1 WILLIAM R. TAMAYO (CA Bar No. 084965) JONATHAN T. PECK (VA Bar No. 12303)
2 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office
3 350 The Embarcadero, Suite 500 San Francisco, CA 94105
4 Telephone No. (415) 625-5646 Facsimile No. (415) 625-5657
5 LUCILA G. ROSAS (CA Bar No. 187345)
6 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Jose Local Office
7 96 North Third Street, Suite 200 San Jose, CA 95112
8 Telephone No. (408) 291-6401 Facsimile No. (408) 291-4539
9 Attorneys for Plaintiff
10 Equal Employment Opportunity Commission

11

UNITED STATES DISTRICT COURT

12

NORTHERN DISTRICT OF CALIFORNIA

13

SAN JOSE DIVISION

14

)

EQUAL EMPLOYMENT OPPORTUNITY ) CIVIL ACTION NO.

15 COMMISSION,

)

)

16

)

Plaintiff,

)

17

)

v.

)

18

)

ENTRAVISION COMMUNICATIONS )

19 CORPORATION,

)

COMPLAINT
Civil Rights Employment Discrimination
JURY TRIAL DEMAND

)

20

Defendant.

)

)

21

)

22 NATURE OF THE ACTION
23 This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil
24 Rights Act of 1991 to correct unlawful employment practices on the basis of sex, retaliation and
25 constructive discharge and to provide appropriate relief to Ms. America Medina, Ms. Sofia Long
26 and other similarly situated female employees of the Defendant. As alleged below, Defendant
27 unlawfully subjected Ms. America Medina, Ms. Sofia Long and other similarly situated female
28

COMPLAINT
1

1 employees to sexual harassment and a hostile work environment. Plaintiff also alleges that

2 Defendant subjected Ms. America Medina to constructive discharge and Ms. Sofia Long to

3 retaliatory discharge because she engaged in a protected activity.

4

JURISDICTION AND VENUE

5

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

6 1343 and 1345. This action is authorized and instituted pursuant to Section 706 (f) (1) and (3) of

7 Title VII of the Civil Rights Act of 1964, as amended (Title VII), 42 U.S.C. §2000e-5 (f) (1) and

8 (3), and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. §1981(a).

9

INTRA-DISTRICT ASSIGNMENT

10

2. This action is appropriate for assignment to the San Jose division because the

11 unlawful employment practices alleged were committed in Monterey County, within the

12 jurisdiction of the United States District Court for the Northern District of California.

13

PARTIES

14

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

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

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

17 and (3) of Title VII, 42 U.S.C. §2000e-5 (f) (1) and (3).

18

4. At all relevant times, Defendant, Entravision Communications Corporation

19 (“Defendant or Entravision”), has continuously been, and is now, a California business, qualified

20 and doing business in the State of California and the City of Monterey and has continuously had

21 and does now have at least 15 employees.

22

5. At all relevant times, Defendant has continuously been an employer engaged in an

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

24 U.S.C. §§ 2000e(b), (g) and (h).

25

STATEMENT OF CLAIMS

26

6. More than thirty days prior to the institution of this lawsuit, Ms. America Medina

27 and Ms. Sofia Long filed a charge with the Commission alleging violations of Title VII by

28 Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled.

COMPLAINT
2

1

7. Since at least January 2000, Defendant has engaged in unlawful employment

2 practices of sex discrimination in violation of Section 703 (a) (1) of Title VII, 42 U.S.C. §

3 2000e-2 (a) (1). These practices include subjecting Ms. America Medina, Ms. Sofia Long and

4 other similarly situated female employees of the Defendant to sexual harassment, creating a

5 hostile, abusive, intimidating and discriminatory work environment, including constructive

6 discharge.

7

8. Since at least January 2001, Defendant has subjected Ms. Sofia Long to adverse

8 employment actions in retaliation for her opposition to and rejection of the sexual harassment in

9 violation of Section 704 (a) of Title VII, 42 U.S.C. Section 2000e-3 (a). These practices include

10 retaliatory discipline and retaliatory discharge.

11

9. The effect of the practices complained of above has been to deprive Ms. America

12 Medina, Ms. Sofia Long and other similarly situated female employees of equal employment

13 opportunities and otherwise adversely affect their employment status because of their sex and on

14 account of retaliation and constructive discharge.

15

10. The unlawful employment practices complained of above were and are

16 intentional.

