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DOCKETED

SEP 2 8 2001

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

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EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

) )

Ole

7508

Plaintiff,
v.

)

)

CIVIL ACTION NO. JUD

)

GE LEINENWEBE(

)

Jnry Trial Demanded

I

NIELSEN & BAINBRIDGE, L.L.C.

)

Defendant.

)

MAGISTRATE JUDGE KEYS

)

)

NATURE OF THE ACTION

This is an action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.

§ 2000e et seq. ("Title VII") and Title I ofthe Civil Rights Act of 1991 to correct unlawful

employment practices on the basis of race and sex and to provide appropriate relief to Maria

Williams and a class of females who were adversely affected by such practices. Plaintiff, EquaJ

Employment Opportunity Commission ("EEOC") alleges that Nielsen & Bainbridge, L.L.C.

("Nielsen & Bainbridge) subjected Maria Williams to sexual and racial harassment because of

her sex, female and race, African-American. The EEOC also alleges that Nielsen & Bainbridge

subjected a class of women to sexual harassment because of their sex (female) and a class of

women to harassment because of their race (Afiican-American).

JURISDICTION AND VENUE

1. Jurisdiction ofthis 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(£)(1) and (3) of

( -I

Title VII, 42 U.S.C. § 2000e-5(t)(1) and (3) and § 102 of the Civil Rights Act of 1991,42 U.S.C. § 1981A.
2. The employment practices hereafter alleged to be unlawful were and are now being committed within the jurisdiction ofthe United States District Court for the Northern District of Illinois, Eastern Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission, is an 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(t)(1) and (3) of Title VII, 42 U.S.C. Section 2000e-5(t)(1) and (3). 4. At all times relevant, Defendant Nielsen & Bainbridge, LLC, a limited liability corporation, registered in the state of Illinois, has continuously been doing business in the Northern District of Illinois and has continuously had at least fifteen employees. 5. At all times relevant, Nielsen & Bainbridge, 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. Sections 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution ofthis lawsuit, Maria Williams filed a charge with the Commission alleging violations of Title VII by Nielsen & Bainbridge. All conditions precedent to the institution ofthis lawsuit have been fulfilled.
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'.
v
7. Since at least June 12,2000, Defendant Nielsen & Bainbridge has engaged in unlawful employment practices at its Bridgeview, Illinois facility, in violation of Sections 701(k) and 703(a) of Title VII, 42 U.S.C. Sections 2000e(k) and 2(a). Such unlawful employment practices have included: I) sUbjecting Maria Williams to harassment because of her sex (female) and race (African-American), sUbjecting a class of women employees to sexual harassment, and 3) subjecting a class of African-American women to harassment because of their race.
8. The effect of the practices complained of above has been to deprive Williams, and classes of women employees adversely affected by the harassment, of equal employment opportunities and otherwise adversely affect their status as employees because of their sex (female) and race (African-American).
9. The unlawful employment practices complained of in paragraphs 7 and 8 above were intentional.
10. The unlawful employment practices complained of in paragraphs 7 and 8 above were done with malice or with reckless indifference to the federally protected rights of Williams and classes of women employees because of their sex (female) and race (African-American).
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Nielsen & Bainbridge, LLC, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates because ofrace and sex. B. Order Defendant to institute and carry out policies, practices and programs which eradicate the effects of its past and present unlawful practices.
-3-

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C. Order Defendant to make whole Williams and the affected classes by providing appropriate back 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.
D. Order Defendant to make whole Williams and the affected classes, by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 7 and 8 above, including medical expenses, in amounts to be determined at trial.
E. Order Defendant to make whole Williams and the affected classes by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraphs 7 and 8 above, including emotional pain, inconvenience, and humiliation, in amounts to be determined at trial.
F. Order Defendant to pay Williams and the affected classes punitive damages for its malicious and reckless conduct described in paragraphs 7 and 8 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest; and
H. Award the Commission its costs in this action.

