PI LID Case 1:06-cv-21668-AJ Document 1 Entered on FLSD Docket 07/05/2006 Page 1 of 6
JUN 10 2006
-IN T. IE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORID A
MIAMI DIVISIO N

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, )

Plaintiff .

v.

)

CIVIL ACTION NO .
COMPLAINT JURY 1RIAI . DEMAND

APPLEGAI'E IJSA . INC . d/b/a

)

UNITED SHEET METAL ) INJUNCTIVE RELIEF REQUESTED

Defendants .

NATURE OF THE ACTIO N 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 co rrect unlawful employment practices on the basis of sex, female and pregnancy , and to provide appropriate relief due to Jessica Hernandez ("He rn andez ") who was adversely affected by such practices . As stated with greater particularity in the paragraphs below , the United States Equal Employment Opportunity Commission (hereinafter the "EEOC" or "Commission ") alleges that Defendant discriminated against Ms . Hernandez because of her sex, female, and her pregnancy .
JURISDICTION AND VENU E 1 . Jurisdiction of this Court is invoked pursuant to 28 U .S .C . `5 451, 1331, 1337, 1343 and 1345 . This action is authorized and instituted pursuant to Section 706 (f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U .S .C. . §2000e-5(f)(1) and (3 ) ("Title VII") 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 th e
1
I

Case 1:06-cv-21668-AJ Document 1 Entered on FLSD Docket 07/05/2006 Page 2 of 6
jurisdiction of the United States District Court for the Southern District of Florida . Miam i Division .
PARTIE S 3. Plaintiff, the 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 Section 706(1)(1) and (3) of Title VII, 42 U .S.C . §2000e-5(f)(1) and (3) . 4 . At all relevant times, Defendant Applegate USA . Inc . d/b/a United Sheet Metal ("Defendant"), a sheet metal contractor, has continuously been a Florida corporation, doing business in the State of Florida and the City of Miami . and has continuously had at least 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. §5 2000e(b), (g) and (h).
STATEMENT OF CLAIM S 6. More than thirty days prior to the institution of this lawsuit, Jessica Hernandez 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 . Since at least February 2005, Defendant has engaged in unlawful employment practices in violation of Section 703 ( a)(1) of Title VII, 42 U .S .C . 2000e-2(a) .
a. Jessica He rnandez began working for Defendant in August 2004 as an Administrative Assistant .
b. On or about April 18 , 2005, Ms. Hernandez informed her employer that she wanted to take maternity leave beginning on July 2005 .
c . On or about April 28, 2005 , approximately ten days after informing

Case 1:06-cv-21668-AJ Document 1 Entered on FLSD Docket 07/05/2006 Page 3 of 6
Defendant of her upcoming need for maternity leave . Defendant terminated her employment . 8 . The effect of the unlawful employment practices complained of above has been to deprive Jessica Ilernandez of equal employment opportunities . and otherwise adversely affect her status as an employee because of her sex . 9. The unlawful employment practices complained of above were intentional . 10. The unlawful employment practices complained of above were done with malice or with reckless indifference to the federally protected rights of Jessica I Iernandez .
PRAYER FOR RELIEF Wherefore, the Commission 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 sex and pregnancy discrimination in employment practices at its facilities . B . Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for women which eradicate the effects of its past and present unlawful employment practices . C . Order Defendant to make whole Jessica Hernandez by providing appropriate bac k 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, including but not limited to, reinstatement, rightful-place hiring, and front pay . D . Order Defendant to make whole Jessica Hernandez by providing compensation for past and future pecuniary losses resulting from the employment practices described in paragraph seven above, including but not limited to, out-of-pocket losses, medical expenses and

Case 1:06-cv-21668-AJ Document 1 Entered on FLSD Docket 07/05/2006 Page 4 of 6
job search expenses, in amounts to be determined at trial . E. Order Defendant to make whole Jessica IIernandez by providing compensation
for past and future nonpecuniary losses resulting from the employment practices described in paragraphs seven above, including but not limited to, emotional pain, suffering, inconvenience, loss of enjoyment of life, and humiliation, in amounts to be determined at trial .
F . Order Defendant to pay punitive damages for their malicious and reckless conduct described in paragraph seven above, in an amount to be determined at trial .
G . Grant such further relief as the Court deems necessary and proper in the public interest .
11. Award the Commission its costs of this action . JURY TRIAL DEMAN D
The Commission requests a jury trial on all questions of fact raised by its complaint .
Respectfully Submitted ,
JAMES L . LEE Deputy General Counse l GWENDOLYN YOUNG REAMS Associate General Counsel DELNER FRANKLIN-THOMAS Regional Attorney
Az~
Lauren G . Dreilinger Trial Attorne y New York Bar No . 750288890 EQUAL EMPLOYMENT OPPORTUNITY COMMISSIO N
4

Case 1:06-cv-21668-AJ Document 1 Entered on FLSD Docket 07/05/2006 Page 5 of 6 2 South Biscayne Boulevard , Suite 2700 Miami, Florida 3313 1 Tel . (305) 808-1795 Fax (305) 808-1835 laurcn .dreilinger(ceeoc .gov
5

®JS 44 (Rev . 11/05)
Case 1:06-cv-21668-AJ

DocumCeIVntIL1 COEVntEeRreSdHoEnEFTLSD Docket 07/05/2006

Page 6 of 6

The 1S 44 civil cover sheet and the information contained herein neither replace nor supplement the tiling and same le s or oche et ~5 re roll b~hw, except as provided

by local rules of court . This form, approved by the Judicial Conference of the United States in September 1974. is r e o ems! of ro lea f u fit o se of miuating

Inc civil docket sheet . (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM .)

