Case 1:16-cv-00595-RDB Document 1 Filed 03/01/16 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND BALTIMORE DIVISION

U.S. Equal Employment Opportunity Commission,
10 S. Howard Street, 3rd Floor Baltimore, MD 21201,
Plaintiff,
v.
Pallet Companies d/b/a IFCO Systems NA, Inc. 3030 Waterview Avenue, Suite 200 Baltimore, MD 21230,
Defendant.

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Civil Action No.

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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 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the bases of sex and retaliation, and to provide appropriate relief to Yolanda Boone, who was adversely affected by such practices. As alleged with greater particularity below, the United States Equal Employment Opportunity Commission (the "EEOC" or the "Commission") alleges that Defendant Pallet Companies d/b/a IFCO Systems NA, Inc. ("Defendant" or "IFCO") unlawfully discriminated

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,
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Case 1:16-cv-00595-RDB Document 1 Filed 03/01/16 Page 2 of 7

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(t)(l) and (3) ("Title VII"). This action is also authorized and instituted pursuant to Section 102 of Title I of the Civil Rights Act of 1991,42 U.S.C. § 1981a.

2.

The employment practices alleged to be unlawful were committed within the

jurisdiction of the United States District Court for the District of Maryland.

PARTIES

3.

Plaintiff: the United States 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 Sections 706(f)( 1)

and (3) ofTitle VII, 42 U.S.C. §§ 2000e-5(t)(l) and (3).

4.

At all relevant times, Defendant has continuously been a corporation doing

business and operating within the State of Maryland with at least fifteen (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, Boone filed a charge

VII IFCO.

to eliminate the discriminatory practices and provide appropriate relief.

8. The

with Defendant to

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Defendant the opportunity to remedy the discriminatory practices described in the Letter of Determination.

9.

The Commission was unable to secure from Defendant a conciliation agreement

acceptable to the Commission.

10. On or around October 23, 2015, the Commission issued to Defendant a Notice of Failure of Conciliation.

11. All conditions precedent to the institution of this lawsuit have been fulfilled. 12. Defendant hired Boone on September 14, 2013, as a forklift operator working the first shift. Boone was an excellent forklift operator.

13. Boone is a lesbian. Her sexual orientation was known to most, if not all, of her coworkers, including the night shift manager, Charles Lowry.

14. Approximately three months after Boone began working for IFCO, Lowry requested that Boone begin working some hours during the night shift, which she agreed to do to earn extra income.

15. Almost as soon as Boone began working the night shift, Lowry began harassing Boone on a weekly basis, making comments such as "I want to tum you back into a woman;" "I want you to like men again;" "You would look good in a dress;" "Are you a girl or a man?" and "You don't have breasts." He also quoted

comments

to

her supervisor Anthony Powell in February and March 2014, but no action was taken.

Case 1:16-cv-00595-RDB Document 1 Filed 03/01/16 Page 4 of 7

17. On April 18, 2014, Lowry blew a kiss and stuck out his tongue and circled it in a

suggestive manner toward Boone.

18. Boone immediately complained to Powell, and then to Anthony "Tony" Flores,

the General Manager.

19. Boone told Flores what happened that day and also complained about the

perpetual harassment and comments to which Lowry subjected her. Flores said he would speak

with Lowry.

20. After her meeting with Flores, Boone returned to the warehouse and contacted

Human Resources through the employee hotline to file a complaint about Lowry's harassment.

21. Lowry later returned to the warehouse and continued to intimidate and harass her.

Unable to endure the continuing harassment, she informed Flores that she would leave early that

day, which she did.

22. Boone returned to work on her next scheduled work day, April 22, 2014. As soon

as she arrived, Flores called Boone into a meeting with himself, Brian Schaffer, the Regional

Director, and Randall Lucas, a Human Resources representative, and asked her to resign. Boone

refused to resign.

