IN THE UNITED STATES DISTRICT COURT

FILED cA-STuE~N ~li~~RRI;C(JT COURT -~I • • A':Vt.NSAS

EASTERN DISTRICT OF ARKANSAS EASTERN DIVISION
EQUAL EMPLOYMENT OPPORTUNITY

OCT 2 7 1998

JAMES VV, Nit:L

By:

l:HK

--~-£:?!"¥4-_

COMMISSION,

PLAINTIFF

VS.

H-C-98-008

THE CAJUN COMPANY, INC.

DEFENDANT

ORDER GRANTING PLAINTIFF'S MOTION TO COMPEL
Plaintiff asks the Court to order Defendant to produce documents for inspection and
copying which indicate the full name, job title, race, Social Security number, last known home
address, and last known home telephone number of all persons who have been employed by
Defendant and who were assigned to the same work-site as Wayne Bordelon, a supervisory
employee of Defendant, at any time during the period from May 9, 1992 to the time when Mr.
Bordelon's employment with the Defendant ended. Further, Plaintiff requests documents
showing the address of the relevant work-site where the person was assigned, the period of time
in which the person and Mr. Bordelon were assigned to the relevant work-site, and the name,
address, home telephone number, and work telephone number of any persons identified by the
employee for notification in case of emergency. Defendant objects to Plaintiffs requests.
Defendant contends that the requests are irrelevant, unreasonable, burdensome, and speculative.
Federal Rule of Civil Procedure 26(b)(1) states:
Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, ... including ... the identity and location of persons having any knowledge of any discoverable matter. The information sought need not be admissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.

- Fed. R.Civ. P. 26(b)(I).
After reviewing the law and the briefs of the parties, the Court finds that Plaintiff should be provided the information requested in its motion to compel. Plaintiff has stated in its Complaint and its Amended Reasonable Cause Determination that the Charging Party, Mr. Rickey Lee, and other Black employees were racially harassed, subjected to different terms and conditions of employment, and discharged or constructively discharged because of their race by the Defendant. Testimony regarding Mr. Bordelon's treatment of Black employees and his comparable treatment of white employees by other persons who worked with, or under Mr. Bordelon's supervision, at Defendant's work-sites is relevant to a determination of the facts in this case. Without the information which Defendant possesses as to whom these persons are, and where they may be contacted, Plaintiff is precluded from uncovering this relevant evidence.
Defendant argues that Plaintiff's requests for information should be limited to the Helena work-site in which Mr. Lee worked with Mr. Bordelon. The Court believes that Plaintiff should be allowed to discover evidence outside the Helena work-site. There is no evidence that management at the Helena site made independent policy decisions. Therefore, the Court believes that evidence gathered from other work-sites regarding Mr. Bordelon's conduct and Defendant's reaction to, or knowledge of, Mr. Bordelon's conduct may be.relevant. Further, the Court notes that the Helena project lasted only 2 months. Limiting Plaintiffs discovery requests to the Helena work-site would also unduly restrict Plaintiff's discovery time period.
Next, Defendant argues that it should only be obligated to produce information on persons employed by Defendant within 180 days before Mr. Lee's Charge was filed. However, "[i]ncidents which occurred outside the filing period also may be admissible as relevant

background to later discriminatory acts." Kimzey v. Wal-Mart Stores. Inc., 107 F.3d 568, 573 (8th

Cir. 1997)(citing Uni!edAir Lines. Inc. v. Evans, 431 U.S. 553, 558, 97 S.Ct. 1885, 1889,52

L.Ed.2d 571 (1977»). Therefore, Defendant m~st supply the requested information for the period

from May 9, 1992 to the time when Wayne Bordelon's employment with the Defendant ended.

Finally, the Court does not believe the production of the requested information would be

unreasonably burdensome to Defendant. It is noted that Ms. Julia E. Davis, Office

ManagerlExecutive Assistant to the President of Defendant, has already reviewed the personnel

records for the years 1993 and 1994 to prepare her affidavit for Defendant's Motion to Transfer

Venue. However, "[w]hat is of importance is that the records are relevant and material, so that

mere inconvenience to an employer should not justifY withholding the documents from the

Commission." EEOC v. Quick Shop Markets. Inc., 396 F. Supp. 133, 137 (E.D. Mo. 1975).

