Case 2:05-cv-02182-KS-MTP Document 1-1 Filed 12/14/2005 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI

HATTIESBURG DIVISION

DEC 1 ~ 2005

EQUAL EMPLOYMENT OPPORTUNITY

1

COMMISSION,

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BY

Plaintiff,

J J

CIVIL ACTION# oL 'tf15CI/o2/f,Jj(J-J"~

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vs.

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COMPLAINT

JA & P RESTAURANTS, INC.

1 JURY TRIAL DEMAND
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dba CRECHALE'S RESTAURANT

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Defendant.

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1

NATURE OF THE ACTION

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 correct tmlawful employment practices on the basis of sex and to provide

appropriate relief to Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and

Stephanie Usry and a class of women who were adversely affected by such practices. As alleged

with greater particularity in paragraph 7 below, the Defendant Employer discriminated against

Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class

ofwomen on the basis of their sex by subjecting them to sexual harassment.

JURISDICTION AND VENUE

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

1343 and 1345. This action is authorized and instituted pursuant to Sections 706(f)(l) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(l) and (3) ("Title

VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.

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2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Southern District of Mississippi Hattiesburg Division.
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)(l) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(l) and (3). 4. At all relevant times, Defendant, JA & P Restaurants, Inc. dba Crechale's Restaurant (the "Employer"), has continuously been a Mississippi corporation doing business in the State of Mississippi and the City of Hattiesburg, and has continuously had at least 15 employees. 5. At all relevant times, Defendant Employer 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, Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry filed charges with the Commission alleging violations of Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since before the beginning of April, 2004, and continuing thereafter Defendant Employer engaged in unlawful employment practices at its Hattiesburg, Mississippi facility, in violation of Section 703(a)(l) and Section 704(a) of Title VII, 42 U.S.C. § 2000e-2(a)(l)and §

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2000e-3(a). In particular, the Defendant Employer engaged in unlawful employment practices at and around its facility in Hattiesburg, Mississippi, through the actions of one its supervisors, Restaurant Manager Nick Crechale. Since at least the beginning of April, 2004 and continuing thereafter, Crechale sexually harassed Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women by subjecting them to unwelcome and offensive sexual actions, comments and, in some instances, unwelcome and inappropriate touching of their private body parts.
8. The effect of the practices complained of in paragraph 7 above has been to deprive Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women of equal employment opportunities and otherwise adversely affect their status as employees, in some instances up to and including discharge, because of their sex.
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 Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in sexual harassment and any other employment practice which discriminate on the basis ofsex.

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B. Order Defendant Employer 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 Employer to institute and carry out a complaint procedure which encourages employees to come forward with complaints regarding violations of its policies against discrimination, harassment and retaliation.
D. Order Defendant Employer to institute and carry out a training program which shall promote supervisor accountability imposing on all managers and supervisory personnel a duty to actively monitor their work areas to ensure compliance with policies on nondiscrimination and anti-retaliation; and requiring all managers and supervisors to report any incidents and/or complaints of harassment and/or retaliation of which they become aware to the department charged with handling such complaints.
E. Order Defendant Employer to make whole Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women 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.
F. Order Defendant Employer to make whole Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above in amounts to be determined at trial.
G. Order Defendant Employer to make whole Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women by

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providing compensation for past and future non-pecuniary losses resulting from the unlawful

practices complained of in paragraph 7 above, including emotional pain, suffering,

inconvenience, loss of enjoyment oflife, and humiliation, in amounts to be determined at trial.

H. Order Defendant Employer to pay Laura Quinn, Christina King, Kathleen

McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women punitive

damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be

determined at trial.

I.

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

interest.

J. Award the Commission its costs of this action.

JURY TRIAL DEMAND

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

Respectfully submitted,
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 "L'' Street, Northwest Washington, DC 20507