-4-

\.J
JURY TRIAL DEMAND The Commission requests ajury trial on all questions of fact raised by its complaint.
Respectfully submitted,
NICHOLAS M. INZEO Acting Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
l l J i t ¥.nU1Ly-------
Noelle C. Brennan Supervisory Trial Attorney
~r-.d:tk
Pamela S. Moore-Gi bs Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Chicago District Office 500 West Madison Street Suite 2800 Chicago, Illinois 60661 (312) 886-9120
-5-

Civil Cover Sheet

http://www .ilnd .uscourts .gov/PUBL!C/Forms/autojs44.cfrr

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

SEP 2 8 2001

Civil Cover Sheet

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required
by law. This form is authorized for use only in the Northern District oflllinois.

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Defendant(s):NIELSEN & BAINBRIDGE,
L.L.c.

County of Residence:

County of Residence:

Plaintiffs Atty:

Pamela S. Moore-Gibbs

Defendant's Atty:

Equal Employment Opportunity

Commission

500 W. Madison, Suite 2800

Chicago, IL 60661

312-886-9120

Edward C. Jepson, Jr. Vedder Price Kaufman Kammholz 222 N. LaSalIe Street Chicago, IL 60601-1003

II. Basis of Jurisdiction:

1. U.S. Gov't Plaintiff

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

IV. Origin:

1. Original Proceeding

JUDGE LEINENWEBER MAGISTF?ATE JUDGE KEYS

V. Nature of Suit:

442 Employment

Vr.Cause of Action:

Title VII of the Civil Rights Act of1964, as amended, 42 U.S.C. §

2000e et seq. ("Title Villi) and Title I of the Civil Rights Act of 1991

§ to correct unlawful employment practicies on the basis of race and

sex.

VII. Requested in Complaint

Class Action:

'.''-<0 ••

DolIar Demand:

. J
-"

Jury Demand: Yes

•••• J

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

;_.. -.

Signature: ~dA. lAftMv-J~

" ,:' (j) ::")

o~~~~s~cor c t, Date: Ifany

please go back to the Civil Cover Shcctlnput form using the Back button in your browser and

change It. Once correct, print this form, sign and date it and submit it with your new civil action. Note: You may need to adjust

the font size in your browser display to make the form print properly.

Revised: 06128100

I of I

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In the Matter of

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

Eastern Division

Ti (C; (\:0.W.'\ ".,S V:0'

Case Number:

DOCKH~C
SEP 2 8 2001

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATToRNE-MM'}161U,zATE JUDGE KEYS

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P~:nela S. Moore-a'bbs

FIRM
Equal Employment Opportunity Commission

STREET ADDRESS
500 W. Madison Suite 2800

cITh~TATElZ1P
C lcago, IL 60661

(3Ll2)N8'g6~9Et20

IDENTII'!CATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC NO.06197710

MEMBER OF TRIAL DAR?

0 YES

TRIAL ATIORNEY?

0 YES

NO 0
NO 0

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FIRM

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Equal E nployment OIJportunity Commission

STREET ADDR lSS
500 W/ \1adison, Suite 2800
CITY~E/ZIP
Thicago, IL 60661

TELEPHONE NUMBER
(312) 353-8551

IDENT[FICAnON NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 01187589

MEMBER OF TRIAL BAR?

0 YES

TRIAL ATIORNEY?

0 YES

NO 0 NO 0

DESIGNATED AS LOCAL COUNSEL?

0 YES

NO 0

(B)

JJ. J S1G(~',T(t \'./

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NAME
Noelle C. Brennan

PIRM
Equal Employment Opportunity Commission

STREET ADDRESS
500 W. Madison Suite 2800

CITYISTATE/ZlP
Chicago, IL 60661

(312n53~7582

IDENTIFICA nON NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 06228901

MEMBER OF TRIAL DAR?

0 YES

TRIAL ATIORNEY?

El YES

NO 0
NO 0

DESIGNATED AS LOCAL COUNSEL?

