SECURITY

)

SERVICE D/B/A KANE SECURITY,

)

)

Defendant.

)

)

Civil Action No. 00 C 5714 Judge Coar

NOTICE TO ALL KANE SECURITY EMPLOYEES

This Notice is posted pursuant to a Consent Decree jointly agreed upon between the U.S. Equal Employment Opportunity Commission and Burns International Security Service resolving a lawsuit in U.S. District Court, No. 00 C 5714.

The lawsuit alleged that Bums International Security Service d/b/a Kane Security ("Kane") had violated Title VII of the Civil Rights Act of 1964, as amended, by failing to accommodate the religious practices of one of its employees and then terminating her. Kane denies the allegations. Kane and the EEOC entered into the Consent Decree as an amicable way ofproviding monetary reliefto the former employee who filed the charge upon which the lawsuit was based, and resolving all outstanding differences that may have existed in this case.

The Consent Decree provides that Kane will apply and enforce policies which require the company to reasonably accommodate the religious beliefs of its employees. It also provides that Kane will follow the laws against discrimination, and pay monetary damages to the employee who filed the original charge.

Title VII prohibits employers from discriminating on the basis of sex, race, color, religion or national origin, and from retaliating against employees who oppose any practice made unlawful by Title VII. The Equal Employment Opportunity Commission is the agency responsible for enforcing Title VII. If you have any complaints of discrimination or questions concerning your rights under Title VII, you may contact the EEOC at the address and phone number given below.

Equal Employment Opportunity Commission Dated:_ _ _ _ _ _ _ _ _ _ _ __

Bums International Security Service d/b/a Kane Security

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED OR REMOVED
This Notice must remain posted for one (1) year from the date shown above. Any complaints of discrimination or questions concerning this Notice or compliance with its provisions may be directed to the Equal Employment Opportunity Commission, Chicago District Office. Telephone:(312) 353-7546.

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?756823580870594-L_35...
BROWN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:00-cv-05714

EEOC v. Burns Intl Sec Svc Assigned to: Hon. David H. Coar Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/18/2000 Date Terminated: 12/19/2000 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Jeanne B. Szromba United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7546 Email: jeanne.szromba@eeoc.gov LEAD ATTORNEY 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

Jose Jorge Behar Hughes Socol Piers Resnick & Dym Ltd. 70 West Madison Street Suite 4000 Chicago, IL 60602 (312) 580-0100 Fax: 312-580-1994 Email: jbehar@hsplegal.com ATTORNEY TO BE NOTICED

V. Defendant

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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?756823580870594-L_35...

Burns International Security Services Corporation

represented by Roger J. Guerin Rothschild, Barry & Myers, P.C. 55 West Monroe Street Xerox Centre, Suite 3900 Chicago, IL 60603-5012 (312) 372-2345 Email: rguerin@shb-law.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
William J. Raleigh Nisen & Elliott 200 West Adams Street Suite 2500 Chicago, IL 60606 (312) 346-7800 TERMINATED: 10/25/2000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan S. Madans Rothschild, Barry & Myers, P.C. 55 West Monroe Street Xerox Centre, Suite 3900 Chicago, IL 60603-5012 (312) 372-2345 Email: madans@rbmchicago.com ATTORNEY TO BE NOTICED
John M Stephen Porter, Wright, Morris & Arthur 41 South High Street Columbus, OH 43215 (614) 227-2030 ATTORNEY TO BE NOTICED
Margaret Mary Cahill Raleigh & Cahill, P.C. 200 West Adams Suite 2505 Chicago, IL 60606 (312) 460-0600 TERMINATED: 10/25/2000
Robert W Edmund Porter, Wright, Morris & Arthur 41 South High Street Columbus, OH 43215 (614) 227-2030

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Intervenor Plaintiff Marquesha Martin

Sherrill Ann Otto Raleigh & Cahill, P.C. 200 West Adams Suite 2505 Chicago, IL 60606 (312) 460-0600 TERMINATED: 10/25/2000
represented by Kamran A. Memon Law Offices of Kamran Memon 200 South Michigan Avenue Suite 1240 Chicago, IL 60604 (312) 961-2354 Email: discrimination@hotmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/18/2000 09/22/2000 09/29/2000 10/12/2000
10/13/2000 10/20/2000 10/20/2000