Accordingly, Plaintiff s motion to compel discovery (Docket # 15) is granted. If the

parties cannot agree on a date certain for the production herein ordered, a conference call should

be scheduled, through Ms. Mary Johnson (501-324-6800), on or before November 5,1998.

C:!Jf!t- IT IS SO ORDERED this

day of October, 1998.

. THIS DOCUMENT ENTERED O~ ~

, DOCKET SHEET IN COMPLIANCE:

, WITH RULE 5 ANDIOR ~~p ,

ON 10

BY_ _+-I-:.:t.GJl:!~io---

S DISTRICT JUDGE

lb UNITED STATES DISTRICT COURT Eastern District of Arkansas U.S. Post Office & Court House 600 West Capitol, Suite 402 Little Rock, Arkansas 72201-3325
October 27, 1998

* * MAILING CERTIFICATE OF CLERK * *
Re: 2:98-cv-00008.

True and correct copies of the attached were mailed by the clerk to the following:

Dan F. Bufford, Esq. Laser, Wilson, Bufford & Watts, 101 South Spring Street
Suite 300 Little Rock, AR 72201-2488

P.A.

Gregory Guidry, Esq. Onebane, Bernard, Torian, Diaz, McNamara & Abell 102 Versailles, Suite 600
Post Office Box 3507 Lafayette, LA 70502-3507

Maria F. Manuel, Esq. Onebane, Bernard, Torian, Diaz, McNamara & Abell 102 Versailles, Suite 600 Post Office Box 3507 Lafayette, LA 70502-3507

Carson L. Owen, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104

Terry Beck, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104

Katharine W. Kores, Esq.
Equal Employment Opportunity Commission 1407 Union Avenue
Suite 621 Memphis, TN 38104

press

Date:

16 - ~1-rl

James W. McCormack, Clerk BY:

 
 IN THE UNITED STATES DISTRICT COURT

FILED
u s rw; inleT COURT

t' AS T F'~ . i ;. C:' ~ ,( 1 (\;1 c~ '\ NS

FOR THE EASTERN DISTRICT OF ARKANSAS

~:T l 4: 1999

EASTERN DIVISION

I;."., _ _ _ _-+~~~

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff,
v.
THE CAJUN COMPANY, INC.,
Defendant.

)

)

)

)

) CIVIL ACTION NO.

)

)

H-C-98-008

)

)

)

CONSENT DECREE

This lawsuit was filed January 28, 1998 by the Equal Employment Opportunity Commission (EEOC) against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). The Complaint in the lawsuit claims that Cajun Company racially harassed Black employees bHcause of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees b€~cause of their race.
EEOC and Cajun Company have agreed to this consent decree to settle all of the claims involved in this lawsuit.
The Court has reviewed the terms of this decree in light of the applicable laws and regulations, and hereby approves this decree. THEREFORE, it is hereby ORDERED:

I. JURISDICTION The United States District Court for the Eastern District of Arkansas, Eastern Division, has jurisdiction over the parties and subject matter of this lawsuit, and will retain jurisdiction over this decree for purposes of enforcement and dispute resolution.
II. DISCLAIMER Neither the negotiation of or agreement to this decree is an admission or acknowledgment by Cajun Company that any of its employees, officers, directors, or agents have violated Title VII.
III. DURATION OF DECREE This dBcree will be binding on the parties to this lawsuit for three years after the date of its entry by the Court.
IV. INJUNCTIVE RELIEF Cajun Company, its supervisors, managers, officers, directors, agents, and successors are enjoined from discriminating against employees because of their race.
V. INDIVIDUAL REMEDIES Cajun Company will pay Anthony Adams $10,000.00. Cajun Company will send the payment to Mr. Adams to:
Anthony Adams P.O. Box 416/B Barataria, LA 70036 within ten days after receiving: 1. A copy of this decree after its entry by the Court; and .2. The Release attached to this decree signed by Mr. Adams.
2