0 D YES

NO

SIGNATURE

(D)

NAME FIRM STREET ADDRESS CITY/STATE/ZIP TELEPHONE NUMBER IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

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 United States District Court, Northern District of Illinois

Sitting J'HIj:!;~ it" Other thllll Assigned ,Judge

CASE NUMBER /OIC73X

DATE

1211 712()02

CAS!!: TITLE,
MOTION:

l il1lec , ates of America vs. Nidsen & Bainbridge EEOC V~. Niel~en & Bainbridge
1,ln till.: f~\ll~)wil1g bnx (<'I) indkw~~ (ill.; P,U[Y 1i!ing the motion, e.g,.lJlaintitl. defendant, 31'(1 pilrty plailltif{ ;uld {b) :,li\lt~ bridly tilt: Ililture
~,r(I\(: [1\~ltinIlIKing P!\\~clltcd.1

DOCKCT CNTRY:

Joint Motion Ii,,· Entry of Consent Decree

( I)

D

f-'ilcd motion of[ usc listing in "Motion~~ box above.]

(2)

D

Ul'ief in SUppOl't of motion due _ _ _.

(3)

Il

Answer hri(,;f" l,o 1l1ol.ion due

Reply to answer brid' tlu!..:.

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RulinJ,!,/llenring on .___._. set for

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SIi.11LiS llci:lrillg.l:hcid/colltinued to I Iset r()t/I'e-sl~t forl on ___ set for ___ at _ _ _ .

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IR(,.~IlCh/.lll1"): trialJ [Hearing) h(.~[J/C()nliflueJ 10

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This CdSC is d~,-;lilissed [with/wlthoutl prejudice and \vithout costsrby/agreement/pursuJnt tol
D FRCP4(m) D LuuLi Rule 41.1 D 1-'RCP4I (a)(i ) D I'RCPill(a)(2).

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or 1011"'1" docker entryJ The .Ioinl Motion I()r Entry Consent Decree is granted. Enter Conscnt

Decree. Status hearing stricken_

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[hn lluthcl' detail see order (on reverse side of/attached to) the original minute ol'del',l

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Ill'liling deputy initial,;

Dor:un'feM
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IN TIlE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
DOCKETED

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff, and
MARIA WILLIAMS,
Plaintiff-Intervenor,
v.
NIELSEN & BAINBRIDGE, LLC,
Defendant.

)

DEC 2 :1 7002

)

)

)

)

Judge Leinenweber

)

Magistrate Judge Keys

)

)

)

)

)

No. 01 C 7508

)

)

)

)

MARIA WILLIAMS, Plaintiff,
v. NIELSEN & BAINBRIDGE, LLC,
Defendant.

)

)

)

)

)

)

No. 01 C 7388

)

)

)

)

)

CONSENT DECREE The Litigation
Plaintill~ Equal Employment Opportunity Commission (herea1ter the "EEOC"), filed this

action on September 28,2001, alleging that Defendant Nielsen & Bainbridge, L.L.C., (Nielsen &

Bainbridge) discriminated against Charging Party Maria Williams and a class of female

employees, in violation of Title VII ofthe Civil Rights Act of 1964, as amended, 42 U.S.c. §

