f
'-

IN THE UNITED S'TATES'r>:tSTRICT COURT
FOR THE NORTHERN DISTRICT OF ILI.Il.fOI~i 1\; ,- [i t: f,~ (j: I I
WESTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

PZ RESTAURANTS, INC.

)

)

)

Defendant.

)

------------------------------~~--)

NATURE OF THE ACTION

04C50251
Case No.
JURY TRIAL DEMANDED

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

correct unlawful employment practices on the basis of sex and

retaliation and to provide appropriate relief to Sandra White

("White"), and to a class of female employees who were adversely

affected by such practices. The U.S. Equal Employment Opportunity

Commission (the "EEOC" or "Commission"), alleges that Defendant, PZ

Restaurants, Inc. ("Defendant") discriminated against White and a

class of female employees employed at Defendant's Parkway

Restaurant in Sterling, Illinois by subj ecting them to sexual

harassment, in violation of Title VII. The Commission alleges

further that Defendant retaliated against White and a class of

female employees for complaining of sexual harassment in that it
DOCKETED
JUN 042004

()
terminated White's employment and the employment of other members of the class, in violation of Title VII. Defendant later rehired White but made conditions so intolerable that it caused her constructive discharge.
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, 42 U.S.C. §§ 2000e5 (f) (1) and (3) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. 2. The unlawful acts alleged below were committed within the Jurisdiction of the United States District Court for the Northern District of Illinois, Western Division.
PARTIES 3. Plaintiff, EEOC, is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Sections 706 (f) (1) and (3) of Title VII, 42 U.S.C. §§ 2000e-5 (f) (1) and (3).
4. At all relevant times, Defendant has continuously been doing business in the State of Illinois and the City of Sterling,
2

""....~ ...~,

n

and has continuously had at least fifteen (15) employees. 5. At all relevant times, Defendant has continuously been an
employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 u.s.c. §§ 2000e (b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty (30)days prior to the institution of this lawsuit, White filed a charge with the Commission alleging violations of Title VII by Defendant All conditions precedent to the institution of this lawsuit have been fulfilled. 7 . Pursuant to 42 u.S.C. §2000e-5 (f) (1), EEOC's representatives attempted to eliminate the unlawful employment practices alleged below and to effect voluntary compliance with Title VII prior to institution of the lawsuit but EEOC was unable to secure a conciliation agreement acceptable to the Commission. 8. Since at least July 2000, Defendant has engaged in unlawful employment practices at Parkway Restaurant in Sterling, Illinois, in violation of Sections 703(a) and 704 of Title VII, 42 u.S.C. § 2000e-2(a)and 3. These practices include, but are not limited to, sexually harassing White and a class of female employees, failing to correct the sexually hostile work environment, and retaliating against White and a class of female employees after they complained of harassment by terminating White
3

and other females and then, after rehiring White, making conditions so intolerable that it caused her c9nstructive discharge.
9. The effect of the practices complained of above has been to deprive White and a class of female employees at Parkway Restaurant of equal employment opportunities and otherwise adversely affect their status as employees because of their sex and retaliation.
10. The unlawful employment practices complained of in paragraphs 8 and 9 above were intentional.
11. The unlawful employment practices complained of in paragraphs 8 and 9 above were done with malice or with reckless indifference to the federally protected rights of White and a class of female employee.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practices which discriminate on the basis of sex or engaging in retaliation; B. Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for its employees regardless of sex and which
4

eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant to make whole Sandra White and a class of female employees by providing appropriate backpay 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 Sandra White and the class of female employees, by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 8 and 9 above, in amounts to be determined at trial.
E. Order Defendant to make whole Sandra White and the Class of female employees by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 8 and 9 above, including emotional pain, humiliation, and inconvenience, in amounts to be determined at trial.
F. Order Defendant to pay punitive damages for its malicious and reckless conduct described in paragraphs 8 and 9 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
5

H. Award the Commission its costs of this action.
JURy TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted, Eric S. Dreiband General Counsel James Lee Deputy General Counsel Gwendolyn Young Reams Associate General Counsel
Laurie S. Elkin Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 500 West Madison Street Suite 2800 Chicago, Illinois 60661 312/353-7259
6

Civil Cover Sheet

Page 1 of2

UNITED STATES DISTRICT COURT r"H"T), \;ffl
NORTHERN DISTRICT OF ILLINOIS
Civil Cover Sheet
This automated JS-44 confonns generally to the manual JS-44 approved by the Judicial Conference of the United States in September 1974. The data is required for the use' of the Clerk of Court for the purpose of initiating the civil docket sheet. The infonnation contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This fonn is authorized for use only in the Northern District of Illinois.