23. Flores, Schaffer, and Lucas called Boone back into Flores's office later that day

and handed her a typed letter stating had resigned

her position. They again demanded

practices in violation of Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a) by subjecting Boone

to harassment which culminated her discharge.

aforementioned conduct directed at

Case 1:16-cv-00595-RDB Document 1 Filed 03/01/16 Page 5 of 7
Boone was motivated by Boone's sex (female), in that sexual orientation discrimination necessarily entails treating an employee less favorably because of her sex; in that Boone, by virtue of her sexual orientation, did not conform to sex stereotypes and norms about females to which Lowry subscribed; and in that Lowry objected generally to females having romantic and sexual association with other females, and objected specifically to Boone's close, loving association with her female partner.
25. Since at least April 22, 2014, Defendant engaged in unlawful employment practices in violation of Section 704(a) of Title VII, 42 U.S.C. § 2000e-3(a) when it discharged Boone tor complaining about the harassment.
26. The effect of the practices complained of in the above paragraphs has been to deprive Boone of equal employment opportunities and otherwise adversely atfect her rights under Title VII, resulting in expenses incurred due to lost wages, emotional pain, suffering, inconvenience, mental anguish, embarrassment, frustration, humiliation, and loss of enjoyment oflife.
27. The unlawful employment practices complained of above were intentional. 28. The unlawful employment practices complained of above were done with malice or with reckless indifference to Boone's federally protected rights.
PRAYER FOR RELIEF

concert

employment practice that discriminates on the basis of sex and from retaliating against persons

who

in protected

Case 1:16-cv-00595-RDB Document 1 Filed 03/01/16 Page 6 of 7
B. Order Defendant to institute and carry out policies, practices, and programs that provide equal employment opportunities for women and that eradicate the effects of its past and present unlawful employment practices, and prevent sex discrimination and retaliation from occurring in the future;
C. Order Defendant to make Boone whole 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 reinstatement or front pay in lieu of reinstatement;
D. Order Defendant to make Boone whole by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in the paragraphs above.
E. Order Defendant to make Boone whole by providing compensation for past and future non-pecuniary losses including emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, embarrassment, frustration, and humiliation, in an amount to be proven at trial;
F. Order Defendant to pay Boone punitive damages for its callous indifference to her federally protected right to be free from discrimination based on disability;
time,
VII;

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H. Grant such further relief as the Court deems necessary and proper in the public interest; and

I.

Award the Commission its costs in this action.

The Commission requests a jury trial on all questions of fact raised by its Complaint.
Respectfully submitted,
P. DAVID LOPEZ General Counsel
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
DEBRAM. LAWRENCE Regional Attorney
MARIA SALACUSE Supervisory Trial Attorney
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/AMBER
I Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 10 S. Howard Street, 3rd Floor

 
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FilED rllUS.TS.~!DriST"R',I-C'T •.C..C• !~f~:,T,-

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2016 Juri 28 Pli Iz:FiStR THE DISTRICT OF MARYL
BALTIMORE DIVISION

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JUN 2 4 2016

U,S. EQUAblBMPlJOYMENT OPPORTUNITY )

UNITED S'lIm:::i UISI i1ICT JUDGE

COMMIoS,tSION, -

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Plaintiff, v. PALLET COMPANIES d/b/a IFCO SYSTEMS NA, INC"
De~ndant. ------------)

) ) ) Civil Action No. 1:16-cv-00595-CCB ) ) ) ) ) )

CONSENT DECREE

This action was instituted by Plaintiff Equal Employment Opportunity Commission (the

"EEOC" or the "Commission") against Defendant Pallet Companies d/b/a IFCO Systems NA,

Inc. ("IF CO" or "Defendant"), under Title VII of the Civil Rights Act of 1964 ('Title VII") and

Title I of the Civil Rights Act of 1991, alleging that Defendant unlawfully discriminated against

Yolanda Boone ("Ms. Boone") on the basis of her sex (female) by subjecting her to harassment,

which culminated in her discharge, and that Defendant discharged Ms. Boone in retaliation for

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complaining about the harassment. Defendant asserts that discrimination or harassment based on

sexual orientation is against both its values and its written employment policies, which policies

have been in place since 2007, and Defendant denies that it discriminated in any way against Ms,

,

Boone. The parties desire to resolve amicably the Commission's action without the time and

"

expense of continued litigation, and, as a result of having engaged in comprehensive settlement

negotiations, the Parties have agreed that this action should be finally resolved by the entry of a

,,,,

"

Consent Decree. With these understandings, the Parties have jointly formulated a plan to be

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embodied in a Decree which will promote and effectuate the purposes of Title VII.