17

11. The unlawful employment practices complained of above were done with malice

18 and/or reckless indifference to the federally protected rights of Ms. America Medina, Ms. Sofia

19 Long and other similarly situated female employees of the Defendant.

20

PRAYER FOR RELIEF

21

Wherefore, the Commission respectfully requests that this Court:

22

A. Grant a permanent injunction enjoining Defendant, their officers, successors,

23 assigns, and all persons in active concert or participation with it, from engaging in sexual

24 harassment, retaliation, constructive discharge and any other employment practice which

25 discriminates on the basis of sex.

26

B. Order Defendant to carry out policies, practices, and programs which provide

27 equal employment opportunities for women and those persons who complain about sexual

28 harassment, and which eradicate the effects of its past and present unlawful employment

COMPLAINT
3

1 practices.

2

C. Order Defendant to make whole Ms. America Medina, Ms. Sofia Long and other

3 similarly situated female employees by providing appropriate back pay with prejudgment

4 interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate

5 the effects of their unlawful employment practices.

6

D. Order Defendant to make whole Ms. America Medina, Ms. Sofia Long and other

7 similarly situated female employees by providing compensation for past and future pecuniary

8 losses resulting from the unlawful employment practices described above, in amounts to be

9 determined at trial.

10

E. Order Defendant to make whole Ms. America Medina, Ms. Sofia Long and other

11 similarly situated female employees by providing compensation for past and future non-

12 pecuniary losses caused by the above unlawful conduct, including pain and suffering, emotional

13 distress, indignity, loss of enjoyment of life, loss of self-esteem and humiliation, in amounts to be

14 determined at trial.

15

F. Order Defendant to pay Ms. America Medina, Ms. Sofia Long and other similarly

16 situated female employees punitive damages for its malicious and reckless conduct described

17 above, in amounts to be determined at trial.

18

G. Grant such further relief as the Court deems necessary and proper in the public

19 interest.

20

K. Award the Commission its costs of this action.

21 ///

22 ///

23 ///

24 ///

25 ///

26 ///

27 ///

28 ///

COMPLAINT
4

1

JURY TRIAL DEMAND

2

The Commission requests a jury trial on all questions of fact raised by its complaint.

3

4

5

Respectfully submitted,

6

7

ERIC S. DREIBAND

General Counsel

8

EQUAL EMPLOYMENT OPPORTUNITY

9

COMMISSION

Office of the General Counsel

10

Washington, DC 20507

11

12 Dated: 11/17/03
13
14

s/William R. Tamayo WILLIAM R. TAMAYO Regional Attorney

15 Dated: 11/17/03
16
17

s/Jonathan T. Peck JONATHAN T. PECK Supervisory Trial Attorney

18 Dated: 11/17/03
19
20

s/Lucila G. Rosas LUCILA G. ROSAS Trial Attorney

21

EQUAL EMPLOYMENT OPPORTUNITY

22

COMMISSION

San Jose Local Office

23

96 North Third Street, Suite 200

San Jose, CA 95112

24

25

26

27

28

COMPLAINT
5

 
 1 WILLIAM R. TAMAYO (CA Bar No. 084965) JONATHAN T. PECK (VA Bar No. 12303)
2 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office
3 345 Spear Street, Suite 500 San Francisco, CA 94105-1687
4 Telephone No. (415) 625-5646 Fax No. (415) 625-5657
5 LUCILA G. ROSAS (CA Bar No. 187345)
6 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Jose Local Office
7 96 North Third Street, Suite 200 San Jose, CA 95112
8 Telephone No. (408) 291- 6401 Facsimile No. (408) 291- 4539
9 Attorneys for Plaintiff
10 Equal Employment Opportunity Commission

11 JOHN A. LAVRA, CSB 1145233 JERI L. PAPPONE, CSB 210104
12 LONGYEAR, O’DEA & LAVRA, LLP 3620 American River Drive, Suite 230
13 Sacramento, CA 95864-8510 Telephone No. (916) 974-8500
14 Facsimile No. (916) 974-8510

15 UNITED STATES DISTRICT COURT
16 NORTHERN DISTRICT OF CALIFORNIA
17 SAN JOSE DIVISION
18

19 20

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

) ) )

)

CIVIL ACTION NO. C-03-05117 JW (HRL)

Plaintiff,

)

21 v.
22

) )

CONSENT DECREE

)

23 ENTRAVISION COMMUNICATIONS CORP.,
24 Defendant.

) ) ) ) )

25

26

I. INTRODUCTION

27

On November 19, 2003, Plaintiff, Equal Employment Opportunity Commission

28 (“EEOC”), filed this action pursuant to Title VII of the Civil Rights Act of 1964 (“Title VII”) and

Consent Decree C-03-05117 JW (HRL)

1

1 Title I of the Civil Rights Act of 1991. Plaintiff alleged that Defendant, ENTRAVISION

2 COMMUNICATIONS CORPORATION (“Defendant”), subjected Ms. America Medina, Ms.

3 Sofia Long and other similarly situated female employees to sexual harassment and a hostile

4 work environment. Plaintiff also alleged that Defendant subjected Ms. Medina to constructive

5 discharge and Ms. Long to retaliatory discharge because she engaged in a protected activity.