NOTICE . A ttorneys ease All 11 Ca

. rr"

1 . (a) PLAINTIFFS U . S . EQUAL EMPLOYMENT OPPORTUNITY COMMISSIO N

DEFENDANT S APPLEGAT I C . /a UNITED SHEET METAL

(b) County of Residence of First Listed Plaintiff Miami-Dade County (EXCEPT IN U .S . PLAINTIFF CASES )

County of Residence of First Listed D°efeF n a A Dade Count-y
(IN U .S . PLAINTIFF CASES ONLY)

(C) Attorney's (Finn Name . Address, and Telephone Number )
U .S . Equal Employment Opportunity Commission 2S th Biscayne Blvd ., Suite 270 0
iami, ' 33 I Tel : (305) 808-1783

NOTE : IN LAN[}FQNDEMNATION CASES, USE THE LOCATION OF Till . TRACT LAN INVOLVEDir

ILI c- _y

t

(d) Check County Where Action Arose : MIAMI- DADE O MONRO E

BROWAR

O PALM BED II fl MARTIN O S- . aL Ga~A AW N RIVER O OKEECIIOBEI I110til-ANU S

Ill . BASIS OF JURISDICTION (P lace an "X" in One Box Only)

6M I U .S. Government Plaintiff

0 3 Federal Questio n (U .S. Government Not a Party )

111 . CITIZENS MP OF P ~~/ .~ARTIES(Place an °x" in one Box for Plaintif f

(Fur Diversity Cases Onl `` n(x Oand One Box for Defendant)

UEF VO PTF DEF

CitiLen ofThis State

~I Incorporated or Principal Place r7 4 r1 4

" -- ss In This Stat e 4Q,!.!, "

71 2 U .S. Governmen t Defendant

^14 Diversity (Indicate Citizenship of P arties in Item III )

Citizen of Another State rl 2 11 2

of Bus'ihess In Another State

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

CON [RACT

TORTS

Citizen or Subject of a rl 3 C1 3 Foreign Nation Foreign County

FORFEITURE/PENALTY

BANKRUPTCY

rl 6 r1 6 OTHER STATUTE S

71 1 10 Insurance rl 120 Marine '1 130 Miller Act

PERSONAL INJURY 71 31(1 Airplane 71 315 Airplane Product

O 140 Negotiable Instrument

Liability

O 150 Recovery of Overpayment O 320 Assault, Libel &

& Enforcement of Judgment

Slander

C1 151 Medicare Act

O 330 Federal Employers'

0 152 Recovery of Defaulted

Liability

Student Loans (Excl . Veterans) O 153 Recovery of Overpayment of Veteran's Benefits rl 160 Stockholders' Suits t1 190 Other Contract O 195 Contract Product Liability rl 196 Franchise

O 340 Marine O 345 Marine Product
Liability O 350 Motor Vehicle r7 355 Motor Vehicle
Product Liability rl 360 Other Personal
Injury

REAL PROPERTY O 210 Land Condemnation
220 Foreclosure O 230 Rent Lease & Ejectment
rl 240 Torts to Land O 245 Ton Product Liability Cl 290 All Other Real Property

CIVIL RIGHTS 0 441 Voting X 442 Employment
0 443 Ilousingi Accommodations
O 444 Welfare 0 445 Amer . w/Disabilities -

Employment rl 446 Amer . w,Disabilities -
Other

1440 Other Civil Right s

PERSONAL INJURY O 610 Agriculture

r1 362 Personal Injury - rl 620 Other Food & Drug

Med. Malpractice r1 625 Drug Related Seizure

O 365 Personal Injury -

of Property 21 USC 881

Product Liability O 630 Liquor Laws

O 368 Asbestos Personal fl 640 R.R. & Truck

Injury Product

O 650 Airline Regs .

Liability

0 660 Occupational

PERSONAL PROPERTY

Safety/Health

0 370 Other Fraud

O 690 Other

O 371 Truth in Lending I LABOR

0 380 Other Personal

O 711) Fair Labor Standards

Property Damage

Act

0 385 Property Damage O 720 Labor/Mgmt . Relations

Product Liability rl 730 LaboriMgmt .Reporting

& Disclosure Act

PRISONER PETITION S r1 740 Railway Labor Act

O 510 Motions to Vacate O 790 Other Labor Litigation

Sentence

1 791 Empl . Ret Inc .

Ilabeas Corpus:

Security Act

O 530 General

0 535 Death Penalty

0 S40 Mandamus & Other

0 550 Civil Rights

fl 555 Prison Condition

O 422 Appeal 28 USC 158 fl 423 Withdrawal
28 USC 157
PROPERTY RIGIITS rl 820 Copyrights 0 830 Patent 0 840 Trademark
SOCIAL SECURITY 0 861 HIA (I395ff) O 862 Black Lung (923) O 863 DIWC/DIWW (405(g)) 1 864 SSID Title XVI 1 865 RSI (405(g))
FEDERAL TAX SUITS 0 870 Taxes (U .S . Plaintiff
or Defendant) 0 871 IRS Third Party
26 USC 7609

O 400 State Reapportionmen t O 410 Antitrus t O 430 Banks and Bankin g O 450 Commerce 0 460 Deportatio n rl 470 Racketeer Influenced an d
Corrupt Organizations 0 480 Consumer Credi t r1 490 Cable/Sat T V D 810 Selective Servic e 0 850 Securities/Commodities ,
Exchange rl 875 Customer Challenge
12 USC 341 0 O 891) Other Statutory Action s rl 891 Agricultural Act s 0 892 Economic Stabilization Ac t 0 893 Environmental Matter s O 894 Energy Allocation Ac t 0 895 Freedom of Informan tio
Ac t O 900Appeal of Fee Determinatio n
Under Equal Acces s to Justic e O 950 Constitutionality o f
State Statute s

V . ORIGIN ( Place an "X" in One Box Only) El I Original 0 2 Removed from 0 3

Ke-filed-

O

4

Reinstated

or

0

5

anothaenrothdeirstric

ttiscr

ct

0

6

Multidistrict

Proceeding State Court ( see VI below )

Reopened

(specify) Litigation

VI . RELATED/ RE-FILED

CASE(S) .