A copy of the check (front and back), and of the payment transmittal, will be mailed at
the same timt9 to: Carson L. Owen, Senior Trial Attorney Equal Employment Opportunity Commission 1407 Union Ave., Suite 621 Memphis, TN 38104.
Cajun Company will pay Willard Coleman $10,000.00. Cajun Company will
send the payment to Mr. Coleman to: Willard Coleman Route 1, Box 222 Holly Grove, AR 72069
within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Coleman.
A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above.
Cajun Company will pay Nathan Davis $40,000.00. Cajun Company will send
the payment to Mr. Davis to: Nathan Davis 1061 Georgia Ave. Port Allen, LA 70767
within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Davis.
A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above.
3

Cajun Company will pay Michael Houston $2,000.00. Cajun Company will send the payment to Mr. Houston to:
Michael Houston P.O. Box 328 Fayette, MS 39069 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Houston. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above. Cajun Company will pay Farrel Isom $2,000.00. Cajun Company will send the payment to Mr. Isom to: Farrellsom 12812 Maple Street Vacherie, LA 70090 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Isom. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same timE! to Carson Owen at the address shown above. Cajun Company will pay Bruce Jacobs $23,000.00. Cajun Company will send the payment to Mr. Jacobs to: Bruce Jacobs P.O. Box 1953 Harvey, LA 70059-1953
4

within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Jacobs.
A copy of thE! check (front and back), and of the payment transmittal, will be mailed at the same timB to Carson Owen at the address shown above.
Cajun Company will pay Herbert Jenkins $23,000.00. Cajun Company will send the payment to Mr. Jenkins to:
Herbert Jenkins P.O. Box 679 Boutte, LA 70039 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Jenkins. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above. Cajun Company will pay Rickey Lee $60,000.00. Cajun Company will send the payment to Mr. Lee to: Rickey Lee, No. 610558
~;.\AI.A.C.P.C.
Texarkana, AR 71854 within ten days after receiving:
1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Lee. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above.
5

Cajun Company will pay Renard Markee $70,000.00. Cajun Company will send the payment to Mr. Markee to:
Renard Markee P.O. Box 835 Boutte, LA 70039 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Markee. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above. Cajun Company will pay Charles Roberts $40,000.00. Cajun Company will send the payment to Mr. Roberts to: Charles Roberts 312 Travis Dr. Avondale, LA 70094 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and :2. The Release attached to this decree signed by Mr. Roberts. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time! to Carson Owen at the address shown above. Cajun Company will pay Martin Smith $65,000.00. Cajun Company will send the payment to Mr. Smith to: Martin Smith '10844 Alco Ave" Apt. B Baton Rouge, LA 70816 within ten days after receiving:
6

1. A copy of this decree after its entry by the Court: and 2. The Release attached to this decree signed by Mr. Smith. A copy of thE~ check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above. Cajun Company will pay Victor Winston $5,000.00. Cajun Company will send the payment to Mr. Winston to: Victor Winston 1910 West 30th Pine Bluff, AR 71603 within ten days after receiving: 1. A copy of this decree after its entry by the Court: and 2. The Release attached to this Decree signed by Mr. Winston. A copy of the check (front and back), and of the payment transmittal, will be mailed at the same time to Carson Owen at the address shown above.
VI. POSTING OF NOTICE Cajun Company will post the notice attached to this decree for thirty days in conspicuous places at each of its job sites where notices to employees are customarily posted. Within ten days after the entry of this decree Cajun Company will send a letter to Carson Owen, at the address indicated above, verifying that the notice has been posted.
VII. POLICY PROHIBITING RACIAL HARASSMENT Cajun Company has a policy prohibiting racial harassment which includes a procedure for communicating the policy to employees and a procedure for reporting and investigating complaints alleging racial harassment.
7

VIII. TRAINING Cajun Company has trained all of its supervisory and management employees, including foremen, in the prohibitions of the federal employment discrimination laws and Cajun Company's policy prohibiting racial harassment.
IX. REPORTING Cajun Company will submit a report to Carson L. Owen, at the address indicated above, six months after the entry of this decree, and every six months thereafter during the duration of this decree. Each report will describe all complaints received from employees concerning racial language or conduct at work, includin!J the name, home address, and home telephone number of each employee who complained, the nature of the complaint, what action, if any, was taken in response to the complaint, and if no action was taken an explanation of why no action was taken. With the first report, Cajun Company will submit a copy of the curriculum for its training program.
X. ATTORNEY'S FEES AND COSTS EEOC and Cajun Company will each bear its own attorneys' fees and costs incurred in this action.