LINE H. MCNAIR (PA 42332)
Acting Regional Attorney

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~403/fi/0 Supervisory Trial Attorney
~~~
J. MARK GRAHAM (LA 06216) Sedior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham District Office Ridge Park Place, Suite 2000 1130 22nd Street South Birmingham, AL 35205 Telephone: (205) 212-2054 Fax: (205) 212-2041 E-mail: john.graham@eeoc.gov

 
 Case 2:05-cv-02182-KS-MTP Document 8 Filed 05/03/2006 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
HATTIESBURG DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
LAURA QUINN, CHRISTINA KING, KATHLEEN McCANN, ANDREA POWELL AND STEPHANIE USRY
Plaintiffs-Intervenors vs.
JA & P RESTAURANTS, INC. dba CRECHALES’ RESTAURANT
Defendant.

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] CIVIL ACTION #2:05CV2182KS-JMR

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JURY TRIAL DEMAND

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COMPLAINT IN INTERVENTION This is a Civil Action pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., alleging that the Defendant-Employer discriminated against Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry and a class of similarly situated women on the basis of their sex by subjecting them to sexual harassment; in the case of Stephanie Usry resulting in the termination of her employment by Defendant; and in the case of Laura Quinn, Christina King, Kathleen McCann and Andrea Powell resulting in their constructive discharge.

EXHIBIT “A”

Case 2:05-cv-02182-KS-MTP Document 8 Filed 05/03/2006 Page 2 of 6
JURISDICTION AND VENUE 1. Jurisdiction is conferred upon this Court by 42 U.S.C. Section 2000e-5, 28 U.S.C. Sections 451, 1331, 1337, 1343 and 1345. Jurisdiction is also conferred by Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981a.
PARTIES 2. Plaintiffs-Intevenors, Laura Quinn, Christina King, Kathleen McCann, Andrea Powell are adult resident citizens of the Southern District of Mississippi, Hattiesburg Division, which is also where said unlawful employment actions took place. Stephanie Usry, while an adult resident citizen of the Southern District of Mississippi, Hattiesburg Division, at the time the unlawful employment actions complained of took place, is now a non-resident of the State of Mississippi. Defendant, JA & P Restaurants, Inc. dba Crechales’ Restaurant (the “Employer”), is a Mississippi corporation doing business in the State of Mississippi and the City of Hattiesburg, and has continuously had at least fifteen (15) employees. 3. At all relevant times, Defendant-Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. Sections 2000e(b), (g) and (h).
FACTS 4. Plaintiffs-Intevenors were hired by Defendant-Employer in April and May, 2004. 5. Beginning with the hire of each Plaintiff-Intervenor, either in April, 2004 or May, 2004, and continuing thereafter Defendant-Employer engaged in unlawful employment practices at its Hattiesburg, Mississippi facility, in violation of Section 703(a)(1) and Section 704(a) of
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Title VII, 42 U.S.C. Section 2000e-2(a)(1) and Section 2000e-3(a). In particular, the DefendantEmployer engaged in unlawful employment practices at and around its facility in Hattiesburg, Mississippi through the actions of one of its supervisors, restaurant manager, Nick Crechale. Since at least the beginning of April, 2004 and continuing thereafter, Crechale sexually harassed Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry by subjecting them to unwelcome and offensive sexual actions, comments, and in some instances, unwelcome and inappropriate touching of their private body parts.
6. The effect of the practices complained of in the above and foregoing paragraph has been to deprive Laura Quinn, Christina King, Kathleen McCann, Andrea Powell, Stephanie Usry of equal employment opportunities and otherwise adversely affecting their status as employees, in some instances up to and including discharge, because of their sex.
7. The unlawful employment practice complained of in the above and foregoing paragraphs were intentional.
8. The unlawful employment practices complained of in the above and foregoing paragraphs were done with malice or reckless indifference to the federally protected rights of Laura Quinn, Christina King, Kathleen McCann, Andrea Powell and Stephanie Usry.
9. Each Plaintiff-Intervener herein filed a timely Charge of Discrimination with the Equal Employment Opportunity Commission alleging sexual harassment and discrimination based on her sex. After investigation, the Equal Employment Opportunity Commission issued its determinations regarding each Plaintiff-Intervener and found that each Plaintiff-Intervener was discriminated against in violation of Title VII of the Civil Rights Act of 1964 as amended, and
Page -3-

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further finding that each Plaintiff-Intervener was subject to sexual harassment and other forms of employment discrimination based on her gender.
CAUSES OF ACTION 10. The actions of Defendant-Employer, as a aforesaid, constitute a violation of Title VII of the Civil Rights Act of 1964 and in particular constitute discrimination based on sex and sexual harassment against Plaintiffs-Interveners, including the discharge of one or more of Plaintiffs-Interveners.
PRAYER FOR RELIEF 11. Plaintiffs-Interveners seek that the Court issue the following relief: a. Enter declaratory relief declaring that Defendant-Employer has engaged in a
pattern and practice of sexual harassment and discrimination on the basis of sex, and enjoin the Defendant-Employer from in the future engaging in such sexual harassment and discrimination on the basis of sex; b. Enter temporary and permanent injunctions restraining Defendant-Employer from engaging in sexual harassment and any other employment practice which discriminates on the basis of sex; c. Award Plaintiffs-Interveners equitable back pay with Pre-Judgment interest, in amounts to be determined at trial; d. Award Plaintiffs-Interveners past and future pecuniary losses resulting from the unlawful employment practices described hereinabove, in amounts to be determined at trial;
