U.S. DISTRiCT COURT NORTHERN DISTRICT OF TEXAS
FILED

IN THE UNITED STATES DISTRICT CO RT

SEP~

FOR THE NORTHERN DISTRICT OF T S

ORIGINAL

DALLAS DIVISION

CLERK,U . .

COURT

< By ___.___~~+_-----

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

SPRING VALLEY UNITED

)

METHODIST CHURCH

)

)

Defendant.

)

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

CIVIL ACTION NO.
3-06CV1785-R
COMPLAINT (JURY DEMANDED)

COMPLAINT This is an action under Title I ofthe Americans with Disabilities Act of 1990 to correct unlawful employment practices on the basis of disability and to provide appropriate relief to Audrey Durante, who was adversely affected by such practices. The Equal Employment Opportunity Commission ("Commission") alleges that the Defendant, Spring Valley United Methodist Church, violated the Americans with Disabilities Act by terminating Ms. Durante from her positions as a Preschool Teacher and Nursery Worker based on her perceived disability.
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 107(a) of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. § 12117(a), which incorporates by reference §§706(t)(1),(3) and 707(a) of of Title VII of the Civil Rights Act of 1964 ("Title VII"), 42 U.S.C. §2000e-5(t)(1),(3) and 2000e-6(a), and pursuant to §102 of the Civil Rights Act of 1991,

42 U.S.C.§1981A. 2. The employment policies and practices alleged to be unlawful were
committed within the jurisdiction of the United States District Court for the Northern District of Texas, Dallas Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission, is the agency of the United States of America charged with the administration, interpretation and enforcement of Title I of the ADA and is expressly authorized to bring this action by §107(a) of the ADA, 42 U.S.c. § 12117(a), which incorporates by reference §§706(t)(1),(3) and 707(a) of Title VII, 42 U.S.C. §2000e-5(t)(1),(3) and 2000e-6(a). 4. At all relevant times, Defendant, Spring Valley United Methodist Church, has continuously been and is now doing business in the State of Texas and has continuously had at least fifteen employees. 5. At all relevant times, Defendant has continuously been an employer engaged in an industry affecting commerce under § 101(5) of the ADA, 42 U.S.C.§ 12111(5), and § 101(7) of the ADA, 42 U.S.C. § 12111(7), which incorporates by reference §§ 701(g) and (h) of Title VII, 42 U.S.C. §§ 2000e-(g) and (h). 6. At all relevant times, Defendant has been a covered entity under §101(2) of the ADA, 42 U.S.C. § 12111(2).
STATEMENT OF CLAIMS 7. More than 30 days prior to the institution of this lawsuit, Audrey Durante filed a charge of discrimination with the Commission alleging violation of Title I of the ADA by the

COMPLAINT

2

Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 8. The Defendant, Spring Valley United Methodist Church, has engaged in unlawful
employment practices, in violation of § 102 of Title I ofthe ADA, 42 U.S.C. § 12112, by terminating Audrey Durante from her positions as a Preschool Teacher and Nursery worker or because Defendant regarded Ms. Durante as disabled, based on her hearing impairment.
9. The effect of the practices complained of in paragraph 8, above, has been to deprive Audrey Durante of equal employment opportunities and has otherwise adversely affected her status as an employee.
10. The unlawful policies and practices complained of in paragraph 8, above, were committed intentionally.
11. The unlawful policies and practices complained of in paragraph 8, above, were committed with malice or with reckless indifference to the federally protected rights of Audrey Durante.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction ensuring compliance with the ADA, and enjoining Defendant, Spring Valley United Methodist Church, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of disability or perceived disability. B. Order the Defendant to institute and carry out policies, practices and programs that provide equal employment opportunities for qualified individuals with disabilities and which eradicate the effects of the Defendant's past and present unlawful practices.