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Defendant(s):PZ RESTAURANTS, INC.

County of Residence:

County of Residence: Whiteside County

Plaintiffs Atty:

Laurie S. Elkin

Defendant's Atty:

Equal Employment Opportunity Commission

04C50251

500 W. Madison, Suite 2800

Chicago, IL 60661

II. Basis of Jurisdiction:

1. U.S. Gov't Plaintiff

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

IV. Origin:

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

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

2000e et seq. ("Title VII"), and Title I of the Civil Rights Act of

1991,42 U.S.C. §'1981a, to correct unlawful employment practices

on the basis of sexual harassment and retaliation.

VII. Requested in Complaint

Class Action: Yes Dollar Demand:

'!'CIETED

Jury Demand: Yes

UN 04 2004

VIII. This case IS NOT a refiling of a previously dismissed case.

Signature: Date:

http://www.ilnd.uscourts.govIPUBLIClForms/autojs44.cfm

5/28/2004

In the Matter of

()

UNITED STATES DIStRICT COURT NORTHERN DISTRICT OF1LCINOIS

WESTERN DIVISION

r
t l

-4(' 8: i 0

U.S. Equal Employment Opportunity Commission, Plaintiff
v.
PZ Restaurants, Inc.

1!)4(1J50251

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

Employment Opportunity Commission

500 W. Madison St., Suite 2800

CITY ISTATEJZIP
Chicago, IL 60661

TELEPHONE NUMBER
312-353-7259
E·MAIL ADDRESS

FAX NUMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC NO. 6210523

MEMBER OF TRIAL BAR?

YES

0

NO

500 W. Madison St., Suite 2800

CITYISTATEtZIP
Chicago, IL 60661

TELEPHONE NUMBER
3120353-7259
E·MAIL ADDRESS

FAX NUMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON
ARDC No. 06210804
MEMBER OF TRIAL BAR?
ATTORNEY?
DESIGNATED AS LOCAL COUNSEL?

YES

0 NO

YES

0 NO

YES

o 0 NO

SIGNATURE

NAME

Employment Opportunity Commission

500 W. Madison St., Suite 2800

Chicago, IL 60661

TELEPHONE NUMBER
312-353-8551

FAX NUMBER

E·MAIL ADDRESS

FIRM STREET ADDRESS CITY 1ST ATEtZIP TELEPHONE NUMBER E·MAIL ADDRESS

FAX NUMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 01187589

MEMBER OF TRIAL BAR?

YES

0

TRIAL ATTORNEY?

YES

0

DESIGNATED AS LOCAL COUNSEL?

YES

0

NO

0

NO

0

NO

0

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR? TRIAL ATTORNEY? DESIGNATED AS LOCAL COUNSEL?

YES

0

0 NO

YES

0

0 NO

YES

0

NO 0

\1

 
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~'. ,."
~ : i '....

i"'> t'-
v".'

EQUAL EMPLOYMENT OPPOR1'UNITY )

COMMISSION,

)

)

Plaintiff,

)

)

)

v.

)

-)

)

PZ RESTAURANTS, INC.,

)

)

Defendant.

)

-------------------------------)

Case No. 04 C 50251
Judge Philip G. Reinhard
Magistrate Judge Michael P. Mahoney

CONSENT DECREE

THE LITIGATION

1. Plaintiff Equal Employment Opportunity Commission (the "EEOC") filed this action alleging that Defendant, PZ Restaurants, Inc. violated Section 703(a) of Title VII of the Civil Rights Act of 1964, as amended ("Title VII"), 42 U.S.C. § 2000e-2(a), by fostering or tolerating a working environment that was sexually hostile to female employees. PZ Restaurants denies the allegations contained within the Complaint, and denies that any actions attributable to it or its employees and/or owners, in any way fostered or permitted a work environment that was sexually hostile to female employees.
2. In the interest of resolving this matter, and as a result of having engaged in comprehensive settlement negotiations, the parties have agreed that this action should be finally resolved by entry ofthis Consent Decree (hereafter "Decree"). This Decree fully and finally resolves any and all issues and claims arising out ofthe Complaint filed by the EEOC in this action. Nothing in this Decree should be construed as an admission by any party regarding either liability or non-liability.