/3 if ~'L/ SO ORDERED this

day of

, 1999,

8

Consented to on behalf of the respective parties:

FOR PLAINTIFF EEOC:
C. GREGORY STEWART General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel

FOR DEFENDANT:
Le t rCfA~ ----E. F. DUHE', JR., PresidentTHE CAJUN COMPANY, INC.

cK'wtNu'\vJ~L ,(~
KATHARINE W. KORES Regional Attorney

TERRY B Ct< Supervisory Trial Attorney
CARSON L. ()WEN Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1407 Union Avenue, Suite 621 Memphis, Tennessee 38104 Telephone No. (901) 544-0133

102 Versailles, Suite 600 P.O. Box 3507 Lafayette, LA 70507-3507 Telephone No. (318) 237-2660
ATTORNEYS FOR DEFENDANT
Local Counsel:
LASER, WILSON, BUFFORD & WATTS, P.A.
101 South Spring Street, Suite 300 Little Rock, Ar 72201-2488 Telephone No. (501) 376-2981 1.0. No. 72014

9

RELEASE OF ANTHONY ADAMS I, Anthony Adams, P.O. Box 416/B, Barataria, LA 70036, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, ~1 seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $10,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructivelly discharged me because of my race. I understand that the $10,000.00 is bein~l paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before Signing this release.

Subscribed and sworn to before me this _ day of _ _ _ _ _ _, 1999.

Anthony Adams

Notary Public

My commission expires ___._ _ _ _ __

RELEASE OF WILLARD COLEMAN I, Willard Coleman, Route 1, Box 222, Holly Grove, AR 72069, understand that the United States Equal Employment Opportunity Commission (E EOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act oif 1964, as amended, 42 U.S.C. Section 2000e, et ~,eq. (Title VII). understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees. to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $10,000.00 by Cajun Company. In considel'ation for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $10,000.00 is bein~1 paid to me and accepted by nne in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given thIS opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_dayof _ _ _ _ _ _, 1999.

Willard Coleman

Notary Public

My commission expires __._ _ _ _ __

RELEASE OF NATHAN DAVIS I, Nathan Davis, 1061 Georgia Ave., Port Allen, LA 70767, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $40,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $40,000.00 is being paid to me and accepted by rne in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this _ day of _ _ _ _ _ _• 1999.

Nathan Davis

Notary Public

My commission expires ___._ _ _ _ __

RELEASE .OF MICHAEL HOUSTON I, Michael Houston, P.O. Box 328, Fayette, MS 39069, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $2,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $2,000.00 is being paid tQi me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_day Qif _ _ _ _ _ _, 1999.

Michael Houston

Notary Public

My commission expires __._ _ _ _ __

RELEASE OF FARREL 150M I, Farrel Isom, 12812 Maple Street, Vacherie, LA 70090, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees bl9cause of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $2,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $2,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_dayof _ _ _ _ _ _, 1999.

Farrellsom

Notary Public

My commission expires _ _._ _ _ _ __

RELEASE OF BRUCE JACOBS I, Bruce Jacobs, P.O. Box 1953, Harvey, LA 70059-1953, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. II understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $23,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructivel'y discharged me because of my race. I understand that the $23,000.00 is bein~1 paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_dayof _ _ _ _ _ _, 1999.

Bruce Jacobs

Notary Public

My commission expires ___._ _ _ _ __

RELEASE OF HERBERT JENKINS I, Herbert Jenkins, P.O. Box 679, Boutte, LA 70039, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $23,000.00 by Cajun Company_ In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $23,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this _ day of _ _ _ _ _ _, 1999.

Herbert Jenkins

Notary Public

My commission expires _________

RELEASE OF RICKEY LEE I, Rickey Lee, No. 610558, S.W.A.C.P.C., Texarkana, AR 71854, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et ~;iill. (Title VII). understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $60,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $60,000.00 is beingl paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given thl9 opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_dayof ______,1999.

Rickey Lee

Notary Public

My commission expires __________

RELEASE OF RENARD MARKEE I, Renard Markee, P.O. Box 835, Boutte, LA 70039, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race" and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $70,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $70,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this_dayof _ _ _ _ _ _ , 1999.