6

On January 7, 2004, Defendant answered the complaint and denied liability on all claims

7 asserted by the EEOC.

8

The EEOC and Defendant want to conclude fully and finally all claims arising out of the

9 above action without the expenditure of further resources and expenses in contested litigation.

10 They enter into this Consent Decree to further the objectives of equal employment opportunity as

11 set forth in Title VII.

12

II. NON-ADMISSION OF LIABILITY

13

This Consent Decree is not an adjudication or finding on the merits of this case and shall not

14 be construed as an admission of a violation by Defendant.

15

The Court has reviewed the terms of this Consent Decree in light of the pleadings, the record

16 herein, and the applicable law, and now approves the Consent Decree in its entirety.

17

Therefore, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:

18

III. GENERAL PROVISIONS

19

1. This Court has jurisdiction over the subject matter and the parties to this action.

20

2. This Consent Decree constitutes a full resolution of Plaintiff’s complaint in Civil

21 Action No. C-03-05117 JW (HRL) and the underlying charge of discrimination filed with the

22 EEOC.

23

3. This Consent Decree shall become effective upon its entry by the Court.

24

4. Each party shall bear its own costs and attorney fees.

25

IV. INJUNCTIVE RELIEF

26

1. Sexual Harassment: Consistent with Section 703 of Title VII, 42 U.S.C. §2000e-2,

27 Defendant, its officers, agents, management (including supervisory employees), successors and

28 assigns, and all those in active concert or participation with them, will make every effort to
Consent Decree C-03-05117 JW (HRL)
2

1 comply with all requirements of Title VII with respect to providing a work environment free

2 from discrimination on the basis of sex and free from any action, policy or practice that is

3 intended to or known to them to have the effect of harassing or intimidating any female employee

4 on the basis of her gender or creating, facilitating or permitting the existence of a work

5 environment that is hostile to female employees.

6

2. Retaliation: Consistent with Section 704 of Title VII, 42 U.S.C. §2000e-3, Defendant,

7 its officers, agents, management (including supervisory employees), successors or assigns, and

8 all those in active concert or participation with them, agree not to engage in, implement or permit

9 any action, policy or practice with the purpose of retaliating against America Medina, Sofia Long

10 or any person who was identified as a possible witness in this action because they opposed any

11 practice of harassment or other discriminatory acts on the basis of gender made unlawful under

12 Title VII; filed a Charge of Discrimination alleging any such practice; or testified or participated

13 in any manner in any investigation (including, without limitation, any internal investigation

14 undertaken by Defendant), proceeding or hearing in connection with this case.

15

V. MONETARY RELIEF

16

1. Defendant will pay the total sum of $185,000.00 (“the Settlement Sum”) as damages to

17 be allocated to Ms. America Medina, Ms. Sofia Long, and identified former employees of

18 Entravision in full settlement of the discrimination claims made in this lawsuit.

19

2. The Settlement Sum is being paid in complete compromise of all disputed issues

20 arising out of the Complaint filed in this lawsuit, Civil Action No. C-03-05117 JW (HRL), U.S.

21 District Court for the Northern District of California (San Jose Division).

22

VI. NON-MONETARY RELIEF

23

1. Defendant affirms the following “Statement of Zero-Tolerance Policy and Equality

24 Objectives”:

25

Defendant is firmly committed to maintaining a zero-tolerance

26

policy concerning sexual harassment and retaliation against

individuals who report harassment in the company’s workplace; to

27

swiftly and firmly responding to any acts of sexual harassment and

retaliation of which the company becomes aware; to implementing

28

a disciplinary system that is designed to strongly deter future acts

Consent Decree C-03-05117 JW (HRL)

3

1

of sexual harassment or retaliation; and to actively monitoring its

workplace in order to ensure tolerance, respect and dignity for all

2

people.

3

This paragraph does not create any contractual causes of action or other rights that would

4 not otherwise exist.