\'8

2000e et seq. ("Tille VII") and § 102 of the Civil Rights Act of 1991,42 U.S.c. § 1981 A, by subjecting Williams and a class of female employees to a hostile working envirolmlent because of their sex (female) and because oflheir race (Black). Maria Williams, represented by her own counsel, intervened in the EEOC's suit on Febmaty 7, 2002. On June 12, 2002, Case Numher 01 C 7388, which alleged retaliation and constructive discharge, was consolidated into this action. Nielsen & Bainbridge has denied the allegations of the Complaints. As a result onhe parties having engaged in se((]emen( discussions, the parties have agreed that this action should be finally resolved by entJy of this Consent Decree. Tbis Consent Decree is intended to atld does fully atld finally resolve any ami all claims arising out of the Complaints atld all ofthe claims arising out of the Complaint in Case Number 01 C 7388.
Findings Having examined the temls and provisions of (bis Consent Decree atld based on the pleadings, records, and stipulations orthe patties, this Court finds the following: A. This Comi has jurisdiction over th", subject matter of this action and over the parties. B. The tenus and provisions of this Consent Decree arc fair, adequate, reasonable, equitable and just. The rights of the patties are adequately protected by this Consent Decree. C. This Consent Decree conlonns with the Federal Rules of Civil Procedure and
Title VTT. The entry of this Consent Decree will further the objectives ofTi(le vn and will be in
the best interest of the parties and the public. D. NOW THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:
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N on~Discrimination I. In all matters arising from or relating to employment, Nielsen & Bainbridge, its officers agents, employees, successors, and assigns shallnol discriminate on the basis of sex or race in violation ofTit1c VII.
Non-Retaliation 2. Niclsen & Bainbridge, its officers, agents, employees, successors, and assigns shall not rdaliate against, penali/.e or otherwise prejudice any employee, former employee or applicant for employment because such person has opposed any practice made unlawful by Titk VII; filed a Complaint Of Charge; testi Ii ed, assisted, or otherwise participated in any manner in any investigation, proceeding, hearing or litigation under Title VTT; asserted any right under this Consent Decree; or othelwise exercised his or her lights under Title VJT.
Monetary Relief 3. Nielsen & Bainbridge shall pay monetary damages in the sum of one hundred fifty-five thousand dollars ($155,000.00). Payment will be made as follows: A. Atter the Consent Decree has been entered and within fourteen (14) business days after the EEOC has provided to Nielsen & Bainbridge a Release iorm (attached as Exhibit A to this Consent Decree) executed by each ofthe three (3) class members identified in the attached sealed App~ndix, Nielsen & Bainhridge shall issue, by certified mail to the three class members, checks payable to the order ofthe class members in the amolmts of fifteen thousand dollars ($15,000) ench, Cor a total of forty-five thousand dollars ($45,000.00), representing monetary dal1lag~s. Nielsen & Bainhridge shall isslic a Form 1099 to each orthe three class members. The EEOC shall also provide Nielsen &
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•

Bainbridge with cun-ent addresses ((If the class members. Nielsen & Bainbridge shall

send a copy of the checks to EEOC.

B. After the Consent Decree has been entered and within fourteen (14) husincss days

after Nielsen & Bainbridge receives a Release form executed by Maria Williams,

approved by her own private attorney, Nielsen & Bainbridge shall send by certi lied mail,

three checks to Sharon Finegan Patterson. Maria Williams' attorney, located at 39 South

LaSalle, Suite 1014, Chicago, lllinois 60603. One check shall be for back pay in the

amount of $5,000.00 less the employee's share of alllcgally required taxes and other

withholdings. Nielsen & Bainbridge shall be responsible for payment of' employer

taxes, which includes ami is limited to appropriate amounts for state and federallaxes

and FICA. The second check Shflll he in the sum 01'$68,333.34 payable to Maria

Williams for non-wage monetary damages for which a 1"01111 1099 win be issued to

Williams. The third check, payable to Sharon Finegan Patterson, shall be issued for

attorneys fees in the sum 0[$36,666.66 for which a FOIlTI 1099 will he issued to

Patlerson for non-employee compensation. Nielsen & Bainblidge shall send a copy or

the checks to the EEOC.