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e. Award Plaintiffs-Interveners for past and future non-pecuniary losses resulting from the unlawful practices described hereinabove, including emotional pain, suffering, inconvenience, loss of enjoyment of life, and humiliation, in amounts to be determined at trial;
f. Award Plaintiffs-Interveners punitive damages for Defendant-Employer’s malicious and reckless conduct as described hereinabove, in amounts to be determined at trial;
g. Award Plaintiffs-Interveners their attorney fees, costs and expenses of litigation; and
h. Award such other relief to which Plaintiffs-Interveners may be entitled under law. Respectfully submitted, this the 3rd day of May, A.D., 2006.
LAURA QUINN, CHRISTINA KING, KATHLEEN McCANN, ANDREA POWELL and STEPHANIE USRY
s/MICHAEL ADELMAN MICHAEL ADELMAN, ESQ. ADELMAN & STEEN, L.L.P. POST OFFICE BOX 368 HATTIESBURG, MS 39403-0368 PHONE: 601/544-8291 FAX: 601/544-1421 MS BAR NO.: 1153 COUNSEL FOR PLAINTIFFS-INTERVENERS
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CERTIFICATE OF SERVICE
I hereby certify that on May 3, 2006 that I electronically filed the foregoing Complaint in Intervention with the Clerk of the Court using the ECF system which sent notification of each filing to the following:
F. Douglas Montague, III, Esq. Post Office Box 1975 Hattiesburg, MS 39403-1975 J. Mark Graham, Esq. Equal Employment Opportunity Commission Ridge Park Place, Suite 2000 1130 22nd Street, South Birmingham, AL 35205 This the 3rd day of May, A.D., 2006.
s/MICHAEL ADELMAN
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 Case 2:05-cv-02182-KS-MTP Document 66 Filed 03/09/2007 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
HATTIESBURG DIVISION

EQUAL EMPLOYMENT OPPORTUNITY ]

COMMISSION,

]

]

Plaintiff,

]

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vs.

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]

JA & P RESTAURANTS, INC.

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dba CRECHALE’S RESTAURANT

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Defendant.

]

]

CIVIL ACTION # 2:05cv2182KS-JMR CONSENT DECREE

The Equal Employment Opportunity Commission (“EEOC” or “Commission”) filed this

action against JA & P Restaurants, Inc. dba Crechale’s Restaurant. (“Crechale’s” or

“Defendant”) on December 14, 2005, in this Court, to enforce Title VII of the Civil

Rights Act of 1964, 42 U.S.C. §2000e et seq. (Title VII) and the Civil Rights Act of

1991, 42 U.S.C. §1981a. In the Complaint, the Commission alleged that, in violation of

Title VII, Crechale’s discriminated against and harassed Laura Quinn, Christina King,

Kathleen McCann, Andrea Powell and Stephanie Usry (Quinn, King, McCann, Powell

and Usry) and a class of similarly situated women on the basis of their sex, female, and,

in some instances, discharged them after they complained about the discrimination.

Crechale’s denies all allegations raised in the complaint, nor does anything in this

decree constitute an admission of liability on the part of Crechale’s.

The Parties do not object to the jurisdiction of the Court over this action and

waive their rights to a hearing and the entry of findings of fact and conclusions of law.

Venue is appropriate in the Southern District of Mississippi (Hattiesburg Division). The

parties agree that this Consent Decree is fair, reasonable, and equitable and does not

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violate the law or public policy. The rights of Quinn, King, McCann, Powell and Usry, Crechale’s and the Commission are protected adequately by this Decree.
In the interest of resolving this matter, and as a result of having engaged in comprehensive settlement negotiations, the Commission and Crechale’s have agreed that this action should be finally resolved by entry of this Consent Decree.
It is ORDERED, ADJUDGED AND DECREED: 1. This Decree resolves all claims arising out of the issues between the Commission and Defendant Crechale’s in this lawsuit including, without limitation, back pay, compensatory and punitive damages, injunctive relief, costs, and attorney fees. 2. Defendant and its officers, agents, employees, successors, and assigns both at the time that this Decree becomes effective and for the duration of this Decree agree to comply with Federal law and agree not to : (a) discriminate against any employee on the basis of sex, (b) harass any employee based on sex; (c) retaliate against any employee because he or she: (i) opposes or opposed discriminatory practices made unlawful by Title VII; (ii) files or filed a charge of discrimination, or assists, assisted, participates, or participated in the filing of a charge of discrimination; or (iii) assists, assisted, participates or participated in an investigation or proceeding brought under the federal or state laws prohibiting discrimination or retaliation; and (d) alter the terms and conditions of any employee’s employment because of sex to the extent required by Federal law.
MONETARY RELIEF 3. Crechale’s shall pay, by check or money order, the total amount of Twelve thousand five hundred dollars and zero cents ($12,500.00) within thirty (30) days from the date of the entry of this Decree to Laura Quinn, Christina King, Kathleen McCann,

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Andrea Powell and Stephanie Usry. Crechale’s will not condition the receipt of individual relief on Quinn’s, King’s, McCann’s, Powell’s or Usry’s agreement to (a) maintain as confidential the terms of this Decree, or (b) waive their statutory rights to file a charge with any federal or state anti-discrimination agency. Crechale’s will issue applicable United States Internal Revenue Service Forms to Quinn, King, McCann, Powell and Usry for all such payments on or before January 31, 2007.