COMPLAINT

3

C. Order the Defendant to make whole Audrey Durante by providing appropriate back pay with prejudgment interest, in amounts to be proved at trial, and other affirmative relief necessary to eradicate the effects of the Defendant's unlawful employment practices, including but not limited to rightful place reinstatement of Ms. Durante and/or front pay.
D. Order the Defendant to make whole Audrey Durante by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 8 above, including but not limited to emotional pain, suffering, inconvenience, humiliation, mental anguish, and loss of enjoyment of life, in amounts to be determined at trial.
E. Order the Defendant to pay Audrey Durante punitive damages for its malicious conduct or reckless indifference described in paragraph 8, 10, and 11 above, in an amount to be determined at trial.
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Commission its costs in this action.
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.

COMPLAINT

4

COMPLAINT

Respectfully submitted,
RONALD COOPER General Counsel
JAMES LEE Deputy General Counsel
GWENDOLYN REAMS Associate General Counsel
~~"ft±~ Regional Attorney Oklahoma State Bar No. 011782
ROBERT B. HARWIN Associate Regional Attorney District of Columbia Bar No. 076083
SUZANNE M. ANDERSON Supervisory Trial Attorney Texas Bar No. 14009470
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Antonio Field Office 5410 Fredericksburg Road, Suite 200 San Antonio, Texas 78229-3555
Dallas District Office 207 South Houston, 3rd Floor Dallas, Texas 75202 (214) 253-2740 (214) 253-2749 (FAX)
5

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herein neither replace nor supplement the filing and service of pleadings or other papers as required

,ppmvod by tho Jodid,1 Conforen" ofth' Unitod St.." in S",tomb" 1974, i, ,,,,oi,'" fm tho

0" oftho Clock o,foO fu, tho p0'P0re ofiniti"i g tho civil do,kol 'hoot. (SEE INSTRUCnONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINT FFSCLERK, U.S. DISTRICT COURT
.... NORTHERN DISTRICT OF TEXAS
U. S. Equal Employment Opportunity CommissIOn

DEFENDANTS SPRING VALLEY UNITED METHODIST CHURCH

(b) County of Residence of First Listed Plaintilf
(EXCEPT IN U S PLAINTIFF CASES)
ORIGINAL
(c) Attorney's (Firm Name, Address, and Telephone Number)
Suzanne M. Anderson, Supervisory Tnal Attorney EEOC-Dallas District Office 207 South Houston St , 3n1 Floor Dallas, TX 75202 (214) 253-2746

County of Residence of First Listed Defendant (IN U.S. PLAINTIFF CASES ONLY)
NOTE IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOLVED
Attorneys (If Known)
- 3-06 Cv 1 7 8 5 R

II. BASIS OF JURISDICTION (Place an "X" 10 One Box Only)

XI U.S. Government Plaintiff

03 Federal Question (U.S. Government Not a Party)

III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" 10 One Box for PlamtIff

(For Diversity Cases Only)

and One Box for Defendant)

CItizen of This State

PTF DEF 01 01

PTF DEF

o Incorporated or Principal Place

4 04

of Business In This State

02 U.S. Government

04 DiverSity

o Citizen of Another State 02 02 Incorporated and Pnnclpal Place 5 05

Defendant

(Indicate Citizenship of Parties

of Business In Another State

in Item III)

Citizen or Subject of a 03 03 Foreign Nation

o 6 06

Forei!!n Countrv

IV. NATURE OF SUIT (Place an "X" in One Box Only)

CONTRACT

TORTS

FORFEITUREIPENALTY

BANKRUPTCY

OTHER STATUTES

0 110 Insurance

PERSONAL INJURY

PERSONAL INJURY 0

0 120 Marine

0 310 AIrplane

0 362 Personal InJury- 0

0 130 MIller Act

0 315 AIrplane Product

Med MalpractIce 0

0 140 NegotIable Instrument

LIabIlIty

0 365 Personal Injury -

0 150 Recovery of Overpayment 0 320 Assault, Libel &

Product Liability

0

& Enforcement of Judgment

Slander

0 368 Asbestos Personal 0

0 151 MedIcare Act

0 330 Federal Employers'