The Court has examined this Decree and finds that it is reasonable and just and in

accordance with the Federal Rules of Civil Procedure and Title VII. Therefore, upon due

consideration of the record herein and being fully advised in the premises, it is ORDERED,

ADJUDGED AND DECREED:

Scope of Decree

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1. This Decree resolves all issues and claims in the Complaint filed by the EEOC in

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this Title VII action ("the Complaint"), which emanated from the Charge of Discrimination filed

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by Ms. Boone. This Decree in no way affects the EEOC's right to process any other pending or

future charges that may be filed against Defendant and to commence civil actions on any such

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charges as the Commission sees fit.

2. This Decree shall be in effect for a period of two years from the date it is entered

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by the Court. During that time, this Court shall retain jurisdiction over this matter and the parties

for purposes of enforcing compliance with the Decree, including issuing such orders as may be

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required to effectuate the purposes of the Decree. If the Court determines that Defendant has

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failed to meet the established terms at the end of two years, the duration of the Decree may be

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extended.

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3. Unless otherwise specified in this Decree, the terms of this Decree apply to

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Defendant's seven plants in the North Region of IFCO's Third-Party Operations Division (the

"Region") located in the following cities: Baltimore, MD, Barrington, NJ, Scarborough, ME,

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Martinsburg, VA, Wilmington, MA, and Suffolk, VA.

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4. This Decree, being entered with the consent of the parties, shall not constitute an

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admission, adjudication, or finding on the merits of the case.

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Monetary Relief 5. Within ten (10) business days of entry of this Decree, Defendant shall pay Yolanda Boone monetary relief in the total amount of$182,200, representing $7,200 in back pay with interest and $175,000 in nonpecuniary compensatory damages. Defendant will issue to Ms. Boone an IRS Form 1099 for the 2016 tax year for the non-pecuniary damages amount and an IRS W2 form for the 2016 tax year for the back pay amount. Defendant shall make all legally required withholdings from the back pay amount. The checks and IRS forms will be sent directly to Ms. Boone, and a photocopy of the checks and related correspondence will be mailed to the EEOC, Baltimore Field Office, 10 S. Howard Street, 3rd Fioor, Baltimore, Maryland 21201 (Attention: Trial Attorney Amber Trzinski Fox). 6. Defendant shall provide Ms. Boone, within ten (10) days of the entry of this Decree, with a positive letter of reference, on IFCO letterhead, setting forth, at a minimum, the following: Ms. Boone's dates of employment, position, and work location. In response to any inquiry received by Defendant's automated employment and income verification provider, The Work Number, concerning Ms. Boone from a potential employer, headhunter, or other person inquiring about Ms. Boone's employment history, Defendant shall ensure that The Work Number provides a positive reference concerning Ms. Boone, indicating the following: Ms. Boone's dates of employment, position, and work location. Ms. Boone should direct all potential employers, headhunters or other persons inquiring about her employment history at Defendant to contact The Work Number by visiting its website at www.theworknumber.com or by dialing 1-800-367-5690 (1-800-424-0253 TTY). Defendant's Work Number employer name is IFCO Systems and its employer code is 16415. 7. Defendant will contribute, each year of this Decree, $10,000 to the Human Rights

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Campaign Foundation to support, specifically, the Human Rights Campaign Workplace Equality

Program.

Injunctive Relief

8. . Defendant, its managers, officers, agents, successors, purchasers, assigns, U.S.

subsidiaries, and any corporation or entity into which Defendant may merge or with which

Defendant may consolidate are enjoined from engaging in sex discrimination by creating or

maintaining a hostile work environment on the basis of sex. The prohibited hostile work

environment includes the use of offensive or derogatory comments, or other verbal or physical

conduct based on an individual's sex, which creates a severe and/or pervasive hostile working

environment, or interferes with the individual's work performance that violates Title VII, which,

in part, is set forth below:

It shall be an unlawful employment practice for an employer - (1) ... to discriminate

against any individual with respect to [her]

terms, conditions, or privileges of

employment, because of such individual's ... sex .