(See instructions second page) :

a) Re-filed Case 71 YES L-I NO b) Related Cases 0 YES 0 N O

JUDGE

DOCKET NUMBER

07

Appeal to District Judge fro m
Magistrate Judgmen t

VII . CAUSE OF ACTIO N

Cite the U .S . Civil Statute under which you are filing and Write a Brief Statement of Cause ( Do nut cite jurisdictional statutes unless diversity) :
TITLE VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 . Employment Discrimination on the basis of sex (female . pregnancy) . LENGTH OF TRIAL via 3-5 days estimated (for both sides to try entire case )

VIII . REQUESTED IN O CHECK IF THIS IS A CLASS ACTIO N COMPLAINT : UNDER F .R .C .P . 2 3

DEMAND S

CHECK YES only if demanded in complaint : JURY DEMAND : [Yes Iv N o

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE

SIGNATU~)',3FjrCTTORbfC1'9~ RECORD

DATE:

FOR OFFICE USE ONL

AMOUNT RECEIPT 8

IF P

 
 Case 1:06-cv-21668-AJ Document 34 Entered on FLSD Docket 07/03/2007 Page 1 of 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION CASE NO. 06-21668-CIV-JORDAN

UNITED STATES EQUAL

)

EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

) Plaintiff
)

vs.

)

) APPELGATE USA, INC., d/b/a
) UNITED SHEET METAL,
)

Defendant

)

____________________________________

FINAL ORDER OF DISMISSAL WITH PREJUDICE AND CLOSING CASE Pursuant to the parties’ joint stipulation, this lawsuit is DISMISSED WITH PREJUDICE. Each party shall bear its own fees and costs. All pending motions are denied as moot, and this case is CLOSED. The court retains jurisdiction to enforce the terms of the consent decree. DONE and ORDERED in chambers in Miami, Florida, this 3rd day of July, 2007.

Copy to: All counsel of record

_______________________ Adalberto Jordan United States District Judge

 
 Case 1:06.-.c..v-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 1 of 12

IN THE UNITED STATE~ DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

CASE NO. 06·21668-CIV-JORDAN

UNITED STATES EQUAL EMPLOYMENT

)

OPPORTUNITY COMMISSION,

.

)

)

Plaintiff,

) CLOSED

)

'Vo

) CIVIL

)

APPLEGATE USA, INC. d/b/a UNITED SHEET

)

CASE

METAL,

)

)

Defendaat.

)

CONSENJ DECREE
J. THE LWGAIION
1. Plaintiff Equal Employment Opportunity Commission ("EEOC") filed this action alleging Defendant, Applegate USA, Inc., d/b/a United Sheet Metal violated Title VII of the Civil Rights Act of 1964 and Title I ofthe Civil Rights Act of 1991, Section 703(a)(l), 42 U.S.C. §2000e·2(a). Specifi~ally, EEOC alleged that Defendant violated Title VII when it fired Jessica Chavez, formerly known as Jessica Hernandez,1 on or about April 29, 2005 because she was pregnant.
2. Defendant denies that it engaged in pregnancy discrimination or committed any of the violations alleged by the EEOC but is resolving this matter to avoid the time and expense of continued litigation. Specifically, Defendant filed an Answer to EEOC's Complaint, denying the allegations. This Consent Decree is not an adjudication or finding on whether discrimination
After Jessica Hernandez' employment was terminated by Defendant, Ms. Hernandez married and clumjed her last name to Chavez.

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 2 of 12
occurred and shall not operate as an admission by Defendant that i~ or anyone on its behalf, discriminated against Jessica Chavez. ·For purposes of this Consent Decree, the term '"Defendant" means Applegate USA, Inc. d/b/a United Sheet Metal and/or any other business name under which Applegate USA, Inc. operates and its officers, agents, successors and assigns.
3. In .the interest of resolving this matter and avoiding time and future costs of continuing the litigation and as a result of bavhlg engaged in comprehensive settlement
negotiations, the parties have agreed that this action should be finally resolved by entry of this Consent Decree ("Decree''). This Decree fully and finally resolves any and all issues and claims arising out of the Complaints filed by EEOC in this action arising from the Charge of
Discrimination filed by Jessica Hernandez. The parties agree that this Decree does not resolve future or pending Charges of Discrimination (if any) other than the Charge referred to in this paragraph.
U. FINDINGS Having caretWly examined the terms and provisions of this Decree, and based on the pleadings, record, and stipulations ofthe parties, the Court finds the following: a. · This Court has jurisdiction of 1he subject matter of this action and of the parties. b. No party shall contest the jurisdiction of1bis Federal Court to enforce this Decree and its terms or the right of the EEOC to bring an enforcement suit upon alleged breach ofany term(s) of this Decree. c. The terms of this Decree arc adequate, fair, reasonable, equitable, and just. The rights of the Defendant, the EEOC, the Complainant and the public interest are adequately protected by this Decree.
2

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 3 of 12

I
d. This Decree conforms with the Federal Rules of Civil Procedure and Title

VD 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 Jessica Chavez, EEOC

and the public.

e. The terms ofthis Decree are and shall be binding upon Jessica Chavez, the

EEOC, and the Defendant and its present and future representatives, agents, ~tors, and

officers.

NOW, 1HER.EFORE, IT IS ORDERED, ADJUDGED AND DECREED TIIAT:

Ill. GENERAL INJUNCTIVE PROVISiotJS

4. Defendant· acknowledges its respc;msibility under Title VII to prohibit

discrimination because of sex and pregnancy. Accordingly, Defendant and the officers, agents

(mcluding management personnel), successors, and assigns are hereby enjoined from

discriminating on the basis ofsex and pregnancy.