5

2. In order to accomplish the objectives embodied in the Statement of Zero-Tolerance

6 Policy and Equality Objectives and this Consent Decree, Defendant shall develop policies,

7 procedures and practices to implement the following policies, procedures and practices:

8

(a) Policy Addressing Sexual Harassment: Defendant agrees that it shall

9

develop a harassment policy, within forty-five (45) days of signing the Consent Decree,

10

which: (i) includes definitions of sexual harassment with examples to supplement the

11

definitions of sexual harassment; (ii) includes strong non-retaliation language with

12

examples to supplement the definition of retaliation; (iii) provides that complaints of

13

sexual harassment and/or retaliation will be accepted by Defendant both in writing and

14

orally; (iv) provides a timetable for commencing an investigation after a complaint is

15

made or received and for remedial action to be taken upon conclusion of an investigation;

16

and (v) indicates that, promptly upon the conclusion of its investigation of a complaint,

17

Defendant will communicate to the complaining party the results of the investigation and

18

the remedial actions taken or proposed, if any.

19

Defendant’s policy will be written in both Spanish and English. Defendant will

20

provide a copy of the sexual harassment policy to the EEOC within forty-five (45) days of

21

the signing of the Consent Decree.

22

(b) Complaint Procedures: Defendant shall develop a complaint procedure designed to

23

encourage employees to come forward with complaints about violations of its harassment

24

policy. As part of the policy, Defendant shall provide its employees with convenient,

25

confidential and reliable mechanisms for reporting incidents of sexual harassment and

26

retaliation. Defendant shall designate at least two employees to whom employees may

27

report complaints of harassment. The titles of the contact persons (and with respect to

28

Corporate Legal and Human Resources Department, work locations and telephone

Consent Decree C-03-05117 JW (HRL)

4

1

numbers) shall be listed on the harassment policy, which shall be included in the

2

company’s employee handbook that is generally distributed to all employees on an annual

3

basis.

4

Defendant’s complaint procedure will also be written in both Spanish and

5

English. Defendant will provide a copy of the complaint procedures to the EEOC within

6

forty-five (45) days of the signing of the Consent Decree.

7

(c) Supervisor Accountability:

8

(i) With respect solely to Defendant’s Monterey, California television property,

9

Defendant agrees that it shall impose substantial discipline – up to and including

10

termination, suspension without pay or demotion – upon any supervisor or manager who

11

engages in harassment on the basis of sex or permits any such conduct to occur in his or

12

her work area or among employees under his or her supervision, or who retaliates against

13

any person who complains or participates in any investigation or proceeding concerning

14

any such harassment. Defendant shall communicate this policy to all supervisors and

15

managers at the time the person is hired or promoted to supervisor/manager and

16

subsequently, on an annual basis.

17

(ii) Defendant agrees that it shall advise all managers and supervisors of their duty

18

to actively monitor their work areas to ensure employee compliance with the company’s

19

harassment policy, and to report any incidents and/or complaints of sexual harassment

20

and/or retaliation of which they become aware to the department charged with handling

21

such complaints.

22

(d) Sexual Harassment Training:

23

Defendant will agree to provide annual training to all current employees of the

24

Monterey Station with respect to harassment in the workplace, as follows:

25

(i) Defendant will develop and present to all of its employees at least one (1) hour

26

of mandatory sexual harassment training, the cost of which shall be borne by Defendant.

27

The training will take place within sixty (60) days of the signing of this Consent

28

Decree. The training will be conducted in the appropriate language (i.e. Spanish or

Consent Decree C-03-05117 JW (HRL)

5

1

English) depending on the primary language of the employees being trained.

2

(ii) The training described in the preceding paragraph shall be provided by a

3

person knowledgeable in sexual harassment who shall educate the employees about the

4

problems of sexual harassment in the workplace. The training will include examples of

5

the types of remarks and behavior that will not be tolerated in Defendant’s business

6

locations. The training will further inform each participant that he or she is responsible

7

for knowing and complying with the contents of Defendant’s harassment policy.

8

(iii) Supervisors and/or managers who are responsible for enforcing Defendant’s

9

harassment policy shall also receive training on appropriate techniques for investigating

10

harassment and remedying it. The training on investigative techniques can be included as

11

a component of the mandatory sexual harassment training.

12

(iv) Defendant shall provide to the EEOC, at least five (5) days in advance of the

13

training, a copy of the course syllabus for the training. Following the training session, all

14

participants shall be given a questionnaire through which they will be asked to critique

15

the training and to provide suggestions to improve future trainings.