Renard Markee

Notary Public

My commission expires _ _._ _ _ _ __

RELEASE OF CHARLES ROBERTS I, Charles Roberts, 312 Travis Dr., Avondale, LA 70094, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (TitlE! VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $40,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $40,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me
this_day 01' _ _ _ _ _ _, 1999.

Charles Roberts

Notary Public

My commission expires ___._ _ _ _ __

RELEASE OF MARTIN SMITH I, Martin Smith, 10844 Alco Ave., Apt. B, Baton Rouge, LA "10816, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et !;;eq. (Title VII). understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $65,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to dlifferent terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $65,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given thH opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this _ day 01f _ _ _ _ _ _, 1999.

Martin Smith

Notary Public

My commission expires _________

RELEASE OF VICTOR WINSTON I, Victor Winston, 1910 West 30th, Pine Bluff, AR 71603, understand that the United States Equal Employment Opportunity Commission (EEOC) has filed a lawsuit against The Cajun Company, Inc. (Cajun Company) under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seq. (Title VII). I understand that EEOC claims in the lawsuit that Cajun Company racially harassed Black employees because of their race, subjected Black employees to different terms and conditions of employment because of their race, and constructively discharged Black employees because of their race. I understand that Cajun Company denies that any racial harassment or other racial discrimination occurred. I understand that a settlement has been agreed to by EEOC and Cajun Company, and that as part of that settlement I will be paid $5,000.00 by Cajun Company. In consideration for receiving this amount of money from Cajun Company, I hereby release Cajun Company from any claims that Cajun Company racially harassed me, subjected me to different terms and conditions of employment because of my race, or constructively discharged me because of my race. I understand that the $5,000.00 is being paid to me and accepted by me in settlement of all such claims. I have read this release, I understand it, and I have voluntarily signed it. I have been given the opportunity to consult with an attorney before signing this release.

Subscribed and sworn to before me this _ day of _ _ _ _ _ _, 1999.

Victor Winston

Notary Public

My commission expires _________

1.J.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Memphis District Office

1407 Union Avenue, Suite 621

Memphis, TN 38104 (901) 544-0115
TTY (901) 544-0112 FAX (901) 544-0111

NOTICE

This Notice is being posted as part of a settlement agreement between The

Cajun Company, Inc. (Cajun Company) and the United States Equal Employment

Opportunity Commission (EEOC).

EEOC enforces Title VII of the Civil Rights Act of 1964 (Title VII), which prohibits

employment discrimination based on race, color, religion, sex, or national origin; the

Age Discrimination in Employment Act; the Equal Pay Act; sections of the Civil Rights

Act of 1991:: and Title I of the Americans With Disabilities Act, which prohibits

discrimination against people with disabilities.

Cajun Company supports and will comply with these Federal laws in all respects,

and will not take any action against employees or applicants for employment because

they have exercised their rights under the law by complaining about discrimination or

by filing a discrimination charge with EEOC.

A former employee of ours filed a discrimination charge with EEOC complaining

about being subjected to racial harassment and racial discrimination by one of our

foremen. EEOC filed a lawsuit against us in which it claimed that a number of Black

employees had been racially harassed and discriminated against by the foreman. The

foreman is no longer employed by our company. Settlement amounts have been paid

to each of the Black employees EEOC claims were discriminated against. The

settlement was not an admission of liability by Cajun Company, but rather was made

to amicably resolve the matter with EEOC. We have a strong policy prohibiting racial

harassment and racial discrimination, and each of you received a copy of that policy.

Any employee who we find has engaged in racial harassment or racial discrimination will be disciplined or discharged.

.J .

.J

C
.

(/).~
>L4- /'

/.'1.., /.J.:_ _

E. F. Duhe', Jr., president

The Cajun Company, Inc.

2

lb UNITED STATES DISTRICT COURT Eastern District of Arkansas U.S. Post Office & Court House 600 West Capitol, Suite 402 Little Rock, Arkansas 72201-3325
October 14, 1999

* * MAILING CERTIFICATE OF CLERK * *
Re: 2:98-cv-00008.

True and correct copies of the attached were mailed by the clerk to the following:

Dan F. Bufford, Esq. Laser, Wilson, Bufford & Watts, 101 South Spring Street Suite 300 Little Rock, AR 72201-2488

P.A.