Injury Product

0

0 152 Recovery of Defaulted

LiabIlIty

LiabIlIty

0

Student Loans

0 340 Marme

PERSONAL PROPERTY

(Excl Veterans)

0 345 Marme Product

0 370 Other Fraud

0

0 153 Recovery of Overpayment

LiabIlIty

0 371 Truth m Lendmg

of Veteran's Benefits 0 350 Motor VehIcle

0 380 Other Personal

0 160 Stockholdel s' SUIts 0 190 Other Conti act

0 355 Motor VehIcle Product LIabIlity

Property Damage 0 385 Property Damage

0

0 195 Contract Product LiabilIty 0 360 Other Personal Injury

Product LIabIlIty

0

REAL PROPERTY

CIVIL RIGHTS

0 210 Land Condenmation

0 441 Votmg

0 220 Foreclosure

X 442 Employment

0 230 Rent Lease & Ejectment 0 443 Housmg!

0 240 Torts to Land

AccommodatIons

0 245 Tort Product LiabIlIty 0 444 Welfare

0 290 All Other Real Property 0 440 Other OVII RIghts

PRISONER PETITIONS 0

0 510 MotIOns to Vacate

Sentence

0

Habeas Corpus'

0 530 General

0

0 535 Death Penalty

0 540 Mandamus & Other 0

0 550 CIVIl Rights

0 555 Pnson Cond!l!on

610 Agnculture 620 Other Food & Drug 625 Drug Related Seizure
of Property 21 USC 630 LIquor Laws 640 R R & Truck 650 Alrlme Regs 660 OccupatIOnal
SafetylHealth 690 Other

0122 Appeal 28 USC 158
0123 WIthdrawal 28 USC 157
PROPERTY RIGHTS
[B20 Copynghts [B30 Patent [B40 Trademark

LABOR

SOCIAL SECURITY

710 Fair Labor Standards [B61 HIA (I 395tl)

Act

[B62 Black Lung (923)

720 LaborlMgmt RelatIOns [B63 DIWCIDIWW (405(g)

[B64 SSID TIlle XVI

730 LaborlMgmt Reportmg [B65 RSI (405(g»

& DIsclosure Act 740 Railway Labor Act

FEDERAL TAX SUITS

790 Other Labor Llhgation

[870 Taxes (U S. PlamtIff or Defendant)

791 Empl Ret Inc Secunty Act

[871 IRS-Third Party 26 USC 7609

o 400 State ReapportlOrunent o 410 Antitrust o 430 Banks and Banking o 450 COIrunerce/lCC Rates/etc o 460 Deportation
D 470 Racketeer Influenced and
Corrupt OrganIzations
o 810 SelectIve SCMce o 850 Secuntles/Commodwesl
Exchange
o 875 Customer Challenge
12 USC 3410
o 891 Agncultural ACls o 892 Economic StablhzatlOn Act o 893 EnVIronmental Matters o 894 Energy AllocatIOn Act o 895 Freedom of
Information Act
o 900 Appeal of Fee
Determmatlon Under Equal
Access to JustIce
o 950 ConstitutlOnahty of
State Statutes
o 890 Other Statutory Actions

V. ORIGIN

(PLACE AN "X" IN ONE BOX ONLY)

X I Original

o 2 Removed from

Proceeding

State Court

o 3 Remanded from
Appellate Court

Transferred from
o another district
4 Reinstated or 0 5 (specify)
Reopened

o 6 Multidistrict
Litigation

Appeal to District Judge from
o 7 Magistrate Judgment

CAUSE OF ACTION (CIte the U S CMI Statute under which you are filmg and wnte bnefstatement of cause

VI.