16

(v) Defendant will retain records of the training programs, listing the dates on

17

which it held the training and identifying the persons who attended and those who did not

18

attend. Defendant will provide a copy of these records, the training materials and the

19

completed post-training questionnaires to the Commission within thirty (30) days of

20

completion of the trainings.

21

(vi) Defendant shall provide a refresher training session, at least one (1) hour long,

22

for all of its employees, once a year every year after the initial sexual harassment training

23

until the expiration of the Consent Decree. Defendant shall send to the EEOC the

24

corresponding reports for the refresher training as identified in paragraph (v) above within

25

thirty (30) days of completing the refresher training.

26 ///

27 ///

28 ///
Consent Decree C-03-05117 JW (HRL)
6

1

VII. REPORTING

2

1. Defendant will conspicuously post the notice, a copy of which is attached as Exhibit 1,

3 at its business location in Monterey, California television property. Such notices shall be posted

4 for six (6) months following entry of the Consent Decree. Defendant will monitor the notices

5 and replace within ten (10) days any notice which is defaced or removed.

6

2. Within ninety (90) days of the entry of this Consent Decree, Defendant will send the

7 Commission appropriate verification of its completion of harassment training for its employees at

8 the Monterey, California television property.

9

3. Defendant shall submit a final report to the EEOC thirty (30) days before the Consent

10 Decree expires containing a statement verifying its compliance with the terms of the Consent

11 Decree.

12

VIII. RETENTION OF JURISDICTION AND

13

EXPIRATION OF CONSENT DECREE

14

1. This Consent Decree shall terminate two years from the date of entry by the court,

15 unless EEOC petitions this court for an extension of the Decree because of noncompliance by

16 Defendant. If EEOC determines that Defendant has not complied with the Consent Decree,

17 EEOC will provide written notification of the alleged breach to Defendant and will not petition

18 the court for enforcement sooner than thirty (30) days after providing written notification. The

19 thirty-day period following written notice shall be used by the parties for good faith efforts to

20 resolve the issue. If EEOC petitions the court and the court finds Defendant to be in substantial

21 violation of the terms of the Decree, the court may extend this Consent Decree.

22 ///

23 ///

24 ///

25 ///

26 ///

27 ///

28 ///
Consent Decree C-03-05117 JW (HRL)
7

1

2. This Court shall retain jurisdiction over this action for the purposes of enforcing the

2 provisions of this Consent Decree.

3

4

5 On behalf of Plaintiff:

On behalf of Defendant:

6

7

s/ William R. Tamayo

WILLIAM R. TAMAYO

8 Regional Attorney

EEOC

9

2/07/05 Date

s/ John A. Lavra

2/07/05

JOHN A. LAVRA

Date

Attorney at Law

LONGYEAR, O’DEA & LAVRA

10

s/ Jonathan T. Peck

2/07/05

11 JONATHAN T. PECK

Date

Supervisory Trial Attorney

12 EEOC

s/ Jeri L. Pappone

2/07/05

JERI L. PAPPONE

Date

Attorney at Law

LONGYEAR, O’DEA & LAVRA

13 s/ Lucila G. Rosas
14 LUCILA G. ROSAS Senior Trial Attorney
15 EEOC

2/07/05 Date

16

17

18

19 IT IS SO ORDERED:
20

21

22

23

DAT/sE/JDa:mes

Feb. 9, Ware

2005

24

Honorable James Ware UNITED STATES DISTRICT JUDGE

25

26

27

28
Consent Decree C-03-05117 JW (HRL)
8

1 NOTICE TO EMPLOYEES
2

3 This notice is being posted as part of a consent decree entered into between the U.S. Equal Employment Opportunity Commission (EEOC) and Entravision Communications,
4 Corp.

5 Federal law requires that there be no discrimination against any employee or applicant for employment because of the individual’s race, color, religion, sex, national origin, age
6 (40 and over), or disability with respect to hiring, promotion, firing, compensation, sexual harassment or other terms and conditions or privileges of employment.
7 Federal law also prohibits retaliation against any employee who files a charge of
8 discrimination or who cooperates with the EEOC’s investigation of a charge. The EEOC is committed to protecting employees who file charges or who are witnesses
9 during an investigation including, if necessary, further court proceedings.

10 It is the policy of Entravision Communications, Corp. that it will not retaliate or tolerate retaliation in any way against any employee who has filed a charge or provided
11 testimony in the course of an investigation.