S.

Defendant, its officers, agents, employees, successors, assigns, and all persons

I
acting in concert With it are hereby enjoined from engaging in any form of retaliation against any

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

Charge of Discrimination under Title VII, testified or participated in any manner in any

investigation, prcx1eeding, or hearing under Title VII, or asserted any rights under this Decree.

IV. APOPTiON AND DISTRIBliTION OF ANTI-DISCRIMINATION POLICY

6. Within thirty (30) calendar days of entry of this Consent Decree, Defendant shall

issue an anti-discrimination policy (''Policy'') and shall provide the Policy to EEOC. This and

any other submissions, reports, certifications, notices, or other materials that are required to be

submitted to EEOC shall be mailed to: Applegate Settlement, c/o Maria Kate Boehringer, Senior

3

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 4 of 12
Trial Attorney, United States Equal Employment Opportunity Commission, One Biscayne Tower, 2 South Biscayne Blvd., Suite 2700, Miami, Florida 33131.
7. Defendant's Policy shall clearly define prohibited c:onduct and specifically prohibit harassing, dcmotin& firing, or taking :my adverse action against an employee because that employee is pregnant or because of condition related to pregnancy, such as pregnancy related health care, medical appointments, and/or pregnancy related absences. The Policy shall provide that complaints of discrimination, inquiries about making such complaints, or inquiries about Defendant's Policy, may be made to any supervisory person in the c:hain of command or directly to human resources personnel. The Policy shall state that no employee will be penalized in any manner for making such complaint, seeking information about making such a complaint, seeking information about Defendant's Policy, and/or participating in any investigation or follow-up contact concernina such a complaint.
8. Withln sixty (60) calendar days of entry of this Consent Decree, the Policy shall be distributed to all of Defendant's employees and management staff in all locations (including all job sites, whether temporary or permanent) where employees of Defendant work and all job sites where temporary employees are assigned to work for Defendant and shall be included in any relevant policy or employee manuals kept by Defendant's ~usiness. The Policy shall also be kept and maintained in a conspicuous and accessible place for all employees at all ofDefendant's facilities and printed in a font that is easily legible (at least 12 point font).
9. A ~opy of the Policy shall be distributed to each new regular full-time, part-time, or temporary employee on the day the employee is hired and, for temporary workers who are assigned to work for Defendant through a staffing or tempOrary agency, on the day that the worker first performs work for Defendant. The manager responsible for distribu1ing the Policy to
4

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 5 of 12
each new employee shall review the Policy with the employee. Defendant shall maintain records demonstratirig that each new employee reviewed the Policy and said new employee shall place his or her signature on a oopy ofthe policy, along with the date ofthe signa1ure.
Y-IRAINING
10. ~g each of the three (3) years· covered by this Decree. Defendant shall provide training to all Defendant's employees and to all persons who perfonn work for
Defendant (even ~f that -.York is perfonned on a temjlOrary basis or is performed through a staffing and or temporary agency, but not if that person is an independent contractor or an
employee or ag~t of one of Defendant's independent contractors), including all management personnel, on equal employment opportunity laws (including pregnaricy and sex discrimination) and the new Policy. Defendant shall provide specific training to all Applegate USA, Inc. employees, including all management personnel, on all equal employment opportunity laws (including pregnancy discrimination) and the Policy referenced in paragraph 6. This training
shall be conducted separately from other job-related trainins and/or business-wide meetings and
the· training sessionls shall be dedicated solely to all equal employment opportunity laws and Defendant's Policy referenced in paragraph 6. Defendant sball provide specific training to all employees, supervisors, and managers concerning the strict prohibition against penalizing any
a employee in any m..~rmer ..vhatsoever for making complaint of discrimination, for making . inquiries about making such a complaint. and/or for participating in any investigation of such a
complaiJ,lt. The training shall be conducted by a person and/or persons Bil'eed upon by Defendant and EEOC. The first training shall take place within sixty (60) calendar days of entry of this Decree. The remainder of the training sessions shall take place annually and no later than July 1• of each year throughout the duration ofthe Decree.
s

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 6 of 12
11. Within ten (10) calendar days of the completion of 1raining, Defendant shall notify EEOC of the dates the training was conducted, the name and job title of the person(s) who conducted the training, and the name and job title ofeach person who received the training.
12. Defendant shall provide to EEOC any and all copies of pamphlets, brochures, outlines or other written materials provided to the participants ofthe training sessions.
VL POSTING OF NOTICE 13. Within ten (1 0) business days after entry of this Decree, Defendant shall post an
eleven (11) inches by fourteen (14) inches laminated copy ofthe Notice attached as Exhibit A to this Decree at all' of its facilities (including all offices, temporary job sites, project job sites, or
other places where persons perform work for Defendant) in a conspicuous location easily accessible to and com!nonly frequented by persons who perform work for Defendant. The Notice shall remain posted for three (3) years from the date of entry of this Decree. Defendant shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other materiaL Defendant shall certifY to EEOC in writing within fifteen (IS) business days after entry of the Decree that the Notice has been properly posted. Defendant shall permit a representative of EEOC to enter Defendant's premises for pmposes ofverifying compliance with this Paragraph at any time during normal business hoU:rs without prior notice.
VII. RECORD KEEPING AND REPOR1'JNG 14. D~fendant shall furnish to EEOC the following written reports twice annually for 11. period of three (3) years following entry of this Decree. The first report shall be due six (6) months after entry ofthe Decree. Each such report sha11 contain:
a. A description of each· complaint of discrimination, including the names ofthe comp~aining partles and witnesses and the resolution of such complaint. occurr.ina within the six
6