Gregory Guidry, Esq. Onebane, Bernard, Torian, 102 Versailles, Suite 600 Post Office Box 3507 Lafayette, LA 70502-3507

Diaz,

McNamara

& Abell

Maria F. Manuel, Esq. Onebane, Bernard, Torian, 102 Versailles, Suite 600 Post Office Box 3507 Lafayette, LA 70502-3507

Diaz,

McNamara

& Abell

Carson L. Owen, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104

Terry Beck, Esq.
Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104

Katharine W. Kores, Esq.
Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104

press/f~(
10/14/99 Date:

James W. McCormack, Clerk
LiEda Bell BY:

 
 IN THE UNITED STATES DISTRICT COURT

FILED u.s. DISTRICT COURT
- EASTER~I DISTRICT ARKANSAS

FOR THE EASTERN DISTRICT OF ARKANSAS

EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

) CIVIL ACTION NO.

Plaintiff,

) )

" . c~ 9 8 - 0 08

)

v.

)

COMPLAINT

)

THE CAJUN COMPANY, INC.,

) CLASS IN NATURE ACTION

)

Defendant.

) JURY TRIAL DEMAND~IAI

This case assigned to District JU~ - f l l Lfq)

NATURE OF THE ACTiiifio Magistrate Judge

t-~#].

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 race and to provide

appropriate relief to Rickey Lee and other Black employees who were

racially harassed, subjected to different terms and conditions of

employment, and discharged or constructively discharged by

Defendant Employer because of their race.

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 Sections 706(f) (1) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, (Title VII),

42 U.S.C. §§ 2000e-5(f) (1) and (3), and section 102 of the Civil

Rights Act of 1991, 42 U.S.C. § 1981a.

2. The employment practices alleged to be' unlawful were

committed within the jurisdiction of the United states District

court for the Eastern District of Arkansas, Eastern Division.

PARTIES 3. Plaintiff, .the Equal Employment opportunity Commission (the Commission), is an 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) of Title VII, 42 U.S.C. Section 2000e-5(f) (1). 4. At all relevant times Defendant, The Cajun Company, Inc. (Defendant Employer), has continuously been a Louisiana corporation doing business in the state of Arkansas and the city of Helena, and has continuously had at least fifteen employees. 5. At all relevant times Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of section 701(b), (g), and (h) of Title VII, 42 U.S.C. section 2000e-(b), (g), and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit Rodney Branch filed a charge with the Commission alleging violations of Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least May 9, 1992, Defendant Employer has engaged in unlawful employment practices at its facilities, including but not limited to its Helena, Arkansas facility, in violation of Section 703 (a) of Title VII, 42 U.S.C. Section 2000e2(a). The unlawful employment practices involved racially harassing Rickey Lee and other Black employees, SUbjecting them to different terms and conditions of employment, and discharging or
2

constructively discharging them because of their race. The unlawful employment practices included allowing a White foreman, Wayne Borderlon, to repeatedly call Black employees "niggers", to repeatedly make other racist remarks to Black employees, to treat Black employees more harshly than White employees were treated, and to discharge or constructively discharge Black employees because of their race.
8. The effects of the practices complained of in paragraph 7 above have been to de~rive Mr. Lee and other Black employees pf equal employment opportunities and otherwise adversely affect their status as employees because of their Race, and to cause them emotional and psychological harm.
9. The unlawful employment practices complained of in paragraph 7 above were intentional.
10. The unlawful employment practices complained of in paragraph 7 above were done with malice and/or reckless indifference to the federally protected rights of Mr. Lee and other Black employees.
REQUEST FOR RELIEF Therefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates against employees or applicants for employment because of race;
3

B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for Black employees, and which eradicate the effects of its unlawful employment practices;
c. Order Defendant Employer to make whole Rickey Lee and
other Black employees 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 Employer to make whole Mr. Lee and other Black employees by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in' paragraph 7 above, in amounts to be determined at trial;
E. Order Defendant Employer to make whole Mr. Lee and other Black employees by providing compensation for nonpecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including emotional pain, suffering, anger, and embarrassment, in amounts to be determined at trial;
F. Order Defendant Employer to pay Mr. Lee and other Black employees punitive damages for its malicious and/or reckless conduct described in paragraph 7 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 the Commission its costs of this action.
4

JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
C. GREGORY STEWART General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
+{~L.~
KATHARINE W. KORES
Regional Attorney
Supervisory Trial Attorney
CARSON L. OWEN
Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1407 Union Avenue, suite 621 Memphis, Tennessee 38104 . Telephone number: (901) 544-0133
5

 
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Page 1 of 5

DISC, HDY, TERMED
U.S. District Court Eastern District of Arkansas (Helena) CIVIL DOCKET FOR CASE #: 2:98-cv-00008-WRW

EEOC v. Cajun Company Inc Assigned to: Judge William R. Wilson, Jr Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 01/28/1998 Date Terminated: 10/14/1999 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Carson L. Owen Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0133 Email: carson.owen@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Katharine W. Kores Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0135 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Terry Beck Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0138 Email: terry.beck@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant

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Cajun Company Inc

represented by Dan F. Bufford Laser Law Firm P.A. 101 South Spring Street Suite 300 Little Rock, AR 72201-2488 (501) 376-2981 Email: dbufford@laserlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Guidry Onebane, Bernard, Torian, Diaz, McNamara & Abell Post Office Box 3507 Lafayette, LA 70502-3507 (337) 237-2660 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Maria F. Manuel Onebane, Bernard, Torian, Diaz, McNamara & Abell Post Office Box 3507 Lafayette, LA 70502-3507 (337) 237-2660 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 01/28/1998 02/11/1998 02/24/1998 04/09/1998 04/09/1998 04/09/1998 04/15/1998
06/19/1998

#

Docket Text

1 COMPLAINT with jury demand, filing fee waived/summons were not issued (jap) Modified on 01/28/1998 (Entered: 01/28/1998)

2 REQUEST by plaintiff for admissions (bkp) (Entered: 02/12/1998)

3 WAIVER OF SERVICE OF SUMMONS upon defendant Cajun Company Inc on 2/17/98 (former empl) (Entered: 02/25/1998)

4 MOTION by defendant for attorney Gregory Guidry and Maria F. Manuel to appear pro hac vice (bsm) (Entered: 04/10/1998)

5 DEFENSES AND ANSWERS by defendant; jury demand (bsm) (Entered: 04/10/1998)

6 RESPONSE by defendant to pltf's first request for admissions (bsm) (Entered: 04/10/1998)

7 ORDER by Judge William R. Wilson granting motion for attorney Gregory Guidry and Maria F. Manuel to appear pro hac vice as counsel for deft [4-1] (cc: all counsel) (former empl) (Entered: 04/16/1998)

8 SCHEDULING ORDER by Judge William R. Wilson setting jury trial

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07/22/1998 07/22/1998 07/31/1998 08/04/1998 08/07/1998 08/10/1998
08/18/1998 08/24/1998 08/24/1998 08/24/1998 08/26/1998 09/02/1998
09/04/1998 10/27/1998

for 9:00 the week beginning 3/15/99 in Helena; discovery due 1/15/99; pretrial info sheet due 2/15/99 (cc: all counsel) (former empl) (Entered: 06/22/1998)
9 MOTION by Cajun Company Inc to change venue to the Western District of Louisiana (former empl) (Entered: 07/23/1998)
10 MEMORANDUM by Cajun Company Inc in support of motion to change venue to the Western District of Louisiana [9-1] (former empl) (Entered: 07/23/1998)
11 MOTION by EEOC for extension of time to respond to deft's mot to transfer venue (former empl) (Entered: 08/03/1998)
CLERK'S MINUTES: Telephone conference re discovery disputes; pltf to file motion and brief by 8/25/98; deft to respond by 9/4/98; reply due 9/9/98; pltf to prepare Order (C. Newburg) (maj) (Entered: 08/05/1998)
12 ORDER by Judge William R. Wilson granting pltf's motion for extension of time to respond to deft's mot to transfer until 8/18/98 [11-1] [9-1] (cc: all counsel) EOD 8/7/98 (former empl) (Entered: 08/07/1998)
13 ORDER by Judge William R. Wilson that pltf file its mot to compel discovery no later than 8/25/98, deft's response due no later than 9/4/98, pltf is to file any reply to the response no later than 9/9/98 (cc: all counsel) EOD 8/10/98 (former empl) (Entered: 08/10/1998)
14 STATEMENT by plaintiff in opposition to motion to change venue to the Western District of Louisiana [9-1] (former empl) (Entered: 08/19/1998)
15 MOTION by EEOC to compel discovery (former empl) (Entered: 08/25/1998)
16 BRIEF by EEOC in support of motion to compel discovery [15-1] (former empl) (Entered: 08/25/1998)
17 AFFIDAVIT of W S Grabon (former empl) (Entered: 08/25/1998)
18 REPLY by defendant Cajun Company Inc to statement in opposition to motion to change venue to the Western District of Louisiana [9-1] (former empl) (Entered: 08/31/1998)
19 ORDER by Judge William R. Wilson denying motion to change venue to the Western District of Louisiana [9-1]; deft may renew this mot when the scope of the lawsuit has been decided (cc: all counsel) (former empl) (Entered: 09/03/1998)
20 DEFENDANT'S OPPOSITION to pltf's brief in support of pltf's motion to compel discovery [15-1] (former empl) (Entered: 09/04/1998)
21 ORDER by Judge William R. Wilson granting pltf's motion to compel discovery [15-1]; if the parties cannot agree on a date certain for the production, a conference call should be scheduled on or before 11/5/98 (cc: all counsel) EOD 10/27/98 (former empl) (Entered: 10/27/1998)