Training

4. Within forty-five (45) days after enllY of this Consent Decree, Nielsen & Bainbridge

shall arrange for additional training of employees and supervisors of Nielsen & Bainhridge

regarding requirements of Title VII. Nielsen & Bainbridge shall suhmit to EEOC for approval,

materials regarding the training session, including the credentials of the trainer, prior to such

training. Within five (5) days after the completion of the training described above,

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•

Nielsen & Bainbridge will cer(i Cy to EEOC that the training has been completed, (he name(s) or

the person(s) conducting the training, the (jm<;l(S), duration and datc(s) the training was held and a

list identifying by namc and position all individuals who received the training,

Notice Posting

5. Within ten (J 0) days alter the Court's entry of this Consent Decree and for (he

duration ofthis Decree, Nielsen & Bainbridge shall continu(lusly post the notice annexed hereto

as Exhibit B at its Bridgeview facility in prominent l(lcations frequented by Nielsen &

Bainbridge employees. Withill ten (10) days after the Consent Decree is entered Nielsell &

Bainbridge shall certify in writing to the Chicago District Office of the EEOC that the Notice has

been posted, and sball infonn the EEOC oCthe locati(lns where it has been posted.

Record Keeping and Reporting

6. Nielscn & Bainbridge shall maintain all records concerning its implementation of

this Consent Decree. Nielsen & Bainbridge shall maintain records of any complaints i( receives

of sex or race discrimination at its Bridgeview facility, its investigati(ln of such complaints, and

any response or action taken as a result (If the complaint.

7. Beginning six (6) months after entry (If (his Consent Decree and every six (6)

months thereafter f(lr the ([([ration orthe Consent Decree, Nielsen & Bainbridge shall fumish the

EEOC witb reports reflecting information detailed in the records described in Paragraph 6 ofthis

Consent Decree. Nielsen & Bainbridge's last report will be submitted to the EEOC (wo (2)

weeks prior to the date on which (he Decree is to expire.

8. F(lr (he tenn orthe Consent Decree and upon five (5) business days notice to

Nielsen & Bainhridge, the EEOC, when it has reas(lnable cause to believe Nielsen & Bainbridge

is not in compliance with (he tenns of this Consent Decree, shall have access to Nielsen &

Bainbridge's Bridgeview facility (0 review and copy any documents related to determining

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•

compliance, located at its facility and to interview any perSOtnlei employed by Nielsen &

Bainbridge for the purpose of ddemlining Nielsen & Bainbridge's compliance with the terms of

this Consent Decree,

Duration of Decrcc/RctcntioD of Jurisdiction

9. The terms of this Consent Decree shall be in effect (and the COUTt will retain

jurisdiction of this matter to enforce this Decree) for a period ofthrce (3) years from the date on

which this Consent Decree is entered, provided, however, that if, at the end of the three (3) year

period, there arc disputes that remain unresolved, the term of the Decree shall be aut(lmatically

extended until such time as all such disputes have been resolved.

Attorueys I Fees

10. Nielsen & Bainbridge agrees to pay the reasonable attorneys' fees of Maria

Williams, as agreed to by and between Nielsen & Bainbridge and counsel for Ms. Williams, in

accord,mce with the tenns of the Consent Decree_

Disputc Resolution

11, Tflhe EEOC has reasonable cause to helieve that Nielsen & Bainbridge has

violated any of the terms of this Consent Decree, the EEOC shall notify Nielsen & Bainbridge in

writing and Nielsen & Bainblidge will Ihen h(lve len (10) husiness days in whieh to satisly the

EEOC that there has not been a violation or that the violation has been corrected. Tf al the

expiration of such time period, the EEOC has not been so satisfied, Ihen the EEOC may

immediately apply to the Court for appropriate relief.

12, When the Decree requires the submission by Defendant of reports, notices or

other materials to the EEOc:, they shall be mailed 10 Nielsen & Bainbridge Settlement, Equal

Employment Opportunity Commission, Chicago District Office, 500 West Madison Sireet, Suite

2800, Chicago, Illinois 60661.