4. The checks or money orders provided for in paragraph 3 of this Decree shall be mailed directly by Crechale’s to the attorney for Quinn, King, McCann, Powell and Usry at the addresse supplied by him. Within three business days of the issuance of the checks, Crechale’s shall submit a copy of the checks and related correspondence to the United States Equal Employment Opportunity Commission, Regional Attorney, Birmingham District Office, 1130 22nd Street South, Suite 2000, Birmingham, Alabama, 35205-2886.
OTHER RELIEF 5. Defendant will institute and carry out policies and practices at its Mississippi restaurants that help assure a work environment free from sex-based discrimination, harassment and retaliation for its employees; that allow employees to raise concerns or complaints without retaliation about matters, whether alleged, perceived or actual, made unlawful by Title VII; and that provide procedures for employees to report incidents of sex-based discrimination, and harassment. 6. To assist Defendant in achieving and maintaining compliance in the area of anti-discrimination and equal employment opportunity, within thirty (30) days of the entry of the Decree, Defendant will designate an appropriate and qualified employee to be

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responsible for: (a) reviewing and revising Defendant’s anti-discrimination policies; (b) reviewing and revising Defendant’s procedures with respect to responding to and keeping records regarding complaints received; (c) receiving and investigating complaints of discrimination; (d) evaluating and, if appropriate, disciplining or terminating employees for violation of Defendant’s anti-discrimination policies; (e) evaluating employees in the area of anti-discrimination/equal employment opportunity policies; and (f) preparing reports to the Commission, as required by this Decree.
7. Annually for the duration of this Decree, Defendant will provide mandatory training which shall explain: (1) what constitutes sex-based discrimination, retaliation, and harassment; (2) that Title VII prohibits this misconduct; (3) how to prevent this misconduct; (4) to whom employees may complain if they feel they have been subjected to this misconduct; and (5) that managers will be evaluated on their enforcement of Crechale’s anti-discrimination policies. Training will also include an explanation of Crechale’s policies regarding sex-based discrimination, harassment and retaliation; the importance of maintaining an environment free from harassment; and the discipline that may be taken against any employee found to have harassed or retaliated against other employees and the managers or supervisors who are found to have allowed the harassment or retaliation to occur.
a. Defendant will arrange and be financially responsible for a consultant/lecturer(s), who will provide consultation and a training session for all of its employees in Mississippi. The training session(s) shall be provided by the consultant/lecturer(s). Defendant shall submit to the EEOC the name and resume of the consultant at least sixty days prior to the first training session. EEOC may advise

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Defendant in writing of any objections to the selected consultant. Defendant may videotape the session for those employees who cannot attend the live session.
b. During the live training session(s), the chief executive officer of each facility will speak to the employees about discipline that can be taken against supervisors, managers and employees who commit acts of discrimination, harassment or retaliation or allow discrimination, harassment or retaliation to occur in the workplace; the importance of maintaining an environment free of discrimination; and Defendant’s anti-discrimination policies.
c. The seminar training session shall be at least two (2) hours in length, plus an additional thirty (30) minutes for questions and answers. All of Defendant’s employees, including managers, shall register for and attend the seminar session. Employees who are unable to attend the session may watch a videotape of it.
d. Employees shall sign a registry when they attend the training or watch the videotape. Defendant shall keep, for the duration of the Decree, this written record of all employees who attend the training or watch it on video and shall forward a copy of same to the EEOC on an annual basis.
e. The first seminar training session shall be held within three (3) months of the Consent Decree being entered.
f. Crechale’s will also provide a one-hour training session, to Crechale’s managers and supervisors within six (6) months of the execution of this Agreement which shall discuss sex-based discrimination, harassment and retaliation. Crechale’s will notify the Commission when this training session has been completed.
8. Within thirty days of the entry of this Decree, Defendant will review and

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revise its written policies concerning discrimination and retaliation to conform with the law. Defendant’s written policies must include, at a minimum:
a. A clear and strong commitment to a workplace free of sex-based discrimination, harassment and retaliation;
b. A clear and strong message of encouragement to persons who believe they have been discriminated against to come forward and complain;
c. A description of the consequences, up to and including termination, that will be imposed upon violators of the policy;
d. An assurance of non-retaliation for persons who believe they have been discriminated against and for witnesses;
e. That discrimination on the basis of sex by anyone, including management officials, supervisors, vendors, suppliers, third parties and customers, is prohibited and will not be tolerated;
f. The identification of specific alternative individuals, including managers with their telephone numbers, to whom employees who have been subjected to sex-based discrimination, harassment or retaliation can report the discrimination and who have the authority to investigate allegations of discrimination in a neutral and confidential manner;