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12/07/1998 12/14/1998 12/14/1998 07/13/1999 07/27/1999
08/13/1999 08/27/1999 09/15/1999
10/14/1999

22 JOINT MOTION for continuance of discovery cut-off date & trial (former empl) (Entered: 12/08/1998)
23 ORDER by Judge William R. Wilson granting motion for continuance of discovery cut-off date & trial [22-1] a new scheduling order will be issued (cc: all counsel) (former empl) (Entered: 12/15/1998)
24 SCHEDULING ORDER by Judge William R. Wilson resetting jury trial for 9:00 10/26/99 in Helena; discovery due 8/26/99; pretrial info sheet due 9/27/99 (cc: all counsel) (former empl) (Entered: 12/15/1998)
25 JOINT MOTION by defendant Cajun Company Inc and plaintiff EEOC for continuance (former empl) (Entered: 07/13/1999)
26 ORDER by Judge William R. Wilson denying motion for continuance [25-1]; if the case is not resolved, parties are to file a list of each witness they expect to call at trial on or before 9/15/99 as well as a list of estimated length of time needed to cross-examine each witness which the opposing party expects to all by 9/22/99 (cc: all counsel) EOD 7/27/99 (former empl) (Entered: 07/27/1999)
27 NOTICE (DOC) setting a settlement conference for 1:00 on 8/23/99 in Little Rock, AR (cc: all counsel) (former empl) (Entered: 08/16/1999)
28 JOINT MOTION for protective order (former empl) (Entered: 08/27/1999)
29 STIPULATED PROTECTIVE ORDER AGREEMENT by Judge William R. Wilson as set forth herein, confidential information means any information, oral or in documentary or other tangible form so designated by any producing person, financial information, statements or other documents containing information related to the financial status and/or net worth of the Cajun Company, Inc or any other documents marked confidential & agreed to be the parties as included herein; all confidential information or documents disclosed shall be used solely for the purposes of preparation for trial, pretrial proceedings & trial of this litigation & not for any other purposes; all documents containing confidential information shall be filed in a sealed envelope as set forth in this order; this order shall survive & remain in full force & effect after termination of this litigation; this agreement shall bind the parties as of the date they execute it & shall be treated as an order of the Court without the necessity of filing; it is ordered that the Stipulated Protective Order Agreement between the parties hereto is approved & made an order of this Court [28-1] (cc: all counsel) (former empl) (Entered: 09/15/1999)
30 CONSENT DECREE by Judge William R. Wilson to settle all claims in this lawsuit, the Cajun company will pay the separate individuals listed the amounts set forth in this order; notice will be posted in conspicuous places at each job site for 30 days; deft has a policy prohibiting racial harassment and has trained all supervisory & management employees, including foremen, in the prohibitions of the federal employment discrimination laws & policy prohititing racial harassment; a report will be submitted to Carson L Owen 6 months after the entry of this decree &

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every 6 months thereafter during the duration of this decree; each party to bear its own attorneys; fees & costs (cc: all counsel) (former empl) (Entered: 10/14/1999)

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