IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
CLARA BARTON HOSPITAL ASSOCIATION, INC.,
Defendant.

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CIVIL ACTION NO. 03-1107-MLB

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COMPLAINT

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JURY TRIAL DEMAND

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NATURE OF THE ACTION

This is an action under Title VII of the Civil Rights Act of 1964 to correct

unlawful employment practices on the basis of sex, and to provide appropriate relief to Nita

Brack, who was adversely affected by such practices. The Equal Employment Opportunity

Commission alleges that the Clara Barton Hospital Association, Inc.'s hospital administrator,

who is male, sexually harassed Ms. Brack and subjected her to a sexually hostile working

environment. The Commission also alleges that Defendant retaliated against Ms. Brack for

complaining about the sexual harassment by placing her on probation, demoting her and

terminating her.

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 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").

2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the District of Kansas .
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), 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(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Clara Barton Hospital Association, Inc. ("Defendant"), has continuously been a Kansas not for profit corporation doing business in the State of Kansas and the City of Hoisington, 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. §§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Nita Brack 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 April 1, 2000, Defendant has engaged in the following unlawful employment practices at its facility in Hoisington, Kansas, in violation of Sections 703 and 704 of Title VII, 42 U.S.C. §§ 2000e-2 and 3. (a) Defendant subjected Nita Brack to sexual harassment during her employment. Defendant's hospital administrator, male, sexually harassed Ms.
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Brack and subjected her to a sexually hostile working environment. The unlawful conduct was unwelcome, sexual in nature, and directed at Ms. Brack because of her sex. The unlawful conduct was sufficiently severe or pervasive to create a hostile working environment which altered the terms or conditions of Ms. Brack's employment. (b) Defendant retaliated against Ms. Brack for complaining about sexually harassing conduct by placing her on probation, then demoting her and later terminating her employment. 8. The effect of the practices complained of in paragraph 7 above has been to deprive Nita Brack of equal employment opportunities and otherwise adversely affect her status as an employee , because of her sex and because of retaliation. 9. The unlawful employment practices complained of in paragraph 7 above were intentional. 10. The unlawful employment practices complained of in paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Nita Brack
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 and any other employment practice which discriminates on the basis of sex or which constitutes retaliation.
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B. Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for women and which eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant to make whole Nita Brack, 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, including but not limited to rightful place reinstatement of Nita Brack
D. Order Defendant to make whole , by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including , in amounts to be determined at trial.
E. Order Defendant to make whole Nita Brack by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including pain and suffering, loss of enjoyment of life, damage to reputation, and humiliation, in amounts to be determined at trial.
F. Order Defendant to pay punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
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.
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Respectfully submitted, GWENDOLYN YOUNG REAMS Associate General Counsel ROBERT G. JOHNSON Regional Attorney BARBARA A. SEELY Supervisory Trial Attorney
s/ Andrea Taylor ANDREA TAYLOR KS Bar 70422 Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Kansas City Area Office Gateway Tower II 4th and State Ave., 9th Floor Kansas City, KS 66101 (913) 551-5844
REQUEST FOR PLACE OF TRIAL Plaintiff requests trial of the above case to be held in Wichita, Kansas.
s/ Andrea Taylor ANDREA TAYLOR KS Bar 70422 Senior Trial Attorney
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 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
CLARA BARTON HOSPITAL ASSOCIATION, INC.,
Defendant,

)

)

)

)

CIVIL ACTION

)

CASE NO. 03-1107-MLB

)

)

)

)

)

)

CONSENT DECREE

Introduction

Plaintiff Equal Employment Opportunity Commission (hereinafter the "Commission") has

instituted this action alleging that Clara Barton Hospital Association, Inc. (hereinafter "Defendant")

discriminated against Nita Brack in violation of Title VII of the Civil Rights Act of l964 (hereinafter

"Title VII") by sexually harassing her and retaliating against her when she complained.

For purposes of settlement and compromise only, the parties have advised the Court that they

wish to resolve the instant controversy without the expense, delay, and burden of further litigation;

THEREFORE, it is the finding of this Court, made on the pleadings and on the record as a

whole and upon agreement of the parties, that: (i) this Court has jurisdiction over the parties to and the

subject matter of this action, (ii) the requirements of Title VII will be carried out by the implementation

of this Decree, (iii) this Decree is intended to and does resolve all matters in

controversy in this lawsuit among the parties, and (iv) the terms of this Decree constitute a fair and

equitable settlement of all issues in this lawsuit.

IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED as follows: I. General Provisions
1. This Decree, being entered with the consent of the parties for purposes of settlement, shall not constitute an adjudication on the merits of this lawsuit and shall not be construed as an admission by Defendant of any violation of Title VII or any executive order, law, rule or regulation dealing with or in connection with retaliation and/or sex discrimination in employment.
2. Defendant shall not discriminate against its employees with respect to hiring, promotion, firing, compensation, scheduling or other terms, conditions or privileges of employment on the basis of sex.
3. Defendant shall not discriminate or retaliate against any person because he or she: (a) has opposed any practices alleged in this lawsuit as unlawful under Title VII, (b) has participated in any investigation conducted under Title VII connected with or leading up to this lawsuit; (c) has participated in this lawsuit; or (d) has benefitted or will benefit in any way as a result of this Consent Decree.
II. Relief for Charging Party 4. Within thirty (30) days of the entry of this decree, Defendant shall forward to Nita Brack:
a. A check for back pay in the amount of $1,224.89, less any deductions for the employee's portion of FICA and applicable federal and state income tax withholdings;
bc. A check in the amount of $42,275.11 for her disputed claims of emotional distress; and 2

c. A statement itemizing the deductions made from the back pay. 5. Defendant shall forward copies of the checks with the statement of deductions, referenced in paragraph 4 above, to the Regional Attorney, Equal Employment Opportunity Commission, 1222 Spruce, Room 8.100, St. Louis, Missouri 63103. 6. Within thirty (30) days of the entry of this Decree, Defendant shall place a copy of the Decree in Nita Brack's personnel file. If Defendant receives a request for an employment reference on Nita Brack, it shall respond only by providing her dates of employment and positions held. Within thirty (30) days of the entry of this Decree, Nita Brack may submit to Defendant a letter of resignation effective March 12, 2001, which will be made a part of her personnel file.
III. Training 7. Within sixty (60) days after the entry of this Decree, Defendant shall provide mandatory EEO training for all of its Board members, managers, supervisors and employees. The content of this training shall include sexual harassment, sex discrimination, and retaliation under Title VII of the Civil Rights Act. The training will be provided by an outside contractor of Defendant's choosing who will submit its training materials for approval by the Regional Attorney of the EEOC's St. Louis District Office. 8. Within thirty (30) days of providing any EEO training pursuant to paragraph 7, Defendant shall send to the EEOC's Regional Attorney in its St. Louis Office a report listing the names and job titles of all employees who completed the training.
IV. Posting and Policies 9. Defendant shall post and cause to remain posted copies of the notice attached hereto as
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Exhibit A in locations publicly visible to all employees for a period of two (2) years starting from the date of entry of this Decree.
10. Within sixty (60) days of the entry of this Decree, Defendant shall cause the policy attached hereto as Exhibit B to be signed by Defendant's Chief Executive Officer. Exhibit B shall be made a part of the training referred to in Paragraph 7 above and shall be made a part of Defendant's Employee Handbook within nine (9) months of the entry of this Decree.
V. Reporting, Record-keeping, and Access 11. Within seventy-five (75) days of the entry of this Decree, Defendant shall prepare and submit to the EEOC's Regional Attorney in its St. Louis District Office a letter indicating as follows:
a. That Exhibit A has been posted as required by Paragraph 9, above; b. That the training required by Paragraph 7 above has been completed; and c. That Exhibit B has been signed as required by Paragraph 10 above. 12. Within six (6) months of the date of entry of this Decree and every 6 months thereafter for the duration of this decree, Defendant shall prepare and submit to the EEOC's Regional Attorney in its St. Louis Office, a report listing the names of all persons who complained about sexual harassment, a description of the complaint and a description of all actions taken to investigate the complaint and any remedial action taken as a result of the complaint. 13. During the term of this Decree, Defendant shall allow representatives of the Commission to review Defendant's compliance with this Decree by inspecting and photocopying relevant documents and records, interviewing employees and management officials on their premises, and inspecting their premises. Such review of compliance shall be initiated by written notice to the
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Defendant's attorney of record at least three (3) business days in advance of any inspection of a Defendant's documents or premises.
VI. Term and Effect of Decree 14. By entering into this Decree, the parties do not intend to resolve any charges of discrimination currently pending before the Commission other than the charge that created the procedural foundation for the complaint in this case. 15 This Decree shall be binding upon the parties hereto, their successors and assigns. Defendants shall affirmatively notify any purchasers of the obligations of this Consent Decree prior to any sale which may take place. 16. The Court shall retain jurisdiction of this cause for purposes of compliance and enforcement. 17. Each party shall bear its own costs.