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 7 of 12
(6) month period preceding the report. Information identifying Defendant's employees produced pursuant to this Decree will only be used to facilitate compliance with this Dec:ree.
b. A description of any and all action Defendant took in response to each complaint, conclusions reached, and actions taken as a result of the complaint.
c. A certification by Defendant that the Notice required to be posted in Paragraph 13, above, remained posted during the entire six (6) month period pr,eceding the report.
IS. Defendant shall provide EEOC with copies of all documents and records referred to in paragraph 14. In ~tion, Defendant shall provide the l~t known home address, home telephone number, and mobile telephone number for all persons in its employ during the term of the Decree whom EEOC requests and identifies for purposes of verifYing compliance with this Decree within fifteen (15) calendar days of its receipt of EEOC's written request. Moreover, Defendant shall permit employees whom EEOC requests to interview for the purposes of verifying complianee with this Decree to speak coimdentially with EEOC. In the event that EEOC is unable to contact an employee for purposes of verifying compliance with this Decree, it shall notify Defendant .00 Defendant shall, within fifteen (15) business days, provide EEOC with the employee's scheduled hours of work over the next fourteen (14) day period so that EEOC can conduct these intervievvs at these employees' breaks, at the end of the day, or at some other time convenient to the employee and EEOC. Defendant agrees that it will not discourage employees from participating in these interviews.
16. Nothing contained in this Decrw shall be construed to limit any obligation Defendant may otherwise have to maintain records under Title VII or any other law or regulation.
7

Case 1:06-cv-21668-AJ

Document 36 Entered on FLSD Docket 07/09/2007
VID· MONETARY RELIEF

T Page 8 of 12

17.

Defe:lcm.'lt ::hall pay a lump sum in the amount of Orie Hundred Thousand and

00/100 ($1 OO.OOO.OQ) Dollars to resolve this litigation.

a. Jessica Chavez

i. Ninety Thousand and 00/100 ($90.000.00) Dollars shall be paid to

· Jessica Chavez and shall be representative of compensatory damages. Defendant

slulll issue an I;R.S. Form 1099 to Jessica Chavez for this amount

ii. Ten Thousmd and 00/100 ($10.000.00l Dollars shall be paid to

Jessica Chavez and shall be representative of back pay/lost wages.

Defendant shall issue an I.R.S. Fonn W-2 to Jessica Chavez for this

amount and shall be responsible for the payment of the employer's share

of any federal, state and local income taxes, and social security

withholdings.

18. Payments shall issue within thirty (30) calendar days from the Court~s execution

of this Decree, by Certified Mail (Return Receipt) to Jessica Chavez at 8118 Virgo Street,

Jacksonville, FL 32216. Copies of the payments and I.R.S. Form 1099 shall be forwarded to.the

attention ofMaria Kate Boehringer~ Senior Trial Attorney~ U.S. Equal Employment Opportunity

Commissiollt One Biscayne Tower, 2 South Biscayne Boulevard, Suite 270.0, Miami, Florida

33131.

19. If Defendant fails to tender the payment described in paragraph 17, above, then

Defendants shall pay interest· on the defaulted payment at the rate calculated pursuant to 26

.

.

U.S.C. Section 6621(b) until the same is paid, and bear any additional costs incur.red by the

EEOC caused by the non-compliance or delay ofthe Defendant.

8

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 9 of 12 IX. DISPUTE BESOLUTION
20. In the event that EEOC believes that Defendant has failed to comply with any provision(a) of the Decree, EEOC shall have the right to seek Court intervention. Additiooally, no party shall contest the Court's jurisdiction to hear a dispute arising from the Decree nor challenge EEOC's ability to bring an action to enforce the terms ofthe Decree in this Court.
X. DURATION OF THE DECREE ANP BEJENIION OF JURISDICI'ION 21. All provisions of this Decree shall be in effect for a period of three (3) years immediately following entry ofthe Decree. 22. Each party to this Decree shall bear its own expenses, costs and attorneys' fees.
9

Case 1:06-cv-21668-AJ Document 36 Entered on FLSD Docket 07/09/2007 Page 10 of 12

AGREED TO:
FOR THE PLAINTIFF~ UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

By:

b

Date: J'" u n.s... I..._. J ~00 3=

MARIA KATE OEHRINOER

Senior Trial A ey

Florida Bar No. 0041157

U.S. Equal Employment Opportunity Commission

Miami District Office

2 South Biscayne Boulevard, Suite 2700

Miami, Florida 33131

Telephone: (305) 808-1789

Facsimile: (305) 808-1835

By:

b ~. ~ *· E-mail: maria.boehringer@eeoc.aov
Counsel for Plaintiff EEOC
BRUCE A. INOSENCIO, JR.

Date:

Florida Bar No. 1663 9

Admitted Pro Hac Vice

Law Office ofBruce A. lnosencio, Jr., PLLC

740 W. Michigan Avenue

Jackson, MI 49204-4033

Telephone: (517) 796-1444

Facsimile: (517) 796-1050

E-mail: bru ·

i

C 1 De dant MARK . UBERGER

zs; Date: <1Avtz_ ta11 I

Florida Bar No. 0982024

Buchanan..Ingersoll & Rooney, PC

Bank of America Tower-Suite 3400

100 Southeast Second Street

Miami, FL 33131

Telephone: (305) 347-4080

Facsimile: (305) 347-4089

E-mail: mark.neuber~er@bipc.com

Counsel for Defendant ·

10

Jun 25 07 0315B~

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CaseJu1n:062S-cv2-0201?66lr8&-A&PJ~ DLo•wcumO~efnitc•36or E'~n~t=ecred on FLSD Docket 07/09/2007 Page 11 of 12