Do not cIte JurtsdlCtlOnal statules unless dIverSIty )

Spring Valley United Methodist Church violated the Americans with Disabilities Act by terminating Audrey Durante from her position as a

Preschool Teacher and Nursery Worker based on her perceived disability

VII. REQUESTED IN

D CHECK IF THIS IS A CLASS ACTION

DEMAND $

COMPLAINT:

UNDER F R.C.P. 23

VIII. RELATED CASE(S)

IF ANY

DATE

q

(See instructions)

JUDGE

OFATO~

CHECK YES only if demanded in complaint

JURY DEMAND:

X Yes 0 No

DOCKET NUMBER

FOR OFFICE USE RECEIPT # _ _ _ __ AMOUN _ _ _ _ _ __

APPLYING IFP _ _ _ _ _ __

JUDGE _ _ _ _ _ _ ___ MAG fUDGE ____________________

 
 IN THE UNITES STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
SPRING VALLEY UNITED METHODIST CHURCH
Defendant.

)

)

)

CIVIL ACTION NO.

)

)

)

)

3-06-CV-1785-R

)

)

)

)

)

AGREED ORDER

The parties have entered into the Settlement Agreement

(“Agreement”) set out below. Based on a review of the pleadings

and the Agreement, without an admission or finding of liability on

the part of Defendant, the Court finds that (1) it has jurisdiction

over the parties and this action, (2) the Agreement does not

constitute an admission by the Defendant of any violation of the

Americans With Disabilities Act or other wrongdoing, but that the

Defendant in fact expressly denies any such violation or wrongdoing

and entered into the Agreement in compromise and settlement of a

disputed claim for the sole purpose of avoiding further trouble,

litigation, and expense, and (3) the terms of the Agreement

constitute a fair and equitable resolution of all issues in this

action.

It is therefore ORDERED, ADJUDGED, AND DECREED as follows:

AGREED ORDER – Page 1

(1) That this Order is being entered with the consent of the parties for purposes of settlement, is not an adjudication on the merits of the action, and shall not be construed as an admission or finding of liability on the part of Defendant;
(2) That the Agreement is approved; and (3) That the Court shall retain jurisdiction to enforce the terms of the Agreement until the expiration of the term of the Agreement.
SETTLEMENT AGREEMENT Plaintiff the Equal Employment Opportunity Commission (“EEOC”) and Defendant Spring Valley United Methodist Church (the “Church”) hereby compromise and resolve all issues and disputes in the abovestyled action (the “Action”) on the terms and conditions set out below: 1. The EEOC filed this Action against the Church on September 28, 2006 all eging that the Church had violated the Americans with Disabilities Act (“ADA”) by terminating Audrey Durante from her positions as a Preschool Teacher and Nursery Worker based on her perceived disability. The Action seeks, among other relief, non-economic damages. 2. The Church vigorously denies that it discriminated against Ms. Durante under the ADA as alleged in the Action or otherwise. 3. The parties desire to compromise and resolve all issues
AGREED ORDER – Page 2

and disputes in the Action and that were alleged, or are like or related to those matters alleged, in EEOC Charge No. 310 2004 02384 filed by Ms. Durante (the “Charge”). Accordingly, the parties have entered into this Agreement to memorialize the terms and conditions of their compromise and settlement.
4. The Church affirms its commitment to equal employment opportunity and agrees that it shall not discriminate against any qualified employee on the basis of a disability or perceived disability with respect to any employment policies, practices or decisions, and will attempt reasonable accommodations to qualified persons with disabilities when possible without undue hardship.
5. The Church and Ms. Durante have entered into a voluntary settlement in which the Church agreed to pay, and has paid, the sum of $25,000 to Ms. Durante in full and final settlement of any claims she might have or assert against the Church (the “Settlement Payment”). The Settlement Payment is intended to compensate Ms. Durante for her claimed non-economic damages and is in an amount acceptable to Ms. Durante and the EEOC. The Church will issue Ms. Durante a Form 1099, reflecting payment, and she will be personally responsible for payment of applicable taxes. The parties agree that no further relief is owed to Ms. Durante and that she is not a prevailing party for purposes of this Action.
6. The Church agrees to have an attorney conduct training on the requirements of Title I the ADA for all management/supervisory
AGREED ORDER – Page 3