12 It is also the policy of Entravision Communications, Corp. that discrimination will not be tolerated. This policy includes the fair treatment of all employees and the maintenance
13 of a work environment free of discrimination, including sexual harassment. If any employee is found in violation of this policy, he/she will be subjected to disciplinary
14 action, up to and including dismissal.

15 If you wish to report an instance(s) of discrimination, please contact XXXX (name of company representative). You may also contact the U.S. Equal Employment
16 Opportunity Commission (EEOC) at 408-291-7352 and/or the Department of Fair Employment and Housing (DFEH) at (800) 884-1684.
17 This Notice will remain posted for six months from the date of posting and will not be
18 defaced.

19

20 Date:
21

Company Official

22

23

24

25

EXHIBIT 1

26

27

28
Consent Decree C-03-05117 JW (HRL)
9

1

2

AVISO A EMPLEADOS

3 Este Aviso es anunciado como parte del remedio acordado conforme al acuerdo entre
4 la Comisión de Igualdad de Oportunidades de Empleo (EEOC) y Entravision Communications, Corp.
5 La ley federal requiere que no aiga discriminación contra cualquier empleado o
6 solicitante para empleo a causa de su raza, color, religión, sexo, origen nacional, edad (40 años o mayores), e incapacidades con respecto a contratación, promoción,
7 despido, compensación, u otros términos, condiciones o privilegios de empleo.

8 La ley federal también prohibe represalias contra cualquier empleado que presente una denuncia de discriminación o quienes cooperan con la EEOC en una investigación de
9 una denuncia. La EEOC esta comprometida a proteger empleados que presenten una denuncia, quienes se quejan sobre discriminación o quienes son testigos durante una
10 investigación incluyendo, si es necesario, durante un juicio.

11 Es la póliza de Entravision Communications, Corp., que no tomará represalias ni tolará represalias de cualquier forma contra ningún empleado que se aiga quejado,
12 presentado una denuncia, o proporcionado testimonio durante el transcurso de una investigación.
13 También es la poliza de Entravision Communications, Corp., de prohibir discriminación
14 en el empleo. Esta poliza incluye el tratamiento justo de todos los empleados y de mantener un ambiente en el trabajo libre de discriminación, incluyendo acoso sexual.
15 Si se determina que algún empleado/a ha violado esta poliza, él/ella sera sujeto a una acciòn disciplinaria, incluyendo terminación.
16

17 Si desea reportar un incidente de discriminación, por favor comuniquese con XXXX (nombre de persona de compañía). También se puede comunicar con la
18 EEOC al (408) 291-7352 o la agencia estatal DFEH al (800) 884-1684.

19 Este aviso se mantendra anunciado por seis meses de la fecha del anuncio y no será estropeado.
20

21

22 Fecha

(Oficial de la Compañía)

23

24

25

26

EXHIBIT 1

27

28
Consent Decree C-03-05117 JW (HRL)
10

 
 CAND-ECF - Docket Report

https://ecf.cand.uscourts.gov/cgi-bin/DktRpt.pl?370921609408207-L_3...
ADRMOP, CLOSED, E-Filing, MEDTERM
U.S. District Court California Northern District (San Jose) CIVIL DOCKET FOR CASE #: 5:03-cv-05117-JW

Equal Employment Opportunity Commission v. Entravision Communications Corporation Assigned to: Hon. James Ware Referred to: Magistrate Judge Howard R. Lloyd Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 11/19/2003 Date Terminated: 02/28/2005 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Lucila G. Rosas U.S. EEOC San Jose Local Office 96 North Third Street Suite 200 San Jose, CA 95112 408-291-6401 Fax: 408-291-4539 Email: Lucila.Rosas@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sanya P. Hill Maxion U.S. EEOC 350 The Embarcadero Suite 500 San Francisco, CA 94105-1260 415-625-5650 Fax: 415-625-5657 Email: sanya.hill@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jonathan T. Peck U.S. EEOC 350 Embarcadero Street Suite 500 San Francisco, CA 94105-1687 415/625-5600 Fax: 415-625-5657 Email: Jonathan.Peck@eeoc.gov ATTORNEY TO BE NOTICED

William Robert Tamayo U.S. EEOC 350 Embarcadero Street

1 of 5

6/11/2007 9:09 AM

CAND-ECF - Docket Report

https://ecf.cand.uscourts.gov/cgi-bin/DktRpt.pl?370921609408207-L_3...