',.

FINDINGS

3. Having carefully examined the terms and provisions ofthis Decree, and based

on the pleadings, record, and stipulations of the parties, the Court finds the following:

a. This Court has jurisdiction ofthe subject matter ofthis action and ofthe

parties.

b. The terms of this Decree are adequate, fair, reasonable, equitable, and

just. The rights ofthe parties and the public interest are adequately protected by this Decree.

c. This Decree conforms with the Federal Rules of Civil Procedure and

Title VII and is not in derogation of the rights or privileges of any person. The entry of this

Decree will further the objectives of Title VII and will be in the best interests of the parties,

the Charging Party, and the public.

,NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:

INJUNCTION AGAINST HARASSMENT

4. PZ Restaurants and its officers, agents, management (including supervisory

employees), successors and assigns, and all those in active concert or participation with them,

or any of them, are hereby enjoined from: (i) discriminating against women on the basis of

sex; (ii) engaging in or being a party to any action, policy or practice that is intended to or is

known to have the effect ofharassing or intimidating any female employee on the basis ofher

gender; and/or (iii) creating, facilitating or permitting the existence of a hostile work

environment within the meaning of Title VII.

NON-RETALIATION

5. PZ Restaurants, its officers, agents, employees, successors, assigns and all

persons acting in concert with it shall not engage in any form ofretaliation against any person

because such person has opposed any practice made unlawful under Title VII, filed a Charge

ofDiscrimination under Title VII, testified or participated in any manner in any investigation,

proceeding, or hearing under Title VII, or asserted any rights under this Decree.

2

MONETARY RELIEF 6. PZ Restaurants shall pay the gross sum of $10,000.00 inclusive of attorneys' fees and costs, to Charging Party Sandra White, represented by the law firm of Pignatelli, Liston & Mertes, P.C.. This amount shall be apportioned and distributed as follows: (1) $6,670.00 made payable to Charging Party Sandra White; and (2) $3,300.00 made payable to Pignatelli, Liston & Mertes, P.C. in full and final release of attorneys' fees for which Pignatelli, Liston & Mertes, P.C. will be issued a form 1099. The payment to Charging Party shall be apportioned as follows: (1) $1,700.00 shall be for lost wages and subject to applicable withholdings ofthe employee"s share only; and (2) the remaining $4,970.00 shall be payment for emotional pain and suffering from which no withholdings shall be made. Charging Party and Defendant have entered into a separate release agreement that was negotiated entirely between Charging Party's attorney and Defendant. EEOC has had no part in and EEOC in no way endorses or approves of such release agreement. 7. Within ten (10) business days after receipt by PZ Restaurants of the separate Release Agreement between Charging Party and Defendant discussed above in paragraph 6, PZ Restaurants or its agent shall issue checks to Charging Party and to Charging Party's attorney in the amounts set forth in paragraph 6 above. The checks shall be sent to Pignatelli, Liston & Mertes, P.C.. A copy of each check issued shall be sent to the EEOC.
POSTING OF NOTICE 8. Within ten (10) business days after entry of this Decree, PZ Restaurants shall post same sized copies of the Notice attached as Exhibit A to this Decree on bulletin boards usually used by PZ Restaurants for communicating with employees at its Parkway Restaurant in Sterling, Illinois. The Noticeshal1rem?in posted for two (2) years from the date of entry ofthis Decree. PZ Restaurants shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other material. PZ Restaurants shall certify to the EEOC in writing within ten (10) business days after entry of this Decree that the Notice has been properly posted. PZ Restaurants shall permit a representative ofthe EEOC to enter Parkway
3