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ENTERED AND APPROVED FOR:
I"or the Equal Employment Opportunity Commission:
NICHOLAS M. INZEO Acting Deputy Genenll Counsel
Gwendolyn Young Reams Associ ate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION _-~
18011. S

For Plaintiff Maria Williams:
SHARON FINEGAN PATTERSON A((orney at Law 39 South LaSalle Street, Suite 1014 Chicago, Illinois 60603 (312) 855-1076
greed and Approved for Defendant Nielsen & Bainbridge, LLC:

llJJ.g ~ it U Q,v------
Noelle C. Brennan Supervisory Trial Attorney

Vedder, Price, KauITnan & 222 North LaSalle Street Chicago, Illinois 60601
(312) 609-7582 ----....--

'(If . lhn. ,I( ll A(l9_ 32 "t'G{/>> '/7 ~ i/ ~
amela S. Moore-Gib s
Trial AHomey

Equal Employment Opportunity Commission
Chicago District Office 500 West Madison Street Suite 2800 Chicago, Tllinois 60661 (312) 886-9120
D,,.;i ,/'fdrJd:d-

ENTER:~~~~~~~~~ Honorable Hany D. Leinenwebcr
United States District Judge

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"
I!:XIIIBIT A RELEASR AGREEMENT
I, ____,__ ,~._"" _ _• for and in consideration of the sum of$15.000-00, payable to me pursliant to the terms of the Consent Decree entered by the Court in EEOC v. Nielsen & Bainbridge. LLC, No. 01 C 7508 (N.D. Ill.), on behalf of myself, my heirs, assigns, executors, and agents, do hereby forever release, waive, remise, acquit, and discharge Nielsen & Bainbridge, LLC, ami all past and present shareholders, officers, agents, employees, and representatives of Nielsen & Bainbridge, as well as all successors and assignee~ of Nielsen & Bainblidge from any and all claims and causes of action of any kind whieh 1 now have or ever have had under Title VII ofthe Civil Rights Act of 1964, as amended, 42 U.S-C. § 20000 et §£.(I., and § 102 orthe Civil Rights Act ofl991, 42 U.S-C. § 1981A, as a result of or arising from the subject matter and claims whieh were asselted in EEOC v. Nielsen & Bainhridge, No 01 C 7508 (N.D. IlL).
Date

· .

NOTICE TO ALL RMPLOYERS
This Notice is posted pl~rsuant to the Consent Decree entered in December 2002 by the U.S. District Court resolving the lawsuit entitled U. S. Equal Employment Opportunity Comm.ission v. Nielsen & Bainbrid!):c. LLC, N.D. Illinois No. 01 C 7508.
The lawsuit was based upon a Charge of Discrimination filed with the Equal Employment Opportunity Commission ("EEOC") by an employee who alleged that she was harassed because ofhor sex and racc. The EEOC lawsuit alleged that Nielsen & Bainbridge discriminated against employees on tbe basis of sex and race in violation of Tille VII of the Civil Rights Act of 1964, as amended and the Civil Rights Act of 1991. The EEOC and Nielsen & Bainbridge reached a settlement in the case, and the Court entered a Consent Decree resolving tbe lawsuit.
Under tbe terms of the Consent Decree, Nielsen & Bainbridge will:
1. Not engage in any employment practice which discriminates on the basis of sex and race;
2. Make monetary payments to the claimants and the individual who filed the charge of discrimination;
3. Provide training to managers and employees concerning laws prohibiting employnlent discrimin(ltion;
4. Maintain certain infonnation relating to complaints and report to the EEOC for three (3) years.
Title VII of the Civil Rights Act of 1964, as amended, prohibits employers from discriminating on the basis of sex, race, color, religion or national origin. The Equal Employment Opportunity Commission is the agency responsible for enforcing Title VIT. If you bave any complaints of discrimination or questions concerning your rights under Title VII, you may contact tbe EEOC at (he address and phone number given below.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED OR REMOVED
This Notice must remain posted for three (3) years from the date shown below and must not be altered, defaced or covered by any other matedal. Any complaints of discrimination or questions concerning tbis Notice or compliance wi th its provisions may be directed to the Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661,(312)353-2713.