AGREED TO;
FOR TBE.DUE.ND,ANT., APPl.EGATE tJSA, C. dlltl• UNITED SHF..ETMETAL
By:

ENTERED:

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11

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CaseJu1n:0625-cv2-0201766l18S-SAPJt'l

L"lll Of"-F:Lo~t C)f' ii"I.ICt• Jnos• Sl7 ?96-lU5D
Document 36 Entered on FLSD Docket 07/09/2007

Page 12 of 12

ftXW.II.'I.A

tiPJlg TO ALL APH•F..GA1!1iYS6, INC. E'MJPI;0'¥)1ES

C\pp:llSCo0SAut4Jr'.ItoIItllnDl•TiOel£Ui.)o'PhsdiDanNisvCvoia4idtyoiuoc.la.eoPlAtltiicRsodfPa'bai~ «ro£ptlf4"oItnSlteiecmtplyUcpe~lSt&Oht'AV)ae'D.dtll!pUl•rl'i)~onwf.ht~..rtibdCuboimiisr·~ovtCird\itimJovA~iir.lcntia:anltCiltlcit'i,onc,nh,DanN.1linliocbol.'1A1e01co6Daact-aac2so~aloelf~n~t6nol:9flfCeJtni..t4mt.1.bC;j(r~l)c"]V:Tod.y"deJdbieOC~)~"l:e~,VtbDhuR~Ae~UN"g.Ul)i.o.~$Aan1p,,j.'&oiil~llo~•mCoi£ltva1a:n1trLd~.l

nali011al origbt. Uldlot 1tX. iDCI\ld.hta p~tp'IUSO)', emplo)'ftlCnt discrimiution oC,my ldttclull:t forth it:w

Applegate UEA. lac. wi.U nO"t COildol.e rc4eral ami~·mmina'lioa laws, i.ncl:uclin3.

bllt Dot limited to,. ~Y discrimi'IUI.tioo.

Clhp'*l}' AJipleaate USA. lBc. will usure its

tllat it ~rt:l l'itlo Vll and will not ~:o

Uaunpl)y'toaflenatpnioldDoyiaq..:a.:Jiwl(\iin8inc\&luadntcili:'nnlrnd. ii,n,vaaiMdtiuosaoel,m'bbaaessneetddpolnlJnnIiGOsiP.lx~~ ealn)cdf:n/.ioUrcrDupdmretsotpaD1hac0cvcaeyi.vni•Ac~>oJ-ho•tlpeY'.reco(l}.p.Arisapbspaollelcgbonent"etoacuktisev;ne.,~DICsntcito.o•.,•.

policy p~bibidnc 4iscrtminldiob.

\yioisolbhialviEterE.bOneeCeen~eccnloifsolcor:rrci,em~sZinJtihasteaicofnea,cgSnaeabnd\1lo1lN,afwl0\$o1raimsghaa1iy,n1sc10tc1xdl1l(slllcoerctiElmuEdiDOinaCgtipoanot p(i3na0nC5c!):D)8p'0l)o8fly·11mcc7l~e4~s0tc. .omnIf:t.yhooecubcbabeslaisireJo\u~f
no fcca and hu cmployeocs who lfi!Cak J;aJ~J.CIII n1MJ tbAn Bngl\sh.

aoltocrmecpl,Tldh~ellfaw:cNietohdticitoearmtcuc1mo1VtuIIrNemaC.laBIylbDbyepgdwai:urryKcIocJt~ohreto'Irt:·rmAopatpt(e3lre1iaaayl.t.lc*'S:sAetntUi.yac-m.LqOuthDIIl!tsl,tdic.oa/ontesMbae.b..lonor..wuK: oatobtdei:.1nB&N-ouosethtlarcioonlgbeoerr,:
SenJor Tdal Attomoy, !SOC. One Bi$eayne l·o"Wa"~ 2 South Bisca.)'D• Blvd., Suite 2700, Miami,
Florida 3llll.

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API'LEGA1."'E Ui3i'~.. INC.

l2

 
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CLOSED, EGT, MEDIATION), REF_DISCOV
U.S. District Court Southern District of Florida (Miami) CIVIL DOCKET FOR CASE #: 1:06-cv-21668-AJ

US Equal Employment v. Applegate USA, Inc. Assigned to: Judge Adalberto Jordan Referred to: Magistrate Judge Edwin G. Torres Demand: $0 Cause: 42:2000 Job Discrimination (Sex)
Plaintiff
United States Equal Employment Opportunity Commission

Date Filed: 06/30/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Lauren Gayle Dreilinger Equal Employment Opportunity Commission Miami District Office 2 S Biscayne Boulevard 2700 One Biscayne Tower Miami, FL 33131-2483 305-808-1795 Fax: 305-808-1835 Email: lauren.dreilinger@eeoc.gov TERMINATED: 02/08/2007 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Maria Kate Boehringer Boehringer Law Office PA 1515 N Federal Highway Suite 300 Boca Raton, FL 33432 561-392-2120 Fax: 392-2250 Email: maria.boehringer@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Michael Wells Equal Employment Opportunity Commission 501 E Polk Street 10th Floor Timberlake Federal Bldg Tampa, FL 33602 813-202-7902 Fax: 813-228-2045 TERMINATED: 02/08/2007 LEAD ATTORNEY