DATE: 2/4/04

s/Monti Belot UNITED STATES DISTRICT JUDGE

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BY CONSENT: FOR DEFENDANT:

FOR PLAINTIFF:

/s/ Kimberly A. Jones KIMBERLY A. JONES KS Bar #16684 Blackwell Sanders Peper Martin 2300 Main St., Ste. 1000 Kansas City, MO 64108 (816) 983-8000 (816) 983-8080 (Fax)

ROBERT G. JOHNSON Regional Attorney
/s/ Barbara A. Seely BARBARA A. SEELY Equal Employment Opportunity Commission 1222 Spruce St., Room 8.100 St. Louis, MO 63103 (314) 539-7916 (314) 539-7895 (Fax)

/s/ Andrea G. Baran ANDREA G. BARAN KS Bar #18988 Equal Employment Opportunity Commission Gateway Tower II, 9th Floor 4th and State Ave. Kansas City, KS 66101 (913) 551-5848 (913) 551-6957 (Fax)

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EXHIBIT A
(On Hospital letterhead)
NOTICE TO EMPLOYEES
Federal law prohibits discrimination against any employee or applicant for employment because of that individual's sex with respect to hiring, promotion, firing, compensation, or other terms, conditions or privileges of employment. It also prohibits retaliation against employees because they have opposed practices they believe discriminate on the basis of sex or because they have filed charges with the EEOC or participated in or cooperated with an EEOC investigation. Clara Barton Hospital and its administration are committed to complying with such Federal law in all respects and will not take any action against employees because they have exercised their rights under the law.
Employees should feel free to report instances of prohibited discrimination to any management official at any time. Clara Barton Hospital has established policies and procedures to promptly investigate any such reports and to protect the person making the reports from retaliation by the person allegedly guilty of the discriminatory treatment. Employees are also free to make complaints about employment discrimination to the United States Equal Employment Opportunity Commission, at 1222 Spruce St., Room 8.100, St. Louis, MO 63103 (Attention: Robert Johnson, Regional Attorney) or by telephone at (314) 539-7910.

Date

Chief Executive Officer

EXHIBIT B SEXUAL HARASSMENT POLICY
To be supplied by Defendant

Date

Chief Executive Officer

 
 District of Kansas - Docket Report

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CLOSED, DISC, MEDIATION, PROTO
U.S. District Court District of Kansas (Wichita) CIVIL DOCKET FOR CASE #: 6:03-cv-01107-MLB

Equal Employment Opportunity Commission v. Clara Barton Hospital Association, Inc. Assigned to: District Judge Monti L Belot Referred to: Magistrate Judge Karen M. Humphreys Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 03/27/2003 Date Terminated: 02/04/2004 Jury Demand: None Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Andrea G. Baran U. S. Equal Empoyment Opportunity Commission - KCK 400 State Ave Kansas City, KS 66101 913-551-5848 Fax: 913-551-6957 Email: andrea.baran@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Andrea L. Taylor Office of United States Attorney -- Kansas City 500 State Avenue, Suite 360 Kansas City, KS 66101 913-551-6730 Fax: 913-551-6541 Email: andrea.taylor@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Barbara A. Seely Equal Employment Opportunity Commission- St Louis Robert A. Young Federal Bldg. 1222 Spruce - Room 8.100 St. Louis, MO 63103 314-539-7916 Fax: 314-539-7895 Email: barbara.seely@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert G Johnson Equal Employment Opportunity

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V. Defendant Clara Barton Hospital Association, Inc.

Commission- St Louis Robert A. Young Federal Bldg. 1222 Spruce - Room 8.100 St. Louis, MO 63103 314-539-7910 Fax: 314-539-7895 Email: robert.johnson@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Kimberly A. Jones Blackwell Sanders Peper Martin LLP- KC 4801 Main Street - Ste. 1000 P. O. Box 219777 Kansas City, MO 64112 816-983-8000 Fax: 816-983-8080 Email: kjones@blackwellsanders.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sarah Acosta Horn, Aylward & Bandy LLC 2600 Grand Avenue, Suite 500 Kansas City, MO 64108 816-421-0700 Fax: 816-421-0899 Email: sacosta@hab-law.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Chari J. Young Seyferth Knittig & Blumenthal LLC 300 Wyandotte - Ste. 430 Kansas City, MO 64105 816-756-0700 Fax: 816-576-3700 TERMINATED: 08/06/2003