Restaurant for purposes of verifying compliance with this Paragraph at any time during business hours without prior notice.
RECORD KEEPING 9. For a period of two (2) years following entry of this Decree, PZ Restaurants shall maintain and make available for inspection and copying by the EEOC records of each complaint ofsexual harassment. Such records shall indicate the date the complaint was made, who made it, what was alleged, and what actions PZ Restaurants took to resolve the matter, and when. 10. PZ Restaurants shall make all documents or records referred to in Paragraph 9 above, available for inspection and copying within ten (10) business days after the EEOC so requests. In addition, PZ Restaurants shall make available for interview all persons within its employ whom the EEOC reasonably requests for purposes of verifying compliance with this Decree and shall permit a representative of the EEOC to enter PZ Restaurants's premises for such purposes on five (5) business days advance notice by the EEOC. 11. Nothing contained in this Decree shall be construed to limit any obligation PZ Restaurants may otherwise have to maintain records under Title VII or any other law or regulation.
REPORTING 12. PZ Restaurants shall furnish to the EEOC the following written reports semiannually for a period oftwo (2) years following entry ofthis Decree. The first report shall be due six (6) months after entry of the Decree. The final report shall be due twenty-three (23) months after entry of the Decree. Each such report shall contain:
a. A summary ofthe information recorded by PZ Restaurants pursuant to Paragraph 9, including the names of each person who complained of sexual harassment, the date of the complaint, and the actions, and dates thereof, taken by PZ Restaurants" including any discipline given;
b. A certification by PZ Restaurants that the Notice required to be posted
4

in 8, above, remained posted during the entire six (6) month period preceding the report. MAINTENANCE AND DISTRIBUTION OF POLICY
AGAINSTSEXu.A.L HA:RAS"SMENT
13. PZ Restaurants shall maintain a written policy against sexual harassment ("the Policy") and provide a copy of the Policy to the EEOC within fourteen (14) working days after entry of this Consent Decree. The Policy shall:
a) Prohibit sexual harassment by employees, supervisors, officer and owners of PZ Restaurants;
b) Provide that complaints of sexual harassment may be made directly to an owner; c) Provide that if the alleged harasser is an owner or officer of PZ Restaurants, complaints can be made to a designated outside representative; d) Provide that employees who violate the policy are subject to discipline up to and including discharge; and e) Advise employees that they may complain of sexual harassment to the Equal Employment Opportunity Commission at 500 West Madison, Chicago, Illinois. 14. Within twenty-one (21) days after the entry ofthis Consent Decree ifit has not already done so, PZ Restaurants shall provide a copy of its Policy to each employee of PZ Restaurants. 15. A copy ofthe Policy shall be given to each new employee on the day the person is hired. Copies of the Policy shall also be posted on the bulletin boards customarily used for posting notices from management to employees.
TRAINING 16 Within 60 days of the entry of this Decree, PZ Restaurants shall retain and pay for a trainer approved by the EEOC, to provide training to all owners, officers, supervisors, managers and employees with respect to sexual harassment and with respect to the Policy implemented pursuant to Paragraph 13 above. Attendance shall be mandatory. A registry of attendance shall be maintained.
5

i •
17. PZ Restaurants shall obtain the EEOC's approval of its proposed trainer prior to the training session. PZ Restaurants shall submit the name, address, telephone number and resume of the proposed trainer to the EEOC within 30 days of the entry of this Decree. The EEOC shall have ten calendar days from the date of receipt of the information described above to accept or reject the proposed trainer. In the event the EEOC does not approve PZ Restaurants's designated trainer, PZ Restaurants shall have ten calendar days to identify an alternate trainer. The EEOC shall have ten calendar days from the date of receipt of the information described above to accept or reject the alternate trainer. In the event the EEOC does not approve PZ Restaurants's alternate tra.iner, the EEOC· shall designate the trainer to be retained and paid for by PZ'Restaurants.
18. PZ Restaurants shall certify to the EEOC in writing with ten (10) days after the training has occurred that the training has taken place and that the required personnel have attended. Such certification shall include: (i) the date, location and duration of the training; and (ii) a copy ofthe registry ofattendance, which shall include the name and position ofeach person in attendance.
19. PZ Restaurants agrees to provide EEOC with any and all copies of pamphlets, brochures, outlines or other written materials provided to the participants of the training seSSIOns.
DISPUTE RESOLUTION 20. In the event that either party to this Decree believes that the other party has failed to comply with any provision(s) of the Decree, the complaining party shall notify the other party of the alleged non-compliance within ninety (90) days of the alleged non-compliance and shall afford the alleged non-complying party ten (10) business days to remedy the non-compliance or to satisfy the complaining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged noncompliance or satisfied the complaining party that it has complied within ten (10) business days, the complaining party may apply to the Court for appropriate relief.
6