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V. Defendant Applegate USA, Inc. doing business as United Sheet Metal
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Nora E. Curtin Equal Employment Opportunity Commission Miami District Office 2 S Biscayne Boulevard 2700 One Biscayne Tower Miami, FL 33131-2483 305-808-1789 Email: nora.curtin@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bruce A. Inosencio, Jr. Bruce A Inosencio Jr PLLC 740 W Michigan Avenue PO Box 4033 Jackson, MI 49204-4033 517-796-1444 Fax: 796-1050 Email: bruce@inosencio.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Chalon Tamara Allen Buchanan Ingersoll & Rooney, PC Bank of America Tower 100 SE 2nd Street, 34th Floor Miami, FL 33131-2158 305-347-5924 Fax: 305-347-4089 Email: chalon.allen@bipc.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Mark J. Neuberger Foley & Lardner LLP 100 SE 2nd Street Suite 1600 Miami, FL 33131-2320 305-482-8400 Fax: 305-482-8600 Email: MNeuberger@foley.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
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Date Filed 06/30/2006 06/30/2006 07/21/2006
07/21/2006 09/15/2006 09/15/2006 09/15/2006 10/05/2006
10/13/2006
10/20/2006 10/23/2006
10/30/2006 11/03/2006
11/03/2006 11/07/2006 11/07/2006

#

Docket Text

1 COMPLAINT filed; Magistrate Judge Theodore Klein (vp, Deputy Clerk) (Entered: 07/05/2006)
2 SUMMONS(ES) issued for Applegate USA, Inc. (vp, Deputy Clerk) (Entered: 07/05/2006)
3 Pursuant to Administrative Order 2006-18, this case is temporarily reassigned to Magistrate Judge Edwin G. Torres ( Signed by Judge William J. Zloch on 07/21/06) [EOD Date: 7/27/06] (mg, Deputy Clerk) (Entered: 07/27/2006)
Magistrate identification: Magistrate Judge Edwin G. Torres (mg, Deputy Clerk) (Entered: 07/27/2006)
4 ANSWER to Complaint by Applegate USA, Inc. (Attorney Mark J. Neuberger) (nt, Deputy Clerk) (Entered: 09/18/2006)
5 MOTION by Applegate USA, Inc. for Bruce A. Inosencio, Jr. to appear pro hac vice (nt, Deputy Clerk) (Entered: 09/18/2006)
Pro Hac Vice Fee Paid; FILING FEE $ 75.00 RECEIPT # 947062 (nt, Deputy Clerk) (Entered: 09/18/2006)
6 ORDER denying [5-1] motion for Bruce A. Inosencio, Jr. to appear pro hac vice ( Signed by Judge Adalberto Jordan on 10/05/06) [EOD Date: 10/5/06] (bs, Deputy Clerk) (Entered: 10/05/2006)
7 MOTION for Bruce A. Inosencio, Jr. to Appear Pro Hac Vice Renewed Motion Filing Fee $75, Receipt #100947062 by Applegate USA, Inc.. (Neuberger, Mark) (Entered: 10/13/2006)
8 ORDER re joint scheduling report as required by Local Rule 16.1 . Signed by Judge Adalberto Jordan on 10/19/06. (ep) (Entered: 10/20/2006)
10 ORDER granting 7 MOTION for Bruce A. Inosencio, Jr. to Appear Pro Hac Vice Renewed Motion Filing Fee $75, Receipt #100947062 filed by Applegate USA, Inc. . Signed by Judge Adalberto Jordan on 10/23/06. (hd) (Entered: 11/03/2006)
9 ORDER granting 7 Motion to Appear Pro Hac Vice . Signed by Judge Adalberto Jordan on 10/30/2006. (bs) (Entered: 10/31/2006)
11 NOTICE of Attorney Appearance by Michael Wells on behalf of United States Equal Employment Opportunity Commission (Wells, Michael) (Entered: 11/03/2006)
12 REPORT of Rule 26(f) Planning Meeting. (Attachments: # 1 Scheduling Order)(Wells, Michael) (Entered: 11/03/2006)
13 DISCOVERY procedure order for Magistrate Judge Edwin Torres. Signed by Judge Adalberto Jordan on 11/7/06. (ls) (Entered: 11/08/2006)
14 ORDER SETTING SCHEDULE, REFFERING CERTAIN MOTIONS TO MAGISTRATE JUDGE EDWIN TORRES and REFERRING CASE to Mediation. 15 days to appoint mediator. Discovery due by 4/30/2007. Pretrial

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12/06/2006 12/07/2006 12/11/2006 01/05/2007 01/05/2007 01/05/2007 02/05/2007 02/08/2007
03/30/2007 04/04/2007 04/05/2007 04/12/2007
04/13/2007

Motions [except motions in limine] due by 5/30/2007. Calendar Call set for 7/31/2007 09:00 AM in Miami Division before Judge Adalberto Jordan. Jury Trial set for 8/6/2007 09:00 AM in Miami Division before Judge Adalberto Jordan. Signed by Judge Adalberto Jordan on 11/7/06. (ls) (Entered: 11/08/2006)
15 NOTICE by United States Equal Employment Opportunity Commission PARTIES' ELECTION RE: JURISDICTION BY MAGISTRATE JUDGE (Wells, Michael) (Entered: 12/06/2006)
16 NOTICE by United States Equal Employment Opportunity Commission NOTICE OF SCHEDULED MEDIATION (Attachments: # 1 Text of Proposed Order)(Wells, Michael) (Entered: 12/07/2006)
17 ORDER Scheduling Mediation on 3/28/07 at 1:00pm. Mediator: John W. Salmon Signed by Judge Adalberto Jordan on 12/11/06. (lk) (Entered: 12/11/2006)
18 Notice of Mediation Hearing onMarch 28, 2007 before Mediator, John W. Salmonfiled by John W. Salmon.(Salmon, John) (Entered: 01/05/2007)
19 NOTICE of Striking 18 Notice of Mediation Hearing filed by John W. Salmon, Wrong pleading was attached by John W. Salmon (Salmon, John) (Entered: 01/05/2007)
20 Notice of Mediation Hearing onMarch 28, 2007 before Mediator, John W. Salmonfiled by John W. Salmon.(Salmon, John) (Entered: 01/05/2007)
21 Unopposed MOTION to Substitute Attorney by United States Equal Employment Opportunity Commission. Responses due by 2/20/2007 (Boehringer, Maria) (Entered: 02/05/2007)
22 ORDER granting 21 Motion to Substitute Attorney. Added attorney Nora E. Curtin for United States Equal Employment Opportunity Commission. Attorney Lauren Gayle Dreilinger terminated Signed by Judge Adalberto Jordan on 2/8/07 (lk) (Entered: 02/08/2007)
23 REPORT of Mediation Disposition: Impasse(Salmon, John) (Entered: 03/30/2007)
24 Defendant's MOTION for Extension of Time to File Extend Discovery Deadline by Applegate USA, Inc.. (Allen, Chalon) (Entered: 04/04/2007)
25 RESPONSE in Opposition re 24 Defendant's MOTION for Extension of Time to File Extend Discovery Deadline filed by United States Equal Employment Opportunity Commission. (Boehringer, Maria) (Entered: 04/05/2007)
26 REPLY to Response to Motion re 24 Defendant's MOTION for Extension of Time to File Extend Discovery Deadline filed by Applegate USA, Inc.. (Attachments: # 1 Exhibit A-Case Docket Sheet# 2 Exhibit B-Letter# 3 Exhibit C-Depo Notices)(Allen, Chalon) (Entered: 04/12/2007)
27 ORDER granting 24 Motion for Extension of discovery deadline up to 5/14/07. The parties shall have until 6/14/07 to file any pretrial motions.Signed by Judge Adalberto Jordan on 4/13/07. (lk) (Entered: 04/13/2007)