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Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of Jeanne B. Szromba and Jose J. Behar, John C. Hendrickson as attorney(s) for plaintiff EEOC (No summons(es) issued.) (Documents: 1-1 through 1-3) (hp) (Entered: 09/19/2000)
2 ATTORNEY APPEARANCE for Burns Intl Sec Svc by William J. Raleigh, Margaret Mary Cahill, Sherrill Ann Otto (tlm) (Entered: 09/27/2000)
3 WAIVER of service of summons as to defendant sent on 9/18/00 (hp) (Entered: 10/02/2000)
SCHEDULE set on 10/12/00 by Hon. David H. Coar : Rule 16(b) Scheduling/Pretrial conference set to 11:30 12/1/00 in chambers. The court hereby opts into Rule 26(a)(1) for purposes of this case. Report of planning conference pursuant to Rule 26(f) and proposed scheduling order pursuant to Rule 16(b) to be filed in chambers. (See reverse side of scheduling order. Copies of form reports of planning conference and proposed scheduling order are available in chambers or on the court's web page.) Mailed notice (pm) (Entered: 10/12/2000)
4 MOTION by Marquesha Martin to intervene (Attachment); Notice (hp) (Entered: 10/25/2000)
6 SUBSTITUTION of attorneys Raleigh & Cahill, P.C. in place of Rothschild, Barry & Myers by defendant; Notice (hp) Modified on 10/26/2000 (Entered: 10/26/2000)
7 ATTORNEY APPEARANCE for defendant Burns International Security Services d/b/a The Kane Service, incorrectly sued herein as Burns International Services d/b/a Kane Security by Roger J. Guerin and Alan S. Madans (hp)

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10/23/2000 10/25/2000 10/25/2000 10/25/2000 10/25/2000
11/16/2000 11/22/2000 11/27/2000 11/28/2000
11/28/2000 11/30/2000
12/15/2000 12/19/2000

(Entered: 10/26/2000)
5 MINUTE ORDER of 10/23/00 by Hon. David H. Coar : Marquesha Martin's motion to intervene [4-1] is entered and continued to 10/25/00 at 9:15 a.m. No notice (hp) (Entered: 10/25/2000)
8 APPLICATION for leave to appear pro hac vice by John M. Stephen for defendant Burns Intl Sec Svc ; Order entered granting leave by Hon. David H. Coar (hp) (Entered: 10/26/2000)
9 APPLICATION for leave to appear pro hac vice by Robert W. Edmund for defendant Burns Intl Sec Svc; Order entered granting leave by Hon. David H. Coar (hp) (Entered: 10/26/2000)
10 ATTORNEY APPEARANCE for defendant by John M. Stephen and Robert W. Edmund (hp) (Entered: 10/26/2000)
11 MINUTE ORDER of 10/25/00 by Hon. David H. Coar : Marquesha Martin's motion to intervene as a party plaintiff is granted. [4-1] Pursuant to the substitution of attorneys, leave granted Raleigh & Cahall, P.C. to withdraw as attorneys for the defendant and leave granted Rothschild Barry & Myers to file and substitute appearance for the defendant. Mailed notice (hp) (Entered: 10/26/2000)
14 MOTION by defendant for extension of time to file responsive pleading to plaintiff's and intervneor's complaint ; Notice (hp) (Entered: 11/30/2000)
12 REPORT by parties planning conference; Notice (hp) (Entered: 11/29/2000)
13 MINUTE ORDER of 11/27/00 by Hon. David H. Coar : Defendant's motion for extension of time to file responsive pleading is granted to and including 11/30/00. No notice (hp) (Entered: 11/29/2000)
SCHEDULE set on 11/28/00 by Hon. David H. Coar : Rule 16(b) Schedulin/Pretrial conference reset to 9:30 12/19/00. Jean Szromba, attorney for EEOC, advised that this case is tentatively settled. Mailed notice (pm) (Entered: 11/28/2000)
15 MOTION by defendant for extension of time to file responsive pleading to intervenor's complaint ; Notice (hp) (Entered: 12/01/2000)
16 MINUTE ORDER of 11/30/00 by Hon. David H. Coar : Defendant's motion for extension of time to file responsive pleading is granted. [15-1] Burns to answer or plead on or before 12/19/00, no further extensions. Mailed notice (hp) (Entered: 12/01/2000)
SCHEDULE set on 12/15/00 by Hon. David H. Coar : Pretrial conference reset to 9:30 12/20/00 Telephone notice (pm) (Entered: 12/15/2000)
17 MINUTE ORDER of 12/19/00 by Hon. David H. Coar : This action is resolved by this consent decree. Defendants are permanently enjoined from discriminating on the basis of religious beliefs by failing to accommodate those beliefs Burns will modify its uniform policy to accommodate religious beliefs, provided that such accommodation does not impose an undue hardship on the company. Burns will pay attorneys fees and damages in the amount of $50,000.00 to Martin and

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her attorney. The consent decree is in effect for one year and the Court retains jurisdiction solely for the purpose of enforcing this Counsent Decree. (Entered Consent Decree.) terminating case Notices mailed by judge's staff. (hp) (Entered: 12/28/2000)

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