V.
Defendant Entravision Communications Corporation

Suite 500 San Francisco, CA 94105-1687 415-625-5645 Fax: 415-625-5657 Email: william.tamayo@eeoc.gov ATTORNEY TO BE NOTICED
David F. Offen-Brown U.S. EEOC 350 The Embarcadero Suite 500 San Francisco, CA 94105-1260 (415) 625-5652 Fax: (415) 625-5657 Email: David.Offen-Brown@eeoc.gov TERMINATED: 06/30/2004 ATTORNEY TO BE NOTICED
represented by John Andrej Lavra Longyear, O'D Ea & Lavra, LLP 3620 American River Dr., Suite 230 Sacramento, CA 95864-5923 916-974-8500 Fax: 916-974-8510 Email: lavra@lolllp.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jeri Lynn Pappone Longyear, O'D Ea & Lavra, LLP 3620 American River Drive, Suite 230 Sacramento, CA 95864-5923 916-974-8500 Fax: 916-974-8510 Email: pappone@lolllp.com ATTORNEY TO BE NOTICED

Date Filed 11/19/2003

#

Docket Text

1 COMPLAINT for Civil Rights Employment Discrimination; Summons Issued; Jury Demand (Fees Waived) against Entravision Communications Corporation. Filed by Equal Employment Opportunity Commission. (cfe, COURT STAFF) (Filed on 11/19/2003) Additional attachment(s) added on 12/4/2003 (cfe, COURT STAFF). Additional attachment(s) added on 12/4/2003 (cfe, COURT STAFF). (Entered: 11/19/2003)

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11/19/2003
11/19/2003 11/19/2003 11/24/2003
01/06/2004 02/11/2004 02/24/2004 03/02/2004 03/02/2004 03/02/2004 03/02/2004 03/17/2004 03/17/2004
03/18/2004 03/18/2004

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2 ADR SCHEDULING ORDER: Case Management Statement due by 3/16/2004. Case Management Conference set for 3/23/2004 01:30 PM.. Signed by Judge Howard R. Lloyd on 8/22/02. (Attachments: # 1 Standing Order)(cfe, COURT STAFF) (Filed on 11/19/2003) (Entered: 11/19/2003)
CASE DESIGNATED for Electronic Filing. (cfe, COURT STAFF) (Filed on 11/19/2003) (Entered: 11/19/2003)
Summons Issued as to Entravision Communications Corporation. (cfe, COURT STAFF) (Filed on 11/19/2003) (Entered: 11/19/2003)
3 NOTICE of Substitution of Counsel for Plaintiff by Equal Employment Opportunity Commission (cfe, COURT STAFF) (Filed on 11/24/2003) Additional attachment(s) added on 12/4/2003 (cfe, COURT STAFF). (Entered: 11/25/2003)
4 ANSWER to Complaint with Jury Demand by Entravision Communications Corporation. (cfe, COURT STAFF) (Filed on 1/6/2004) Additional attachment(s) added on 2/20/2004 (cfe, COURT STAFF). (Entered: 01/06/2004)
5 CLERK'S NOTICE re: Failure to E-File and/or Failure to Register as an E-Filer (cfe, COURT STAFF) (Filed on 2/11/2004) (Entered: 02/11/2004)
6 MOTION to Substitute Attorney filed by Equal Employment Opportunity Commission. (Offen-Brown, David) (Filed on 2/24/2004) (Entered: 02/24/2004)
7 STIPULATION and Proposed Order selecting Mediation by Equal Employment Opportunity Commission & Entravision Communications Corp. (Offen-Brown, David) (Filed on 3/2/2004) (Entered: 03/02/2004)
8 ADR Certification (ADR L.R. 3-5b) of discussion of ADR options (Offen-Brown, David) (Filed on 3/2/2004) (Entered: 03/02/2004)
9 CONSENT to Proceed Before a US Magistrate Judge by Equal Employment Opportunity Commission.. (Offen-Brown, David) (Filed on 3/2/2004) (Entered: 03/02/2004)
10 JOINT CASE MANAGEMENT STATEMENT and Proposed ORDER filed by Equal Employment Opportunity Commission. (Offen-Brown, David) (Filed on 3/2/2004) (Entered: 03/02/2004)
11 CLERK'S NOTICE of Impending Reassignment to U.S. District Judge (pmc, ) (Filed on 3/17/2004) (Entered: 03/17/2004)
12 ORDER REASSIGNING CASE. Case reassigned to Judge James Ware for all further proceedings. Judge Howard R. Lloyd remains as the Referral Judge. Signed by Executive Committee on March 17, 2004. (bw, COURT STAFF) (Filed on 3/17/2004) (Entered: 03/17/2004)
13 STIPULATION AND ORDER Selecting Mediation as ADR process.. Signed by Judge JAMES WARE on 3/18/04. (rd, COURT STAFF) (Filed on 3/18/2004) (Entered: 03/18/2004)
14 CLERK'S NOTICE Case Management Conference set for 4/26/2004 10:00 AM. Case Management Statement due by 4/16/2004. (rd, COURT STAFF) (Filed on 3/18/2004) (Entered: 03/18/2004)