officials of its preschool within 60 days of the date the parties sign this Agreement.
7. The Church agrees to revise its current policies or adopt a policy stating its commitment to offer reasonable job accommodations to applicants and employees consistent with the ADA and how and to whom requests for job accommodation may be made within 60 days of the date the parties sign this Agreement.
8. The Church agrees to provide a report on its compliance with paragraphs (6) and (7) above to the undersigned counsel for the EEOC within 10 days of the completion of each.
9. The EEOC agrees to waive all further litigation on all issues that were alleged, or are like or related to those matters alleged, in the Charge and that are alleged or could have been alleged in the complaint in this Action. The EEOC further agrees to release, acquit, and forever discharge, the Church (and its current or former agents, officers, and employees) from any and all claims raised by, growing out of, resulting from, or like or related to those matters alleged, in the Charge and that are alleged or could have been alleged in the complaint in this Action.
10. The parties further acknowledge and agree: (a) That they have the right to specifically enforce the
terms of this Agreement. (b) That this Agreement resolves all issues and disputes
in the Action and that were alleged, or are like or related to
AGREED ORDER – Page 4

those matters alleged, in the Charge. (c) That this Agreement does not preclude the EEOC from
processing other charges or bringing suit to remedy any other alleged violations of the ADA unrelated to the Charge or this Action.
(d) That this Agreement does not constitute an admission by the Church of any violation of the ADA or other wrongdoing, but that the Church in fact expressly denies any such violation or wrongdoing and enters into this Agreement in compromise and settlement of a disputed claim for the sole purpose of avoiding further trouble, litigation, and expense.
(e) That neither party shall contest the validity of this Agreement or the jurisdiction of the Court to enforce this Agreement and its terms during the six (6)-month period following the effective date of this Agreement.
(f) That the effective date of this Agreement shall be the last date upon which a party signs it for approval by the Court.
(g) To bear their own costs associated with this Action, including attorney’s fees.
(h) That the Court may administratively close the Action, however, the term of this Agreement shall be for six (6) months from the effective date, during which time the Court shall retain jurisdiction to enforce the terms of this
AGREED ORDER – Page 5

Agreement until the expiration of the term of the Agreement.

SIGNED this 2nd day of April, 2007.

509214 000003 DALLAS 2157772.3

_______________________________________ THE HONORABLE JERRY BUCHMEYER,
UNITED STATES DISTRICT JUDGE

AGREED ORDER – Page 6

 
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CLOSED, ECF, JURY, SANDERSON
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:06-cv-01785

Equal Employment Opportunity Commission v. Spring Valley United Methodist Church Assigned to: Judge Jerry Buchmeyer Cause: 28:451 Employment Discrimination

Date Filed: 09/28/2006 Date Terminated: 04/02/2007 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Robert A Canino, Jr Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2750 Email: robert.canino@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gwendolyn Young Reams Equal Employment Opportunity Commission 207 S Houston St 3rd Floor Dallas, TX 75202 214/253-2760

James L Lee Equal Employment Opportunity Commission 207 S Houston St 3rd Floor Dallas, TX 75202 214/253-2760

Jennifer Randall Equal Employment Opportunity Commission 5410 Fredricksburg Rd Suite 200 San Antonio, TX 78229-3555 210/281-7636 Fax: 210/281-7669 FAX Email: jennifer.randall@eeoc.gov

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V. Defendant Spring Valley United Methodist Church