42 U.S.C. ~ 2000e-2(a)(l).

9. Defendant, its managers, officers, agents, successors, purchasers, assigns, U.S.

subsidiaries, and any corporation or entity into which Defendant may merge or with which

Defendant may consolidate, are further enjoined from retaliating against any individual for

asserting her or his rights under Title VII or otherwise engaging in protected activity, such as by

complaining of discrimination, opposing discrimination, filing a charge, or giving testimony or

assistance with an investigation or litigation, including, but not limited to, participating in this

matter in any way including by giving testimony, as set forth in the following provision of Title

VII:

It shall be an unlawful employment practice for an employer to discriminate against any of his employees ... because [she] has opposed any practice made an unlawful

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employment practice by this subchapter, or because [she] has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this subchapter.
42 U.S.C. S 2000e-3(a).
Sexual Orientation and No Retaliation Policy

10. Within thirty (30) days of the entry of this Decree, Defendant shall distribute to

all employees in the Region copies of its existing EEO and Speaking Up policies ("Policies")

and wallet cards containing the Speaking Up hotline's toll-free number and web address ("Wallet

Card"). In addition, Defendant will distribute the Policies and the Wallet Card in hard copy form

to any new employees of the Region within seven (7) days of hire. Defendant must also

immediately post the Policies in a manner easily visible to all employees in the Region and

immediately forward a copy of any amended policy to the EEOC.

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Training

11. Defendant shall retain, at its expense, a subject matter expert ("SME") on sexual

orientation, gender identity, and trans gender training to assist Defendant in development of a

training program on LGST workplace issues. The SME shall be identified to the EEOC within

30 days of the entry of this Decree and Defendant must obtain the EEOC's approval ofthe SME.

The EEOC's approval of the SME will not be unreasonably withheld. Within 90 days of the

entry of this Decree, Defendant and its SME will develop a specific training module on sexual

orientation and sexual identity issues in the workplace ("LGST Module") and provide the LGST

Module to the EEOC for its approval. The LGST Module, which will take no less than thirty

minutes and no more than forty-five minutes to complete, will address FAQs, acceptance of

diversity of all individuals in the workplace, and how the Policies provide protection for all

LGST employees, together with other topics or issues determined appropriate by the SME,

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subject to the EEOC's approval. The EEOC may edit and comment on the draft module. Defendant will finalize the LGBT Module after receiving input from the EEOC, and will provide a final copy of the LGBT Module to the EEOC for the EEOC's final approval. The EEOC's approval of the LGBT Module will not be unreasonably withheld. The EEOC may provide the LGBT Module (after deleting all references to Defendant) to other companies and agencies as it deems necessary. Defendant and the SME will not claim any copyright or other ownership interest in the LGBT Module.
12. Defendant will present two types of training programs incorporating the LGBT Module:
A. Nationwide Plant Management and Human Resources Training. The LGBT Module will be presented, either live or via webinar, as part of an hour-long EEO and Harassment training program, to Defendant's General Manager, Vice President of Operations, Regional Operations Directors, Plant Managers, Assistant Plant Managers, Human Resource Directors and Human Resources Regional Field Operations Managers in the United States. This training session will include Defendant's Policies, including its anti. retaliation policy, as well as the requirements of Title VII's prohibitions against sexual harassment and retaliation and the requirements and prohibitions of this Decree. A copy of the entire program will be provided to the EEOC. The training shall be conducted by the SME (or his/her designee) and Kevin W. Shaughnessy or another lawyer selected by Defendant and approved by the EEOC. B. Region Training. The LGBT Module will be presented to all employees in the . Region as part of a live, hour-long EEO and Harassment training program. This training session will include Defendant's Policies, including its anti-retaliation policy, as well as

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the requirements of Title VII's prohibitions against sexual harassment and retaliation and

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the requirements and prohibitions of this Decree. A copy of the entire program will be

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provided to the EEOC. The training shall be conducted by the SME (or his/her designee)

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and Kevin W. Shaughnessy or another lawyer selected by Defendant and approved by the

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EEOC.