g. A written statement that an employee may report the harassment to a designated person outside of his or her chain of management should the employee prefer to do so;

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h. Assurances that Defendant will investigate allegations of sexbased discrimination, harassment and retaliation promptly, fairly, reasonably, effectively and as confidentially as possible under the circumstances, by appropriate investigators and that appropriate corrective action and appropriate follow-up will be taken by Defendant to make victims whole and to eradicate the discrimination; and
i. Information regarding the employee’s right to file a charge of discrimination with the EEOC, including contact telephone numbers, TDY/TDD and addresses for the EEOC.
9. These policies shall be posted in a prominent location, frequented by employees, at Defendant’s restaurant in Hattiesburg, Mississippi. These policies shall also be distributed to each current employee within thirty days of the entry of the Decree, and distributed to all new employees when hired.
10. Defendant shall promptly and appropriately investigate all complaints of sex-based discrimination, harassment or retaliation. The investigation must include: (1) a finding of whether discrimination occurred; (2) a credibility assessment; (3) interviews of all potential victims and witnesses identified; and (4) concurrent notes of the investigation. Defendant shall take immediate appropriate corrective action to make victims of discrimination whole, to discipline violators, and to eradicate the discrimination. Defendant shall follow up with complainants at appropriate intervals to ensure that the harassment, discrimination or retaliation does not reoccur.

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NOTICE 11. Defendant will post the Notice attached as Attachment A at Defendant’s restaurant in Hattiesburg Mississippi. The Notice will be posted in an appropriate place frequented by employees, for the duration of this Decree.
REPORTING BY DEFENDANT AND ACCESS BY EEOC 12. In addition to the reporting specified throughout the Decree above, Defendant shall report in writing and in affidavit form to the Regional Attorney of the Commission’s Birmingham District Office at 1130 22nd Street South, Suite 2000, Ridge Park Place, Birmingham, Alabama, 35205-2886, beginning six months from the date of the entry of this Decree, and thereafter every six months for the duration of the Decree confirmation that: (i) the Notice required in paragraph 12 of this Decree was posted and the location(s) where it was posted; and (ii) the policies required in paragraph 9 were distributed to each current and new employee and posted. 13. The parties shall bear their own attorneys’ fees and costs incurred in this action up to the date of entry of this Decree.
FORCE AND EFFECT 14. The duration of this Decree shall be forty-eight (48) months from its entry. This Court shall retain jurisdiction over this action for the duration of the Decree, during which the Commission may petition this Court for compliance with this Decree. Should the Court determine that defendant has not complied with this Decree, appropriate relief, including extension of this Decree for such period as may be necessary to remedy its noncompliance, may be ordered. Noncompliance which would give rise to enforcement under this provision includes, without limitation, any failure to pay the amounts due to be

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paid to Quinn, King, McCann, Powell and Usry under paragraph 3 of this Consent Decree. Absent extension, this Decree shall expire by its own terms at the end of 48 months from the date of entry, without further action by the Parties.
15. The parties agree to the entry of this Decree subject to final approval by the Court.
16. The parties agree that upon entry of this Decree, they will sign and submit a joint motion to dismiss this action, with prejudice, subject to this Decree.
ORDERED and ADJUDGED this8th day of March, 2007.
s/Keith Starrett UNITED STATES DISTRICT JUDGE APPROVED AND CONSENTED TO BY:

s/ Nick Crechale CORPORATE OFFICER JA & P Restaurants, Inc.

s/ C. Emanuel Smith C. EMANUEL SMITH (MS 7473) Regional Attorney

s/ F. Douglas Montague F. DOUGLAS MONTAGUE, III (MS 3408) MATTHEW L. DEVEREAUX (MS 101833) MONTAGUE, PITTMAN & VARNADO P. O. Box 1975 Hattiesburg, MS 39403-1975 Attorneys for JA & P Restaurants, Inc.

s/ Julie Lee JULIE LEE (DC 433292) Supervisory Trial Attorney
s/ J. Mark Graham J. MARK GRAHAM (LA 06216) Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham District Office

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1130 22ND Street South, Suite 2000 Birmingham, Alabama 35205 (205) 212-2054 Attorneys for Plaintiff

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ATTACHMENT A
NOTICE TO ALL EMPLOYEES OF JA & P RESTAURANTS, INC.
It is unlawful under federal law, Title VII of the Civil Rights Act and state law to discriminate against an employee on the basis of sex, including sexual harassment, in the recruitment, hiring, firing, compensation, assignment, or other terms, and conditions or privileges of employment. Sexual harassment includes unwelcome or offensive sexual advances or touching, requests for sexual favors, or other verbal or physical conduct directed at a person because of her/his sex. It is also unlawful to retaliate against any person because the person protested discriminatory practices or contacted the EEOC.
JA & P Restaurants, Inc. shall not discriminate against any employee on the basis of sex, including sexual harassment, and shall not retaliate against any employee for complaining about sexual discrimination or harassment.
If you believe you have been discriminated against or sexually harassed JA & P Restaurants, Inc. encourages you to report any concerns of harassment, discrimination or retaliation to any management official.
You also have a right to seek assistance from:
EEOC 1130 22ND Street South, Suite 2000 Birmingham, Alabama 35205 Telephone: (205) 212-2100 TTY: (205) 212-2112 Website (national): www.eeoc.gov; or