Dated:

Judge Harry D. Leinenwcber Uniled States District Court

, .
;,: i
CERTIFICATE OF SERVICE Pamela S. Moore-Gibbs, an attomey, hereby certifies that she caused a copy of the foregoing Joint Motion for Entry of Consent Decree, to be served via facsimile and by first class mail, postage prepaid, on this13 'h day of December, 2002, to the following counsel of record: Sharon Finegan Pa((erS(lll 39 South LaSalle Street Suite 1014 Chicago, Illinois 60603 Edward C. Jepson, Jr. VEDDER, PRlCE KAUFMAN & KAMMHOLZ 222 North LaSalle Street Chicago, Tllinois 60601
~~ -'.?1iW~d'- ~ Pamela S. Moore-Gib s

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?422100366248045-L_35...
KEYS, PROTO, STOP, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-07508

EEOC v. Nielsen & Bainbridge Assigned to: Hon. Harry D. Leinenweber Demand: $0 Cause: 42:1981 Civil Rights Plaintiff Equal Employment Opportunity Commission
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Date Filed: 09/28/2001 Date Terminated: 12/17/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Pamela Sue Moore-Gibbs United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7568 Email: pamela.moore-gibbs@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ann M Henry Equal Employment Opportunity Commission 500 W. Madison Street 2800 Chicago, IL 60661 (312)353-8558 Email: ann.henry@eeoc.gov ATTORNEY TO BE NOTICED
John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED
Noelle Christine Brennan Brennan & Monte, Ltd. 20 South Clark Street Suite 1530
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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?422100366248045-L_35...

V. Defendant Nielsen & Bainbridge, LLC.
Intervenor Maria Williams

Chicago, IL 60603 (312) 422-0001 Email: nbrennan@brennan-monte.com ATTORNEY TO BE NOTICED
represented by Edward C. Jepson, Jr. Vedder, Price Kaufman & Kammholz, P.C. 222 North LaSalle Street Suite 2600 Chicago, IL 60601 (312) 609-7500 Email: ejepson@vedderprice.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Mary Claire O'Neil Littler Mendelson, P.C. 200 North LaSalle Street Suite 2900 Chicago, IL 60601 (312) 609-7500 Email: moneil@littler.com ATTORNEY TO BE NOTICED
represented by Sharon Finegan Patterson Attorney at Law 39 South LaSalle Street Suite 1014 Chicago, IL 60603 (312) 855-1076 Email: sfplaw@aol.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/28/2001
10/16/2001

#

Docket Text

1 COMPLAINT; Jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Noelle Christine Brennan, Pamela Sue Moore-Gibbs as attorney(s) for plaintiff (No summons(es) issued). (Documents: 1-1 through 1-3) (cem) (Entered: 09/28/2001)
2 WAIVER of service of summons as to defendant sent on 09/28/01. (mw) (Entered: 10/19/2001)

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11/09/2001 11/19/2001 11/20/2001 11/27/2001 11/30/2001 12/07/2001 12/07/2001 12/07/2001 02/05/2002 02/07/2002 02/07/2002
03/12/2002
04/01/2002 04/24/2002 05/10/2002 05/14/2002
06/12/2002