13. The training for both groups of employees set forth in Section l2A and Section

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l2B must be completed within one hundred eighty (180) days of the entry of this Decree, or 30 days after the EEOC's approval of the final LGBT Module is received by Defendant, whichever

is later. During the effective dates of this Decree, Defendant will also provide the training

program in Section 12A to all new Plant Managers, Assistant Plant Managers, Human Resource Directors and Human Resources Regional Field Operations Managers within thirty (30) days of

their hire or promotion and the training program in Section 12B to all new Region employees

within thirty (30) days of their hire. Training for new employees covered by this Section 13 may

be pre-recorded. 14. In year two of the Decree, Defendant shall provide one hour of EEO and LGBT

training, via an on-line module, to all of its Plant Managers, Assistant Plant Managers, Human

Resource Directors and Human Resources Regional Field Operations Managers in the United

,

States, including a quiz or a test to be passed by all participants. To pass the quiz or test, the

participants must achieve a score of 80 percent or greater.

15. Within ten (10) business days of completing the training described in Paragraphs
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12A and 12B above, Defendant will provide the EEOC with written documentation that the

training occurred, including a list of participants and their job titles, the date the training was

completed, and where the training was delivered through a live session, a signed (either manual ~

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or electronic) attendance sheet. Defendant will provide written documentation of the training of all new employees in the Region, and those trained as described in Paragraph 14, has occurred with its next due semi-annual report.
Notice and Postings 16. Within ten (10) business days of entry of this Decree, Defendant will post, at all of Defendant's locations, the posters required to be displayed in the workplace by Commission
Regulations, 29 C.F.R. S 1601.30.
17. Within fifteen (15) business days of entry ofthis Decree, Defendant will also post in all places where notices are customarily posted for employees at its Baltimore Plant at 3030 Waterview Avenue, Suite #200, Baltimore, MD 21230, the Notice attached as Attachment A. The Notice shall be posted and maintained for the duration of the Decree and shall be signed by Defendant's owner or corporate representative with the date of actual posting shown. Should the Notice become defaced, marred, or otherwise made unreadable, Defendant will ensure that new readable copies of the Notice are posted in the same manner as specified above. Within its first semi-annual report, Defendant shall provide to the EEOC a copy of the signed Notice, written confirmation that the Notice has been posted, and a description of the location and date of the posting.
Monitoring Provisions 18. The EEOC has the right to monitor and review compliance with this Decree. 19. On a semi-annual basis, for the duration of this Decree, and one month before the expiration of this Decree, Defendant must submit written proof via affidavit to the EEOC that it has complied with each of the requirements set forth above. Such proof must include, but need not be limited to, an affidavit by a person with knowledge establishing: (a) the completion of
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training; (b) that the sexual orientation and retaliation policy has been distributed and remains

posted in accordance with this Consent Decree; (c) that it has complied with the injunctive relief

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requested in this Decree; and (d) notifying the Commission of all reported complaints alleging

sexual orientation discrimination in the Region. The notification required by section 19(d) will

include, if the information is available to Defendant, each name of the individual lodging the

complaint; home address; home telephone number; nature of the individual's complaint; the

name of individual who received the complaint or report; the date the complaint or report was

received; description of Defendant's actions taken in response to the complaint or report,

including the name of each manager or supervisor involved in those actions. If no complaints of

alleged sexual orientation discrimination or harassment were reported, Defendant will confirm in

writing to the EEOC that no such complaints were made.

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20. The EEOC may monitor compliance during the duration of this Decree by

inspection of Defendant's Regional premises, records, and interviews with employees at

reasonable times. Upon thirty (30) days' notice by the EEOC, Defendant will make available for

inspection and copying any records requested by the EEOC from the Region.

21. For the duration of this Consent Decree, Defendant must create and maintain such

records as are necessary to demonstrate its compliance with this Consent Decree and 29 C.F.R.

91602 et seq. and maintain an updated EEO poster in compliance with 42 U.S.C. 92000e-IO.

Miscellaneous Provisions

22. All materials required by this Decree to be provided to the EEOC shall be sent by

e-mail to Amber Trzinski Fox, EEOC Trial Attorney, at amber.fox@eeoc.gov, and by certified

mail to Amber Trzinski Fox, EEOC Trial Attorney Baltimore Field Office, 10 South Howard

Street, 3rd Floor, Baltimore, MD 21201. Any notice to Defendant shall be sent by email to

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Kevin W. Shaughnessy at kshaughnessy@bakerlaw.com, and by certified mail to Kevin W. Shaughnessy, Baker & Hostetler LLP, 200 South Orange Avenue, Suite 2300, Orlando, FL 32801,

23. This Consent Decree will operate as a full and final resolution of this action. The EEOC and Defendant shall bear their own costs and attorneys' fees.