You have the right to file a charge with the EEOC if you believe you are being discriminated against, retaliated against or sexually harassed.
No Retaliation Clause. It is against the law for any action to be taken against you by any supervisory or management official of JA & P Restaurants, Inc. for: (1) opposing sexual harassment or other discriminatory practices made unlawful by federal or state law; (2) filing a charge or assisting or participating in the filing of a charge of discrimination; or (3) assisting or participating in an investigation or proceeding brought under Title VII. Should any such retaliatory actions be taken against you, you should immediately contact the EEOC at the addresses or telephone numbers listed above.

 
 CM/ECF LIVE - U.S. District Court: Mississippi Southern District - Doc... https://ecf.mssd.uscourts.gov/cgi-bin/DktRpt.pl?832961808862145-L_9...
CJRA-S, CLOSED, JURY, MTP
U.S. District Court Southern District of Mississippi (Hattiesburg) CIVIL DOCKET FOR CASE #: 2:05-cv-02182-KS-MTP

U.S. Equal Employment Opportunity Commission v. JA & P Restaurants Assigned to: District Judge Keith Starrett Referred to: Magistrate Judge Michael T. Parker Cause: 42:1981 Sex Discrimination

Date Filed: 12/14/2005 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
U.S. Equal Employment Opportunity Commission

represented by C. Emanuel Smith EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham Birmingham District Office Ridge Park Place, Suite 2000 1130 22nd Street South Birmingham, AL 35205-2881 205/212-2131 Fax: 205/212-2041 Email: emanuel.smith@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

J. Mark Graham EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham District Office Ridge Park Place, Suite 2000 1130 22nd Street South Birmingham, AL 35205-2881 205/212-2100 Email: john.graham@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jacqueline McNair EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham Birmingham District Office Ridge Park Place, Suite 2000 1130 22nd Street South Birmingham, AL 35205-2881 205/212-2065 TERMINATED: 04/10/2006

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V. Intervenor Plaintiff Christina King
Intervenor Plaintiff Kathleen McCann
Intervenor Plaintiff Andrea Powell

LEAD ATTORNEY
Julie Steptoe Lee EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham Birmingham District Office Ridge Park Place, Suite 2000 1130 22nd Street South Birmingham, AL 35205-2881 205/212-2076 Fax: 205/212-2105 Email: julie.lee@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Mildred Byrd U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Birmingham District Office Ridge Park Place 1130 - 22nd St., South, Ste. 2000 Birmingham, AL 30205 205/731-1297 Email: mildred.byrd@eeoc.gov TERMINATED: 12/29/2006 LEAD ATTORNEY
represented by Michael Adelman ADELMAN & STEEN, LLP P. O. Box 368 Hattiesburg, MS 39403-0368 (601) 544-8291 Email: adelst33@aol.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Michael Adelman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Michael Adelman (See above for address)

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Intervenor Plaintiff Laura Quinn
Intervenor Plaintiff Stephanie Usry
V. Defendant JA & P Restaurants Inc., d/b/a Crechales's Restaurant

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Michael Adelman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Michael Adelman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by F. Douglas Montague, III MONTAGUE, PITTMAN & VARNADO P.O. Drawer 1975 Hattiesburg, MS 39403-1975 (601) 544-1234 Fax: 6015441280 Email: dmontague@mpvlaw.com ATTORNEY TO BE NOTICED
Matthew L. Devereaux MONTAGUE, PITTMAN & VARNADO P.O. Drawer 1975 Hattiesburg, MS 39403-1975 601/544-1234 Fax: 601/544-1276 Email: mdevereaux@mpvlaw.com ATTORNEY TO BE NOTICED

Date Filed
12/14/2005 12/15/2005 03/07/2006

#

Docket Text

1 COMPLAINT against JA & P Restaurants , filed by U.S. Equal Employment Opportunity Commission. (Attachments: # 1)(ldr, ) (Entered: 12/14/2005)
Summons Issued as to JA & P Restaurants. (ldr, ) (Entered: 12/15/2005)
2 REQUEST FOR WAIVER of Service sent to Mr. Nick Crechale agent for JA & P Restaurants on 03/06/2006 by U.S. Equal Employment Opportunity Commission. Waiver of Service due by 4/5/2006. (Graham, J.) (Entered: 03/07/2006)

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03/08/2006 04/04/2006 04/05/2006 04/05/2006 04/10/2006
05/03/2006 05/03/2006 05/03/2006 05/03/2006 05/22/2006
05/23/2006 05/23/2006 05/23/2006

3 SUMMONS Returned Executed by U.S. Equal Employment Opportunity Commission as to JA & P Restaurants served on 2/10/2006, answer due 3/2/2006. (ldr, ) (Entered: 03/08/2006)
4 ANSWER to Complaint by JA & P Restaurants.(Montague, F.) (Entered: 04/04/2006)
5 MOTION to Intervene by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry. (Attachments: # 1)(Adelman, Michael) (Entered: 04/05/2006)
6 Ex Parte MOTION to Substitute Attorney by U.S. Equal Employment Opportunity Commission. (Graham, J.) (Entered: 04/05/2006)
7 ORDER granting 6 Motion to Substitute Attorney. Added attorney C. Emanuel Smith for U.S. Equal Employment Opportunity Commission. Attorney Jacqueline McNair terminated . Signed by Judge Keith Starrett on 4/6/06. (ldr, ) (Entered: 04/10/2006)
TEXT ONLY ORDER granting 5 Motion to Intervene . No further written order will issue from the Court. Signed by Judge Keith Starrett on 5/3/06. (scp, ) (Entered: 05/03/2006)
8 Intervenor COMPLAINT JA & P RESTAURANTS, filed by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 05/03/2006)
DOCKET ANNOTATION as to #8, attorney contacted, will omit "Exhibit A" from page 1 of Complaint in Intervention and re-file pleading. (ldr, ) (Entered: 05/03/2006)
9 Intervenor COMPLAINT JA & P RESTAURANTS, INC., filed by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 05/03/2006)