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05/14/2007
05/15/2007 05/29/2007 05/30/2007
06/04/2007 06/26/2007 06/27/2007 07/03/2007 07/05/2007

28 Defendant's MOTION to Compel Inspection of the Computer Hard Drive of Jessica Hernandez by Applegate USA, Inc.. Responses due by 5/29/2007 (Attachments: # 1 Exhibit "A" - Applegate's Request for Access to Electronic Documents and Electronic Data# 2 Exhibit "B" - EEOC's Response to Applegate's Request for Access to Electronic Documents and Electronic Data# 3 Exhibit "C" - Excerpts of Deposition Transcript of Jessica Hernandez# 4 Exhibit "D" - Excerpts of the Deposition Transcript of Steven Tucker# 5 Exhibit "E" EEOC's Response to Applegate's First Request for Production# 6 Exhibit "F" Unpublished Opinion in Phoenix Four, Inc. v. Strategic Resources, Corp., Case No. 05 Civ 4837 (HB), 2006 WL 1409413 (S.D.N.Y May 23, 2006))(Allen, Chalon) (Entered: 05/14/2007)
Judge Edwin G. Torres added as per 14. (EGT) (Entered: 05/15/2007)
29 RESPONSE in Opposition re 28 Defendant's MOTION to Compel Inspection of the Computer Hard Drive of Jessica Hernandez filed by United States Equal Employment Opportunity Commission. (Boehringer, Maria) (Entered: 05/29/2007)
30 NOTICE by United States Equal Employment Opportunity Commission re 29 Response in Opposition to Motion of Filing Exhibits/Attachments (Attachments: # 1 Exhibit 1 Deposition of J. Hernandez, V1 (pp. 1-49)# 2 Exhibit 1 Deposition of J. Hernandez, V2 (pp. 50-109)# 3 Exhibit 1 Deposition of J. Hernandez, V3 (pp. 110-169)# 4 Exhibit 2 Defendant's Response to EEOC's Request for Production# 5 Exhibit 2A Defendant's Employee Counts 2005# 6 Exhibit 3 Excerpt of Defendant's Interrogatory Answers# 7 Exhibit 4 Defendant's Rule 34 Request (re: Computer)# 8 Exhibit 5 Composite Exhibit of E-mail# 9 Exhibit 6 Affidavit of J. Chavez)(Boehringer, Maria) (Entered: 05/30/2007)
31 REPLY to Response to Motion re 28 Defendant's MOTION to Compel Inspection of the Computer Hard Drive of Jessica Hernandez filed by Applegate USA, Inc.. (Attachments: # 1 Exhibit Court's 4/13/06 Order# 2 Exhibit #2, Plaintiff's Response Obj to Def Mot Compel# 3 Exhibit #3, Email exchange# 4 Exhibit #4, Notice of Filing of Def Mot Compel Inspection# 5 Exhibit #5, 11/7/06 Court Order)(Allen, Chalon) (Entered: 06/04/2007)
32 ORDER Jury Trial set for 8/6/2007 in Miami Division before Judge Adalberto Jordan. Stipulation of dismissal Deadline by 7/6/2007. Pretrial Stipulation due by 6/27/2007.Signed by Judge Adalberto Jordan on 6/25/07.(lk) (Entered: 06/26/2007)
33 STIPULATION of Dismissal by United States Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit A (Consent Decree))(Boehringer, Maria) (Entered: 06/27/2007)
34 FINAL ORDER DISMISSING CASE with prejudice. All pending motions are DENIED AS MOOT. This case is CLOSED.Signed by Judge Adalberto Jordan on 7/3/07.(lk) (Entered: 07/03/2007)
35 Plaintiff's MOTION for Execution of Consent Decree by United States Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit A (Consent Decree))(Boehringer, Maria) (Entered: 07/05/2007)

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07/09/2007 07/10/2007

36 ORDER granting 35 Motion for approval of Consent Decree; Signed by Judge Adalberto Jordan on 07/06/2007. (bs) (Entered: 07/09/2007)
37 ORDER GRANTING 35 Plaintiff's MOTION for Execution of Consent Decree filed by United States Equal Employment Opportunity Commission, Signed by Judge Adalberto Jordan on 7/9/07.(lk) (Entered: 07/10/2007)

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