24. The EEOC and Defendant shall have independent authority to seek the judicial

enforcement of any aspect, term or provision of this Decree. In the event that either party to this

Decree believes that the other party has failed to comply with any provision(s) of this Decree, the

complaining party shall notify the alleged non-compliant party in writing of such non-

compliance and afford the alleged non-compliant party thirty (30) business days to remedy the

non-compliance or satisfy the complaining party that it has complied. If the dispute is not

resolved within thirty (30) business days, the complaining party may apply to the Court for

appropriate relief.

25. The undersigned counsel of record in the above-captioned action hereby consent,

on behalf of their respective clients, to the entry of this Consent Decree.

FOR PLAINTIFF:

FOR DEFENDANT:

lsi Debra M. Lawrence Debra M. Lawrence Regional Attorney

lsi Maria Salacuse Maria Salacuse Supervisory Trial Attorney

lsi Amber Trzinski Fox Amber Trzinski Fox Trial Attorney EQUAL EMPLOYMENT COMMISSION Baltimore Field Office

OPPORTUNITY

lsi Kevin W Shaughnessy Kevin W. Shaughnessy (with permission) Baker & Hostetler LLP 200 South Orange Avenue Suite 2300 Orlando, FL 32801 Phone: (407) 649-4014 Email: Kshaughnessy@bakerlaw.com
Counsel for Defendant Pallet Companies dibialIFCD Systems NA, Inc.

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lOS. Howard Street, 3rd Floor Baltimore, MD 21201 Phone: (410) 209-2763 Email: amber.fox@eeoc.gov
Counsel for Plaintiff Equal Employment Opportunity Commission

SO ORDERED.

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Signed and entered this 2:$day of

,2016.

The Honorable Catherine C. Blake United States District Court Judge

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ATTACHMENT A

CCaase 11::1166--cv-000559955--CCCCBB DDooccuument 98-1FileFdile0d6/0268/2/136/16PaPgaeg1e32ofof142
NOTICE TO EMPLOYEES POSTED PURSUANT TO A CONSENT DECREE BETWEEN THE EEOC AND PALLET COMPANIES d/b/a IFCO SYSTEMS NA,
INC.

This Notice is being posted as part of the resolution of a lawsuit filed by the Equal Employment Opportunity Commission (EEOC) against Pallet Companies d/b/a IFCO Systems NA, Inc. ("IFCO") in the United States District Court for the District of Maryland, Baltimore Division (EEOC v. Pallet Companies d/b/a IFCO Systems NA, Inc. ("IFCO'')), Civil Action No. 1:16-cv00595-CCB). The EEOC brought this action to enforce provisions of Title VII of the Civil Rights Act of 1964, as amended, which prohibits discrimination on the basis of sex and retaliation.

IFCO will not engage in any acts or practices made unlawful under Title VII, including retaliation against one who exercises his or her rights under Title VII.
Employees or job applicants should feel free to report instances of discriminatory treatment to a supervisor or a manager, at any time. IFCO has established policies and procedures to promptly investigate any such reports and to protect the person making the reports from retaliation, including retaliation by the person allegedly guilty of the discrimination.

IFCO will conduct its hiring and

Individuals are also free to make complaints

employment practices without regard to the

of employment discrimination directly to

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sex or sexual orientation of an applicant or employee and ensure that no employees are

the Baltimore Field Office, 10 South Howard Street, 3rd Floor, Baltimore,

1,

retaliated against for complaining of any

Maryland 21201 or by calling 866-408-

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such discrimination.

8075 / TTY 800-669-6820. General

information. may also be obtained on the

IFCO will take all complaints of

Internet at w~'w.eeoc.gov.

discrimination in the workplace seriously

and address them appropriately.