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03/25/2004 04/06/2004 04/16/2004 04/27/2004 04/30/2004 05/25/2004 06/03/2004 06/24/2004 06/29/2004 10/19/2004 10/25/2004 11/01/2004 12/13/2004 01/11/2005 02/07/2005 02/09/2005

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15 ADR Certification (ADR L.R. 3-5b) of discussion of ADR options Stipulation and Order Selecting ADR Process/ ADR Certification (Pappone, Jeri) (Filed on 3/25/2004) (Entered: 03/25/2004)
16 NOTICE by Equal Employment Opportunity Commission ProofOfServiceCMCNotice (Offen-Brown, David) (Filed on 4/6/2004) (Entered: 04/06/2004)
17 JOINT CASE MANAGEMENT STATEMENT Second filed by Equal Employment Opportunity Commission. (Offen-Brown, David) (Filed on 4/16/2004) (Entered: 04/16/2004)
18 Minute Entry: Initial Case Management Conference held on 4/26/2004 before JAMES WARE (Date Filed: 4/27/2004). (Court Reporter UNREPORTED.) (rd, COURT STAFF) (Date Filed: 4/27/2004) (Entered: 04/27/2004)
19 SCHEDULING ORDER. Signed by Judge James Ware on 4/30/04. (jwlc3, COURT STAFF) (Filed on 4/30/2004) (Entered: 04/30/2004)
20 ADR Clerks Notice Appointing Kristen W. Maloney as Mediator. (bt, COURT STAFF) (Filed on 5/25/2004) (Entered: 05/25/2004)
Pre MED phone conference scheduled on 6/14/04 @9am w/Kristen W. Maloney (bt, COURT STAFF) (Filed on 6/3/2004) (Entered: 06/03/2004)
Set/Reset Hearings: Mediation Hearing set for 10/26/2004 09:30 AM,Clerk's Office, Courtroom 19 on the 16th floor. (bt, COURT STAFF) (Filed on 6/24/2004) (Entered: 06/24/2004)
21 NOTICE by Equal Employment Opportunity Commission Substitution of Counsel for Plaintiff (Rosas, Lucila) (Filed on 6/29/2004) (Entered: 06/29/2004)
22 STIPULATION re 19 Order by Equal Employment Opportunity Commission. (Rosas, Lucila) (Filed on 10/19/2004) (Entered: 10/19/2004)
23 AMENDED SCHEDULING ORDER Pursuant to the parties stipulation:. Signed by Judge JAMES WARE on 10/25/04. (rd, COURT STAFF) (Filed on 10/25/2004) (Entered: 10/25/2004)
Set/Reset Hearings: Mediation Hearing set for 11/30/2004 09:30 AM at 2nd Floor, Hawaii Room, 450 Golden Gate Avenue, SF (bt, COURT STAFF) (Filed on 11/1/2004) (Entered: 11/01/2004)
24 CERTIFICATION OF MEDIATION Session held on 11/30/04 w/Kristen M. Maloney. CAse settled. ADR process completed. (bt, COURT STAFF) (Filed on 12/13/2004) (Entered: 12/13/2004)
25 ORDER to show cause re settlement. Signed by Judge James Ware on Jan. 11, 2005. (jwlc1, COURT STAFF) (Filed on 1/11/2005) (Entered: 01/11/2005)
26 Proposed Order CONSENT DECREE by Equal Employment Opportunity Commission. (Rosas, Lucila) (Filed on 2/7/2005) (Entered: 02/07/2005)
27 Consent Decree. Signed by Judge James Ware on Feb. 9, 2005. (jwlc1, COURT STAFF) (Filed on 2/9/2005) (Entered: 02/09/2005)

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11/02/2005

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FILE located at Federal Records Center (FTR) San Bruno, CA. Accession No:021-05-0044, Location No:84013, Box No:63. (pmc, COURT STAFF) (Filed on 11/2/2005) (Entered: 11/02/2005)

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