Date Filed 03/27/2003

#

Docket Text

1 COMPLAINT with trial location of Wichita, KS, and jury demand filed by Plaintiff Equal Employment Opportunity Commission.(bs) (Entered: 03/28/2003)

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03/31/2003
03/31/2003
04/03/2003 04/03/2003 05/13/2003 05/13/2003 05/15/2003 05/15/2003 05/19/2003 06/06/2003 06/25/2003
07/08/2003 07/23/2003
08/01/2003

2 MOTION for attorney Barbara A. Seely to appear pro hac vice by Plaintiff Equal Employment Opportunity Commission (Attachments: # 1 Affidavit in Support of Motion for Leave to Appear Pro Hac Vice)(Taylor, Andrea) (Entered: 03/31/2003)
3 MOTION for attorney Robert G. Johnson to appear pro hac vice by Plaintiff Equal Employment Opportunity Commission (Attachments: # 1 Affidavit in Support of Motion for Leave to Appear Pro Hac Vice)(Taylor, Andrea) (Entered: 03/31/2003)
4 ORDER granting 2 Motion to Appear Pro Hac Vice by Barbara A Seely for Equal Employment Opportunity Commission . Signed by Judge Karen M. Humphreys on 4/3/03. (cs) (Entered: 04/04/2003)
5 ORDER granting 3 Motion to Appear Pro Hac Vice by Robert G Johnson for Equal Employment Opportunity Commission . Signed by Judge Karen M. Humphreys on 4/3/03. (cs) (Entered: 04/04/2003)
6 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Clara Barton Hospital Association, Inc. waiver sent on 4/8/2003, answer due 6/9/2003. (Taylor, Andrea) (Entered: 05/13/2003)
10 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Clara Barton Hospital Association, Inc. waiver sent on 4/8/2003, answer due 6/9/2003. (cs) (Entered: 05/29/2003)
7 MOTION to Strike 6 Waiver of Service Executed by Plaintiff Equal Employment Opportunity Commission (Taylor, Andrea) (Entered: 05/15/2003)
8 ENTRY OF APPEARANCE by Andrea G. Baran on behalf of Equal Employment Opportunity Commission. (Baran, Andrea) (Entered: 05/15/2003)
9 ORDER TO STRIKE granting 7 Motion to Strike Defective Pleading. The Clerk's Office is directed to refile the document. Signed by Magistrate Judge Karen M. Humphreys on 5/19/03. (sj) (Entered: 05/19/2003)
11 Defendant Clara Barton Hospital Association, Inc.'s ANSWER to Complaint by Clara Barton Hospital Association, Inc..(Young, Chari) (Entered: 06/06/2003)
12 INITIAL ORDER REGARDING PLANNING AND SCHEDULING: telephone scheduling conference set for 7/31/2003 at 11:00 a.m. before Magistrate Judge Karen M. Humphreys. Signed by Magistrate Judge Karen M. Humphreys on 6/24/03. (sj) (Entered: 06/25/2003)
13 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission. (Baran, Andrea) (Entered: 07/08/2003)
14 CERTIFICATE OF SERVICE by Clara Barton Hospital Association, Inc. (of Defendant Clara Barton Hospital Association, Inc.'s First Interrogatories and First Request for Production of Documents to Plaintiff). (Young, Chari) (Entered: 07/23/2003)
15 SCHEDULING ORDER: discovery deadline 2/16/2004; dispositive motion deadline set for 3/15/2004; status conference set for 12/4/2003 at 11:00 a.m. before Magistrate Judge Karen M. Humphreys; final pretrial conference set for

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08/01/2003 08/01/2003 08/05/2003 08/05/2003 08/06/2003
08/06/2003 08/06/2003
08/11/2003 08/12/2003
08/13/2003 08/14/2003
08/25/2003