Owner

Date Posted:

Case 1:16-cv-00595-CCB Document 9 Filed 06/28/16 Page 14 of 14

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 Case: 1:16-cv-595 As of: 12/10/2016 09:44 PM EST 1 of 2
CLOSED,STAYED
U.S. District Court District of Maryland (Baltimore) CIVIL DOCKET FOR CASE #: 1:16−cv−00595−CCB

U.S. Equal Employment Opportunity Commission v. Pallet Companies Assigned to: Chief Judge Catherine C. Blake Cause: 42:2000e−2 Job Discrimination
Plaintiff

Date Filed: 03/01/2016 Date Terminated: 06/28/2016 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

U.S. Equal Employment Opportunity Commission

represented by Amber Trzinski Fox US Equal Employment Opportunity Commission 10 S Howard St 3rd Fl Baltimore, MD 21201 4102092763 Fax: 4109624270 Email: amber.fox@eeoc.gov TERMINATED: 10/15/2016 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Debra Michele Lawrence U S Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14102092734 Fax: 4102092221 Email: debra.lawrence@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Maria Salacuse US Equal Employment Opportunity Commission Baltimore Field Office 10 S Howard St Third Fl Baltimore, MD 21201 14102092733 Fax: 14109624270 Email: maria.salacuse@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Defendant
Pallet Companies doing business as IFCO Systems NA, Inc.

represented by Elizabeth Anne Scully Baker and Hostetler LLP 1050 Connecticut Ave NW Ste 1100 Washington, DC 20036 12028611698 Fax: 12028611783 Email: escully@bakerlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 1:16-cv-595 As of: 12/10/2016 09:44 PM EST 2 of 2
Kevin W Shaughnessy Baker and Hostetler LLP 200 S Orange Ave Suntrust Center Ste 2300 Orlando, FL 32802 4076494000 Fax: 4078410168 Email: kshaughnessy@bakerlaw.com TERMINATED: 10/15/2016 PRO HAC VICE ATTORNEY TO BE NOTICED

Date Filed 03/01/2016 03/01/2016 03/03/2016 03/17/2016 04/14/2016 04/15/2016 06/13/2016 06/15/2016
06/23/2016 06/28/2016

# Docket Text
1 COMPLAINT against Pallet Companies d/b/a IFCO Systems NA, Inc., filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(Fox, Amber) (Entered: 03/01/2016)
2 REQUEST FOR WAIVER of Service sent to Marc Antonetti, Esq. on 03/01/2016 by Equal Employment Opportunity Commission. Waiver of Service due by 4/1/2016. (Fox, Amber) (Entered: 03/01/2016)
Case reassigned to Chief Judge Catherine C. Blake. Judge Richard D Bennett no longer assigned to the case. (cags, Deputy Clerk) (Entered: 03/03/2016)
3 WAIVER OF SERVICE Executed by U.S. Equal Employment Opportunity Commission. Pallet Companies served on 3/1/2016, answer due 5/2/2016. (Fox, Amber) Modified on 3/18/2016 (dass, Deputy Clerk). (Entered: 03/17/2016)
4 Joint MOTION to Stay and Incorporated Memorandum of Law by Pallet Companies Responses due by 5/2/2016 (Scully, Elizabeth) (Entered: 04/14/2016)
5 Marginal ORDER GRANTING 4 Motion to Stay. Status Report due 7/5/16. Signed by Chief Judge Catherine C. Blake on 4/14/2016. (hmls, Deputy Clerk) (Entered: 04/15/2016)
6 MOTION to Appear Pro Hac Vice for Kevin W. Shaughnessy ( Filing fee $ 50, receipt number 0416−6070939.) by Pallet Companies (Scully, Elizabeth) (Entered: 06/13/2016)
7 PAPERLESS ORDER granting 6 Motion to Appear Pro Hac Vice on behalf of Kevin W Shaughnessy. Directing attorney Kevin W Shaughnessy to register online for CM/ECF at https://www.mdd.uscourts.gov/attyregB/inputProHac.asp. Signed by Clerk on 6/15/2016. (srd, Deputy Clerk) (Entered: 06/15/2016)
8 SETTLEMENT AGREEMENT /CONSENT DECREE by U.S. Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit A)(Fox, Amber) (Entered: 06/23/2016)
9 CONSENT DECREE and approval. Signed by Chief Judge Catherine C. Blake on 6/28/2016. (dass, Deputy Clerk) (Entered: 06/28/2016)