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?580368054854068-L_3...
ATTORNEY TO BE NOTICED
Robert B Harwin Equal Employment Opportunity Commission San Antonio District Office 5410 Fredricksburg Rd Suite 200 San Antonio, TX 78240 210/281-7643 Email: Robert.Harwin@eeoc.gov ATTORNEY TO BE NOTICED
Ronald S Cooper Equal Employment Opportunity Commission 207 S Houston St 3rd Floor Dallas, TX 75202 214/253-2760
Suzanne M Anderson Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2740 Fax: 214/253-2749 FAX Email: suzanne.anderson@eeoc.gov ATTORNEY TO BE NOTICED
represented by Elizabeth A Schartz Thompson & Knight - Dallas 1700 Pacific Ave Suite 3300 Dallas, TX 75201-4693 214/969-1737 Fax: 214/880-3209 FAX Email: elizabeth.schartz@tklaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Date Filed 09/28/2006 09/28/2006 09/28/2006 09/28/2006 09/28/2006 09/28/2006 10/24/2006 12/14/2006 12/18/2006 01/12/2007 01/16/2007
01/16/2007 02/23/2007 02/26/2007
04/02/2007

#

Docket Text

1 COMPLAINT against Spring Valley United Methodist Church filed by Equal Employment Opportunity Commission. (axm, ) (Entered: 09/28/2006)
DEMAND for Trial by Jury by Equal Employment Opportunity Commission. (axm, ) (Entered: 09/28/2006)
2 Summons Issued as to Spring Valley United Methodist Church. (axm, ) (Entered: 09/28/2006)
3 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Equal Employment Opportunity Commission. (axm, ) (Entered: 09/28/2006)
***Magistrate Judge Sanderson chosen by random selection to handle matters that may be referred in this case. (axm, ) (Entered: 09/28/2006)
4 Order Designating Case for ECF - see order for specifics. (Signed by Judge Jerry Buchmeyer on 09/28/2006) (axm, ) (Entered: 09/28/2006)
5 NOTICE of Attorney Appearance by Jennifer Randall on behalf of Equal Employment Opportunity Commission (Randall, Jennifer) (Entered: 10/24/2006)
6 Unopposed Motion to Extend Time to Answer or Otherwise Respond to Plaintiff's Original Complaint by Spring Valley United Methodist Church. (klm, ) (Entered: 12/14/2006)
7 ORDER granting 6 Defendant's Unopposed Motion to Extend Time to Answer re 1 Complaint Spring Valley United Methodist Church answer due 1/17/2007. (Signed by Judge Jerry Buchmeyer on 12/18/06) (klm, ) (Entered: 12/18/2006)
8 Joint Motion for Extension of Time to File Answer by Equal Employment Opportunity Commission, Spring Valley United Methodist Church. (klm) (Entered: 01/12/2007)
9 AGREED ORDER granting 8 Joint Motion for Extension of Time for Defendant to Answer re 1 Complaint Spring Valley United Methodist Church answer due 2/27/2007. The parties report to the Court on the status of the settlement or file appropriate papers with the Court no later than February 27, 2007. (Signed by Judge Jerry Buchmeyer on 1/16/07) (klm) (Entered: 01/16/2007)
Set/Reset Deadlines: Status Report due by 2/27/2007 per doc. no. 9. (klm) (Entered: 01/16/2007)
11 JOINT STATUS REPORT by Equal Employment Opportunity Commission, Spring Valley United Methodist Church. (npk) (Entered: 02/26/2007)
10 AGREED ORDER GRANTING TIME FOR THE PARTIES TO FILE APPROPRIATE PAPERS OR FURTHER STATUS REPORT: Status Report due by 3/27/2007. (Signed by Judge Jerry Buchmeyer on 2/26/07) (klm) (Entered: 02/26/2007)
12 AGREED ORDER: This Order is being entered with the consent of the parties for purposes of settlement. (see order for specifics) (Signed by Judge Jerry Buchmeyer on 4/2/07) (klm) (Entered: 04/02/2007)

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04/02/2007

***Civil Case Terminated per doc. no. 12. (klm) (Entered: 04/02/2007)

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