3/1/2004 at 01:30 p.m. before District Judge Monti L. Belot; proposed pretrial order due by 2/23/2004. Signed by Magistrate Judge Karen M. Humphreys on 7/31/03. (sj) (Entered: 08/01/2003)
Minute Entry for proceedings held before Magistrate Judge Karen M. Humphreys: Scheduling Conference held on 7/29/2003. This is a text entry only -- no document is associated with this transaction. (sj) (Entered: 08/01/2003)
16 CERTIFICATE OF SERVICE by Clara Barton Hospital Association, Inc. (of Defendant's Initial Disclosures Pursuant to Fed.R.Civ.P. 26 and Defendant's Log of Privileged Documents). (Young, Chari) (Entered: 08/01/2003)
17 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission. (Baran, Andrea) (Entered: 08/05/2003)
18 MOTION for Protective Order by Defendant Clara Barton Hospital Association, Inc. (Attachments: # 1 Exhibit proposed Protective Order# 2 Affidavit)(Jones, Kimberly) (Entered: 08/05/2003)
19 MOTION to Withdraw as Attorney and Entry of Appearance of Substituted Counsel by Defendant Clara Barton Hospital Association, Inc. (Young, Chari) Modified on 8/7/2003; FILED INCORRECTLY; SEE CORRECTING ENTRY 21 (cs). (Entered: 08/06/2003)
20 PROTECTIVE ORDER granting 18 Motion for Protective Order. Signed by Magistrate Judge Karen M. Humphreys on 8/6/03. (vs) (Entered: 08/07/2003)
21 NOTICE OF WITHDRAWAL by Chari J. Young and ENTRY OF APPEARANCE by Sarah McLean for Clara Barton Hospital Association, Inc (originally filed incorrectly as a motion (DE 19) - THIS IS A CORRECTING ENTRY) (cs) (Entered: 08/07/2003)
22 MOTION for extension of time to Respond to Plaintiff's First Request for Production of Documents and First Interrogatories by Defendant Clara Barton Hospital Association, Inc. (McLean, Sarah) (Entered: 08/11/2003)
23 ORDER granting 22 Defendant's unopposed Motion for Extension of Time to Respond to Plaintiff's First Request for Production of Documents and First Interrogatories; responses due 8/25/2003. Signed by Magistrate Judge Karen M. Humphreys on 8/11/03. (sj) (Entered: 08/12/2003)
24 Unopposed MOTION for extension of time by Plaintiff Equal Employment Opportunity Commission (Baran, Andrea) (Entered: 08/13/2003)
25 ORDER granting 24 Plaintiff's Unopposed Motion for Extension of Time to Respond to Defendant's First Request for Production of Documents and First Interrogatories. Responses due 9/8/2003. Signed by Magistrate Judge Karen M. Humphreys on 8/13/03. (sj) (Entered: 08/14/2003)
26 CERTIFICATE OF SERVICE by Clara Barton Hospital Association, Inc. (Defendant's Objections and Responses to Plaintiff's First Interrogatories and First Request for Production of Documents). (McLean, Sarah) (Entered: 08/25/2003)

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09/10/2003 09/10/2003 09/10/2003 09/10/2003 10/07/2003 10/08/2003
10/08/2003 10/09/2003 12/04/2003
02/04/2004 02/05/2004

27 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for answers to Def 1st interrogatories. (Baran, Andrea) (Entered: 09/10/2003)
28 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for privilege log. (Baran, Andrea) (Entered: 09/10/2003)
29 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for responses to Defendant's 1st Request For Production of Documents. (Baran, Andrea) (Entered: 09/10/2003)
30 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for sworn signature. (Baran, Andrea) (Entered: 09/10/2003)
31 Joint MOTION for extension of time to conduct mediation by Plaintiff Equal Employment Opportunity Commission (Baran, Andrea) (Entered: 10/07/2003)
32 ORDER granting 31 Joint Motion for Leave to Mediate Case Out of Time. The parties may conduct mediation on 11/4/2003. Signed by Magistrate Judge Karen M. Humphreys on 10/8/03. (sj) Modified on 10/9/2003 to correct typo (cs). (Entered: 10/08/2003)
33 CERTIFICATE OF SERVICE by Clara Barton Hospital Association, Inc. 's Amended Log of Privileged Documents Pursuant to Rule 26(b)(5). (McLean, Sarah) (Entered: 10/08/2003)
34 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission Barbara Seely (Baran, Andrea) (Entered: 10/09/2003)
Minute Entry for proceedings held before Magistrate Judge Karen M. Humphreys: Status Conference held on 12/4/2003. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry) (vs) (Entered: 12/04/2003)
35 CONSENT DECREE Signed by Judge Monti L Belot on 2/4/04. (cl) (Entered: 02/04/2004)
RETURN e-mail received re 35 Consent Judgment addressed to Sarah McLean; attorney no longer with Blackwell, Sanders, Peper & Martin as of December; message not remailed; this is a text only entry (cs) (Entered: 02/05/2004)

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