DURATION OF THE DECREE AND RETENTION OF JURISDICTION 21. All provisions of this Decree shall be in effect (and the Court will retain jurisdiction of this matter to enforce this Decree) for a period of two (2) years immediately following entry ofthe Decree, provided, however, that if, at the end of two years, any disputes under Paragraph 20, above, remain unresolved, the term of the Decree shall be automatically extended (and the Court will retain jurisdiction of this matter to enforce the Decree) until such time as all such disputes have been resolved.
MISCELLANEOUS PROVISIONS 22. Each party to this Decree shall bear its own expenses and costs. The EEOC and PZ Restaurants shall bear their own attorneys' fees. 23. The terms of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns, and successors of PZ Restaurants in their capacities as representatives, agents, directors and officers ofPZ Restaurants, and not in their individual capacities. 24. When this Decree requires the submission by PZ Restaurants of reports, certifications, notices, or other materials to the EEOC, they shall be mailed to: Laurie Elkin, Trial Attorney, Equal Employment Opportunity COnlmission, 500 West Madison Street, Suite 2800, Chicago, Illinois, 60661. When this Decree requires submission· by the EEOC of materials to PZ Restaurants, they shall be mailed to: Timothy Zollinger, Esq., Ward, Murray, Pace & Johnson, P.C., 202 East Fifth Street, P.O. Box 400, Sterling, Illinois 61021.
7

· ,
., .
For the Equal Employment Opportunity Commission 1801 L Street, N.W. Washington, D.C. 20507
Eric Dreiband General Counsel
James Lee Deputy General Counsel
Gwendolyn Young Reams Associate General Counsel
Equal Employment Opportunity Commission
500 West Madison Street Suite 2800

For PZ Restaurants, Inc.
.
Co-owner of PZ Restaurants, Inc.

Tim

mger, Esq.

Ward, Murray, Pace & J

202 East Fifth Street

P.O. Box 400

Sterling, Illinois 61021

Laurie Elkin Trial Attorney

Judge Philip G. Reinhard
8

.. ,
EXHIBIT A NOTICE TO ALL PZ RESTAURANT EMPLOYEES
This Notice is being posted pursuant to a Consent Decree entered by the federal court in EEOC v. PZ Restaurants, Inc., No. 04 C 50251 (N.D.Ill.) resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against PZ.Restaurants, Inc. ("the Company").
In its suit, the EEOC alleged that the Company fostered or tolerated a working environment that was hostile to female employees, in violation of Title VII of the Civil Rights Act of 1964 ("Title VII"). The Company denies these allegations.
._To resolye thecase,flieCompanyancrtne EEOChaVeei1terectrnto~Conseiiajecree·
"·~-which pr~vides, among other:t,hings, that:
1) the Company will make a payment to the complainant; 2) the Company will not foster or tolerate sexual harassment; 3) the Company will not retaliate against any person because (s)he opposed any
practice made unlawful by Title VII, filed a Title VII charge of discrimination, participated in any Title VII proceeding, or asserted any rights under the Consent Decree; and 4) the Company will adopt and distribute to all employees a policy against sexual harassment and will train all its supervisors, officers and employees regarding sexual harassment and its policy.
The EEOC epforces th~ federal laws against discrimination in employment on the basis of race, color, religion, national origin, sex, age or disability. If you believe you have been discriminated against, you may contact the EEOC at (312) 353-8195. The EEOC charges no fees and has employees who speak languages other than English. If you believe you have been discriminated against you may contact the EEOC.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
This Notice must remain posted for two years from the date below and must not be altered, defaced or covered by any other material. Any questions about this Notice or compliance with its terms may be directed to: PZ Restaurants Settlement, EEOC, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661.
/CJ/"l-7/0 Y
Date ~ I
9

CERTIFICATE OF SERVICE
I, Laurie S. Elkin, an attorney, do hereby certify that I caused a true and correct copy of the foregoing Agreed Motion For Entry of Consent Decree to be served by Unites States Mail on this 19th day of October, 2004, to the following counsel of record:
Timothy B. Zollinger, Esq. Ward, Murray, Pace & Johnson, P.C. 202 East Fifth Street P.O. Box 400 Sterling, Illinois 61081
(J}CUNVD ~, ~
Laurie S. Elkin

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 1 of 3

MAHONEY, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Rockford)
CIVIL DOCKET FOR CASE #: 3:04-cv-50251