10 Rule 16.1(A) Initial Order: Telephonic Case Management Conference set for 6/14/2006 11:00 AM before Magistrate Judge John M. Roper in Gulfport, MS 39501. Plaintiff to initiate the telephonic conference call (228)563-1779. Confidential settlement memorandas to be submitted to Judge Roper's Chambers at 2012 15th Street, Suite 870, Gulfport, MS 39501 on or prior to 6/7/06. (Stokes, Porfi) (Entered: 05/22/2006)
11 Mail Returned as Undeliverable marked Not Deliverable As Addressed, Unable to Forward, Return to Sender. Mail sent to C. Emanuel Smith containing Order filed 4/10/06, Doc #7. (ldr, ) (Entered: 05/23/2006)
12 Mail Returned as Undeliverable marked "Not Deliverable As Addressed, Unable to Forward, Return to Sender". Mail sent to C. Emanuel Smith containing Text Only Order of 5/3/06. (ldr, ) (Entered: 05/23/2006)
DOCKET ANNOTATION as to #11,12, attorney C. Emanuel Smith was contacted, will forward change of address to Clerk's Office; returned mail and Doc #10 forwarded to Atty. Smith at Birmingham, AL address listed on pleadings. (ldr, ) (Entered: 05/23/2006)

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06/06/2006 06/14/2006 06/14/2006
06/14/2006 06/15/2006 06/23/2006 06/26/2006 06/26/2006 06/26/2006 07/21/2006 07/21/2006 07/25/2006
08/21/2006 08/21/2006 08/22/2006

13 ANSWER to Intervenor Complaint by JA & P Restaurants.(Montague, F.) (Entered: 06/06/2006)
Minute Entry for proceedings held before Judge John M. Roper in Gulfport, MS: Telephonic Case Management Conference held on 6/14/2006. (Stokes, Porfi) (Entered: 06/14/2006)
14 CASE MANAGEMENT ORDER: Case is assigned to the standard track. Parties do not consent to trial by Magistrate Judge. Final Pretrial Conference set for 4/19/2007 9:00 AM before District Judge Keith Starrett. Amended Pleadings due by 7/14/2006. Discovery due by 1/2/2007. Designate Experts Plaintiff Deadline due by 10/1/2006. Designate Experts for Defendant Deadline due by 11/1/2006. Jury Trial Calendar set for 5/7/2007-5/18/2007 at 9:00 AM in Courtroom 1 before District Judge Keith Starrett. Joinder of Parties due by 7/14/2006. Motions due by 1/15/2007. Signed by Judge John M. Roper on June 14, 2006. (Stokes, Porfi) (Entered: 06/14/2006)
15 NOTICE of Disclosure by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry (Adelman, Michael) (Entered: 06/14/2006)
16 NOTICE of Service of Disclosure by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 06/15/2006)
17 NOTICE of Service of Disclosure by JA & P Restaurants. (Attachments: # 1)(Montague, F.) (Entered: 06/23/2006)
18 NOTICE of Service of Interrogatories by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 06/26/2006)
19 NOTICE of Service of Request for Production by Christina King, Kathleen McCann, Andrea Powell, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 06/26/2006)
20 NOTICE of Service of Disclosure by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 06/26/2006)
21 NOTICE of Service of Response to Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 07/21/2006)
22 NOTICE of Service of Response to Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 07/21/2006)
23 ORDER REASSIGNING CASE. Case reassigned to Judge Michael T. Parker for all further proceedings. Judge John M. Roper no longer assigned to case. Signed by Judge Henry T. Wingate on 7/25/06. (Attachments: # 1)(ldr, ) (Entered: 07/27/2006)
24 NOTICE of Service of Interrogatories by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 08/21/2006)
25 NOTICE of Service of Request for Production by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 08/21/2006)
26 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)

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08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 08/22/2006 09/20/2006 09/20/2006 10/06/2006 10/06/2006 10/06/2006 10/06/2006 10/06/2006 10/06/2006

27 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
28 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
29 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
30 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
31 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
32 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
33 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
34 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
35 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
36 NOTICE of Service of Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
37 NOTICE of Service of Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 08/22/2006)
38 NOTICE of Service of Response to Interrogatories by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 09/20/2006)
39 NOTICE of Service of Response to Request for Production by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 09/20/2006)
40 NOTICE of Service of Response to Interrogatories by Andrea Powell.(Adelman, Michael) (Entered: 10/06/2006)
41 NOTICE of Service of Response to Interrogatories by Christina King.(Adelman, Michael) (Entered: 10/06/2006)
42 NOTICE of Service of Response to Interrogatories by Kathleen McCann.(Adelman, Michael) (Entered: 10/06/2006)
43 NOTICE of Service of Response to Interrogatories by Laura Quinn.(Adelman, Michael) (Entered: 10/06/2006)
44 NOTICE of Service of Response to Interrogatories by Stephanie Usry.(Adelman, Michael) (Entered: 10/06/2006)
45 NOTICE of Service of Response to Request for Production by Andrea Powell.(Adelman, Michael) (Entered: 10/06/2006)

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10/06/2006 10/06/2006 10/06/2006 10/06/2006 10/17/2006 10/17/2006 10/18/2006 10/18/2006 10/18/2006 11/14/2006
11/14/2006 11/15/2006 11/15/2006 11/15/2006 11/15/2006 11/15/2006

46 NOTICE of Service of Response to Request for Production by Christina King.(Adelman, Michael) (Entered: 10/06/2006)
47 NOTICE of Service of Response to Request for Production by Kathleen McCann.(Adelman, Michael) (Entered: 10/06/2006)
48 NOTICE of Service of Response to Request for Production by Laura Quinn.(Adelman, Michael) (Entered: 10/06/2006)
49 NOTICE of Service of Response to Request for Production by Stephanie Usry.(Adelman, Michael) (Entered: 10/06/2006)
50 NOTICE of Service of Response to Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 10/17/2006)