6 MOTION by Maria Williams to intervene (Attachments); Notice. (mw) (Entered: 12/12/2001)
7 AMENDED NOTICE by intervenor of her motion to intervene [6-1] (Attachments). (mw) (Entered: 12/12/2001)
3 ANSWER by defendant to plaintiff's complaint [1-1]. (mw) (Entered: 11/20/2001)
4 ATTORNEY APPEARANCE for defendant by Mary Claire O'Neil. (mw) (Entered: 11/28/2001)
SCHEDULE set on 11/30/01 by Hon. Harry D. Leinenweber : Status hearing set for February 7, 2002 at 9:00 a.m. Mailed notice (wp) (Entered: 11/30/2001)
5 ATTORNEY APPEARANCE for Maria Williams by Sharon Finegan Patterson. (mw) (Entered: 12/10/2001)
8 MINUTE ORDER of 12/7/01 by Hon. Harry D. Leinenweber : Maria Williams' motion to intervene is granted [6-1]. No notice (mw) (Entered: 12/12/2001)
9 INTERVENOR'S COMPLAINT by intervenor; Jury demand. (mw) (Entered: 12/12/2001)
10 ANSWER by defendant to intervenor's complaint [9-1]. (mw) (Entered: 02/05/2002)
11 ATTORNEY APPEARANCE for plaintiff by Ann M Henry. (mw) (Entered: 02/07/2002)
SCHEDULE set on 2/7/02 by Hon. Harry D. Leinenweber : Status hearing held and continued to March 12, 2002 at 9:00 a.m. No notice (wp) (Entered: 02/08/2002)
SCHEDULE set on 3/12/02 by Hon. Harry D. Leinenweber : Status hearing held and continued to May 14, 2002 at 9:00 a.m. No notice (wp) (Entered: 03/15/2002)
12 MINUTE ORDER of 4/1/02 by Hon. Harry D. Leinenweber : Entered Agreed Protective Order. Mailed notice (mw) (Entered: 04/02/2002)
13 JOINT MOTION by intervenor Maria Williams to consolidate 01 C 7388 with this case (Attachments); Notice. (mw) (Entered: 05/16/2002)
14 MOTION by plaintiff EEOC to enlarge time to identify class members ; Notice. (mw) (Entered: 05/16/2002)
15 MINUTE ORDER of 5/14/02 by Hon. Harry D. Leinenweber : Status hearing held and continued to 06/04/02 at 9:00 a.m. EEOC's motion to enlarge time to identify class members by 06/04/02 [14-1] is granted. The parties joint motion to consolidate case number 01 C 7388 now pending before Judge Guzman [13-1] is granted. No notice (mw) (Entered: 05/16/2002)
16 MINUTE ORDER of 6/12/02 by Hon. Harry D. Leinenweber : The above cases 01 C 7388 and 01 C 7508 are consolidated for all purposes. No notice (mw) (Entered: 06/13/2002)

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06/12/2002 10/18/2002 12/17/2002
12/17/2002 10/06/2005

CONSOLIDATED for all purposes. See docket of 01 C 7388 for all further entries. (mw) (Entered: 06/13/2002)
17 JOINT MOTION by plaintiff EEOC and intervenor Maria Williams to enlarge time for discovery ; Notice. (cem) (Entered: 10/28/2002)
18 MINUTE ORDER of 12/17/02 by Hon. Harry D. Leinenweber: The joint motion for entry of consent decree is granted. (Entered Consent Decree.) Status hearing stricken. terminating case. Mailed notice (gcy) (Entered: 12/23/2002)
19 APPENDIX filed by plaintiff to the consent decree [18-1]. (RESTRICTED.) (gcy) (Entered: 12/23/2002)
20 ACKNOWLEDGMENT by plaintiff Equal Employment Opportunity Commission of receipt of sealed documents No. 19.(mjc, ) (Entered: 10/13/2005)

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Client Code: eeoc

Description: Docket Report Search Criteria: 1:01-cv-07508

Billable Pages: 2

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 EEOC LITIGATION SETTLEMENT REPORT - DECEMBER 2002

http://www.eeoc.gov/litigation/settlements/settlement12-02.html

EEOC v. Nielsen & Bainbridge, L.L.C. No. 01 C 7508 (N.D. Ill. December 17, 2002)
In this Title VII lawsuit, the Chicago District Office alleged that defendant, a manufacturer and distributor of various types of containers and laminated foam boards, subjected four black female production workers to harassment based on sex and race. Both supervisors and co-workers participated in the harassment, including exposing their buttocks and genitalia, referring to women as "bitches" and "black hairy dog" and, on two occasions, opening the restroom door when a female worker was using the toilet and throwing water on her. The case was resolved through a consent decree which provides for a payment of $155,000 to the four claimants representing $110,000 to charging party ($5,000 in back pay, $68,333 in damages and $36,666 in attorneys fees) and $15,000 each to the other three claimants. The decree enjoins defendant from discriminating on the basis of sex and race and requires training of all employees regarding sexual and racial harassment.

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