EEOC v. PZ Rest Inc Assigned to: Honorable Philip G. Reinhard Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 06/04/2004 Date Terminated: 10/07/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Laurie S. Elkin Equal Employment Opportunity Commission 500 W. Madison Street 2800 Chicago, IL 60661 (312) 353-7259 Email: laurie.elkin@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

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

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

V. Defendant

https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?243030053895655-L_353_0-1

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 2 of 3

PZ Restaurants Inc

represented by Timothy B. Zollinger Ward, Murray, Pace & Johnson, P. C. P.O. Box 400 202 East Fifth Street Sterling, IL 61081 (815) 625-8200 Email: zollinger@wmpj.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
John Anthony Guzzardo Ward, Murray, Pace & Johnson, P. C. P.O. Box 400 202 East Fifth Street Sterling, IL 61081 (815) 625-8200 Email: guzzardo@wmpj.com ATTORNEY TO BE NOTICED

Date Filed 06/04/2004
06/04/2004 06/22/2004
07/07/2004 07/09/2004 07/23/2004
07/27/2004 08/27/2004

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Gregory M. Gochanour, Laurie S. Elkin as attorney(s) for plaintiff ( 0 summons(es) issued.) ( Documents: 1-1 through 1-3) (clb) (Entered: 06/04/2004)

THIS matter is referred to the Hon. P. Michael Mahoney pursuant to Internal Operating Procedure 11(d). (clb) (Entered: 06/04/2004)

SCHEDULE set on 6/22/04 by Hon. P. Michael Mahoney : Status hearing set to 1:30 7/23/04. Plaintiff is directed to notify any party filing an appearance subsequent to the entry of this order of the status hearing. Mailed notice (glg) (Entered: 06/22/2004)

2 ATTORNEY APPEARANCE for PZ Rest Inc by Timothy B. Zollinger, John Anthony Guzzardo (jat) (Entered: 07/08/2004)

3 WAIVER of service of summons as to PZ Rest Inc sent on 6/9/04; signed on 6/28/04 by T. Zollinger as attorney (jat) (Entered: 07/09/2004)

SCHEDULE set on 7/23/04 by Hon. P. Michael Mahoney : Status hearing held. Discovery/ Settlement conference set for 1:30 9/13/04. Real parties in interest to be present as stated. Partie to submit 2 page settlement document by 9/10/04. No notice (glg) (Entered: 07/23/2004)

4 ANSWER by PZ Rest Inc complaint [1-1] and affirmative defenses (jat) (Entered: 07/28/2004)

SCHEDULE set on 8/27/04 by Hon. P. Michael Mahoney : Due to the court's schedule, Discovery/ Settlement conference reset for 1:30 9/14/04 . Mailed notice (glg) (Entered: 08/27/2004)

https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?243030053895655-L_353_0-1

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 3 of 3

09/13/2004 10/05/2004 10/07/2004
10/20/2004 10/27/2004 10/27/2004

SCHEDULE set on 9/13/04 by Hon. P. Michael Mahoney : Settlement conference stricken. Status hearing to report on settlement set to 1:30 10/6/04 . Mailed notice (glg) (Entered: 09/13/2004)
5 MINUTE ORDER of 10/5/04 by Hon. P. Michael Mahoney : mailed notice: Parties report cause settled. Parties given to 11/5/04 to file stipulation to dismiss. Court retains jurisdiction to enforce settlement. (jat) (Entered: 10/05/2004)
6 MINUTE ORDER of 10/7/04 by Hon. Philip G. Reinhard : Pursuant to Magistrate Mahoney's order of 10/5/04, this case is dismissed. Stipulation to dismiss to be filed by 11/5/04. Court retains jurisdiction to enforce settlement. Any pending motions are now moot. mailed notice (jat) (Entered: 10/08/2004)
7 AGREED MOTION by EEOC for entry of consent decree ; Notice of motion (jmm (Entered: 10/20/2004)
8 MINUTE ORDER of 10/27/04 by Hon. Philip G. Reinhard : Plaintiff's agreed motion for entry of consent decree is granted [7-1]. Enter consent decree. This case is dismissed. Any pending motions are now moot. mailed notice (jat) (Entered: 10/28/2004)
9 CONSENT DECREE by EEOC, PZ Rest Inc, signed by Judge Reinhard (jat) (Entered: 10/28/2004)

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