DOCKET ANNOTATION as to #50, attorney contacted to refile using docket event of Notice of Service of Disclosure. (ldr, ) (Entered: 10/17/2006)
51 NOTICE of Service of Response to Interrogatories by JA & P Restaurants.(Montague, F.) (Entered: 10/18/2006)
DOCKET ANNOTATION as to #51, attorney contacted and will docket notice for response to requests for production. (ldr, ) (Entered: 10/18/2006)
52 NOTICE of Service of Response to Request for Production by JA & P Restaurants.(Montague, F.) (Entered: 10/18/2006)
NOTICE: After confirming the availability of counsel, the court has scheduled a telephonic discovery conference for Wednesday, November 15, 2006 at 1:30 p.m. before Magistrate Judge Michael T. Parker in Hattiesburg, MS. Counsel for Intervenor Plaintiffs has agreed to initiate the conference call and shall contact Judge Parker's chambers when all parties are connected (601.544.9100). Counsel for Plaintiff, EEOC, advises the court that Emanuel Smith and/or Mildred Byrd will participate in this call and can be reached at 205.212.2131. (kpm, ) (Entered: 11/14/2006)
Set Hearings: Telephonic Discovery Conference set for 11/15/2006 1:30 PM before Magistrate Judge Michael T. Parker in Hattiesburg, MS. (kpm, ) (Entered: 11/14/2006)
53 NOTICE to Take Deposition of Christina King by JA & P Restaurants.(Montague, F.) (Entered: 11/15/2006)
54 NOTICE to Take Deposition of Kathleen McCann by JA & P Restaurants.(Montague, F.) (Entered: 11/15/2006)
55 NOTICE to Take Deposition of Andrea Powell by JA & P Restaurants.(Montague, F.) (Entered: 11/15/2006)
56 NOTICE to Take Deposition of Laura Quinn by JA & P Restaurants.(Montague, F.) (Entered: 11/15/2006)
57 NOTICE to Take Deposition of Stephanie Usry Ulrich by JA & P Restaurants.(Montague, F.) (Entered: 11/15/2006)

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11/15/2006 11/15/2006 11/15/2006
11/15/2006
11/15/2006 11/16/2006 11/16/2006 12/28/2006 12/29/2006
01/03/2007 01/08/2007 01/08/2007

Minute Entry for proceedings held before Judge Michael T. Parker : Telephone Conference held on 11/15/2006. Participating were Mildred Byrd for the plaintiff and Doug Montague for the defendant. Mike Adelman participating for the intervenor plaintiff. (Wall, Mary Helen) (Entered: 11/15/2006)
Reset Deadlines: Discovery due by 1/26/2007. Motions due by 2/12/2007. All other deadlines set forth in the Case Management Order of June 14, 2006, shall remain in place. (Wall, Mary Helen) Modified on 11/20/2006 (Wall, Mary). (Entered: 11/15/2006)
TEXT ONLY ORDER setting Settlement Conference: Settlement Conference is set for March 26, 2007, at 1:00 p.m. (courtroom 2) before Judge Mike Parker in Hattiesburg, Mississippi. Parties shall submit settlement memos to chambers on or before March 22, 2007. Each party must a have representative with full settlement authority present at conference. NO FURTHER WRITTEN ORDER WILL ISSUE FROM THIS COURT. Signed by Judge Michael T. Parker on November 15, 2006. (Wall, Mary Helen) (Entered: 11/15/2006)
Set Hearings: Settlement Conference set for 3/26/2007 1:00 PM before Magistrate Judge Michael T. Parker in Hattiesburg, MS. Parties shall submit confidential settlement memoranda to Judge Parker's chambers by 3/22/07. Parties must have representative(s) with full settlement authority present at conference. (kpm, ) (Entered: 11/15/2006)
DOCKET ANNOTATION as to #57, Notice of Deposition for Stephanie Ulrich, was not dated or signed; attorney's office contacted requesting date and signature. (ldr, ) (Entered: 11/15/2006)
58 NOTICE to Take Deposition of Stephanie Usry Ulrich by JA & P Restaurants.(Montague, F.) (Entered: 11/16/2006)
59 NOTICE to Take Deposition of Nick Crechale by Christina King, Kathleen McCann, Andrea Powell, U.S. Equal Employment Opportunity Commission, Laura Quinn, Stephanie Usry.(Adelman, Michael) (Entered: 11/16/2006)
60 Ex Parte MOTION to Substitute Attorney by U.S. Equal Employment Opportunity Commission. (Graham, J.) (Entered: 12/28/2006)
TEXT ONLY ORDER granting 60 Motion to Substitute Attorney. Julie Lee is substituted as counsel of record for defendant Equal Employment Opportunity Commission Attorney Mildred Byrd terminated. NO FURTHER WRITTEN ORDER SHALL ISSUE FROM THE COURT . Signed by Judge Michael T. Parker on December 29, 2006. (Parker, Michael) (Entered: 12/29/2006)
DOCKET ANNOTATION as to TEXT ONLY ORDER granting 60 Motion to Substitute Attorney, should read "Julie Lee is substituted as counsel of record for plaintiff Equal Employment Opportunity Commission." (ldr, ) (Entered: 01/03/2007)
61 NOTICE to Take Deposition of Nick Crechale by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 01/08/2007)
62 NOTICE to Take Deposition of J A & P Restaurants Inc. dba Crechale's Restaurant by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 01/08/2007)

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01/09/2007 01/10/2007 01/10/2007 03/06/2007 03/09/2007 03/20/2007 03/23/2007

DOCKET ANNOTATION as to #61,62, attorney's office contacted regarding filing the actual Notice of Deposition showing person being deposed, time and place. (ldr, ) (Entered: 01/09/2007)
63 NOTICE to Take Deposition of Nick Crechale by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 01/10/2007)
64 NOTICE to Take Deposition of J A & P Restaurants dba Crechale's Restaurant by U.S. Equal Employment Opportunity Commission.(Graham, J.) (Entered: 01/10/2007)
65 Joint MOTION to Approve Consent Judgment by U.S. Equal Employment Opportunity Commission. (Graham, J.) (Entered: 03/06/2007)
66 CONSENT DECREE, resolves all claims arising out of the issues between the Commission and defendant JA&P Restaurants, Inc. d/b/a Crechale's Restaurant. Signed by Judge Keith Starrett on 3/8/07. (ldr, ) (Entered: 03/09/2007)
67 Joint MOTION to Dismiss by U.S. Equal Employment Opportunity Commission. (Graham, J.) (Entered: 03/20/2007)
68 ORDER OF DISMISSAL with prejudice, each party to pay their own costs and fees. Signed by Judge Keith Starrett on 3/22/07. (ldr, ) (Entered: 03/23/2007)

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