Case 2:06-cv-O2873-VVY Document 1 Filed 06/30/2006 Page 1 of 7

UDi¢~;1 $I~~G I~.tlaJ l~mployn~nt Opl~i-L~ni~ (~ommi~i~ Ph.[l~.lpbie., PA [9105 Rmchel ~ Smith ~ouns~ for Plain~i~w’:OC (211~{) 440-~A4~-
IN "tHE LTN[TED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

EQUAL EMPLOYME1Vr OPPORTUNITY COMMISSION,

Plaintif£,

CML ACTION NO.

ROSS STORES, INC., Defendant.

.COMPLAINT JURY TRIAL DEMAND

NATI~RE_.OF THE ACTION This is an action under Title V-I] of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 to eon’eet unlawful employment practices that discriminate on the basis of national origin and to provide appropriate relief to Natalia R. Vistinis, who was adversely affected by such practices. As asticulated with greater p~licularity in Paragraph 7 below, the Commission alleges that Ms.Vistinis was discriminated against ba~ed on her national origin (Russian) when Defendant Employer Ross Stores unlawfially denied h~ a raise aRer she was promoted because of her accent. As a result of the discriminatory co, duct, the Commission alleges that M~. Vistin~s suffered baekpay and emotional distress damage,.

Case 2:06-cv-O2873-VVY Document 1 Filed 06/30/2006 Page 2 of 7

JUR/SDICTION AND VENI$E

Juri~iction of this Court is invoked pursuant to 28 U.S.C. §§ 451,133 I, 1337,

1343 and 13~.5. This action is authorized and instituted pttrsuant to § 706(1")(1) and (3) of Title VH

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

Section 102 of the Civil Rights Act of 1991, ~-2 U.S.C. § 1981A. 2. The employment practices alleged to be unlawful were and are now being

committed within the jurisdiction of the United States District Court for the Eastern District of

Pennsylvania.

PARTIES

3. Plaintiff, the Equal Employment Opporturdty 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 achon by Section 706(f)(1) and

(3) of Titie VII, 42 U.S.C. § 2000(e)-5(f)(1) and (3).

4. At all relevant times, Defendant Employer has continuously been and is now doing

busine,s in the State of Pennsylvania, in the City of Lan~ale, and has continuously had at least 15

employees.

5.

At all relevant times, Defendant Employer has cominuo~ly been an employer

engaged in an industry affecting commerce within the meaning of Sections 701(’o), (g) and (h) of

Title Vrl, 42 LI.S.C. §§ 2000e(b), (g) and (h).

STATEMENT OF ~:LAIM~

More than thirty days prior to the institution of this lawsuit, a charge of discrimination

was filed with the Commission, alleging violations of Title VII by Defendant EmplAoyller.

2

Case 2:06-cv-O2873-WY Document 1 Filed 06/30/2006 Page 3 of 7
conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at toast November of 2003, Defendant Employer has engaged in unlawful
employment practices at its Lansdale, Pennsylvania facilityin violation of Section 703(a)(1) e fTitle Vrl, 42 U.S.C. Section 2000e-2(a)(1) by discriminating against Natalia Visfinis on the basis of her National origin (Russian). The unlawful employment practices included the following:
(a) Ms. Vistinis was hired as a Retail Associate by Defendant Employer on or about October 6, 2000. She received a promotion to Front-End Supervisor on or about June 15, 2003 and received a $1.00 per hour pay mcre~e with this promotion.
(b) In November of 2003, Jerome Bennett, former Store Manager, promoted Ms. Vistinis to the position of Area $upetadsor. As Area Supervisor, Ms. Vistinis assumed additional responsibilities such a~ operfing and closing the store, and approving cash deposits.
(c) At the time of Ms. Vistinis" promotion, Mr. Bcrmett also informed her that she w~ entitled to a promotional pay increase. However, Ms. Visfinis never received this pay increase as she was promised. Upon information and belief, other non-Russian persons promoted to Area SupervisoL prior to November of 2003, received a pay increase upon their promotion to Area Supervisor.
(d) Ms. VistilfiS irdormed Mr. Ber~ett that she did not r,e2ive a pay increase with her last promotion to Area Super’~i~r. Mr. Bennett assured Ms. Vistirfis that he would investigate the issue and r~assured her that not onlywould she receive her pay increase, but that it would be applied retroactively.
(e) Having not received the pay increase, in June of 2004, MS. Vistinis again inquired about her raise of Mr. Bennett. Mr. Bemlett th,n informed Ms. Vistinis that he was told by District

Case 2:06-cv-O2873-WY Document 1 Filed 06/30/2006 Page 4 of 7
Manager, Cindy Robinson, that she had not received her raise because of her Russian accent. However, Bennett once again assured Ms. Vistinis that he woutd investigate and apply the raise retroactively.
(f) However, Mr. Bennett took no action to correct the discriminatory action taken against Ms. Vistinis was he was eventually transferred and later terminated from his position a~ Store Manager.
(g) Having received no assistance fromMr. Bennett, Ms.Vistinis approached Assistant Store Manager, Rand Oliver, with her concerns. Ms. Oliver told Ms. Visfinis that Mr. Bennett had previously informed herofthe paymise issue. Ms. Oliver also stated that Mr. Bennett had previously informed her that Ms. Visfirtis was seeking her promotional pay raise, and that Ms. Robinson had stated that Ms. Vistinis had not received her raise because of her Russian accent.
(h) After Ms. Vistinis~ complaints of disparate treatment, Defendant Employer continued to deny Ms. Vistinis a promotional pay raise because of her accent and denied that the manager’s statement about her accent was ever made. Defendant Employer subsequently reclassified Ms. Vistinis’ posit/on, cot~tending that Ms. Vistinis’ promotion was a lateral move, not meriting a pay increase, in or about October of 2004.
10. The effect of the practices complained of in paragraph 7(a) through 0a) above has been to deprive Natalia Vistinis of equal employment opportunities and otherwise affect her status as an employee beeanse of her national origin (Russian) in violation of Title VII.
11. The acts complained of in paragraph 7 above were intentional. 12. The unlawful employment praetiee~ complained of in paragraph 7 (a) through (i) above were done with malice or with reek_less indifference to the federally protected rights o fNatalia Vistinis.
4

Case 2:06-cv-O2873-WY Document 1 Filed 06/30/2006 Page 5 of 7
PRAYER F0=R= RELIF-F Wherefore, the Commi~ion respectfully requests that this Court:
A. Grant a permanent injunction enjoining Defends_nt Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of national origin.
B, Order Defendant Employer to institute and carry out policies, practices, ~d program s which provide equal employment opportunities and which provide for a work environment free of discrimination, and which eradicate the effects ofitspast and present unlawful employment practices.
C, Order Defendant Employer to institute and carry out anti-discrimination policies and compl~dnt procedures.
D. Order Defendant Employer to institute and carry out complaint procedures which encourage employees to come forward with complaints regarding violation of its policies against national origin discrimination,
E. Order Defendant Employer to institute and carry oat a training program which shall promote supervisor aceotmtability imposing on all managers and supervisory personnel a duty to actively monitor their work areas to ensure compliance with policies on non-discrimination; and requiring all managers and supervisors to report shy incidents and/or complaints of discrimination of which they become aware to the department charged with handling such complaints.
F. Order Defendant Employer to make whole Nstalia Vistinis by pro viding appropriate back pay with prejudgment interest, m amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlzwfuI employment practices.

Case 2:06-cv-O2873-WY Document 1 Filed 06/30/2006 Page 6 of 7
G. Order Defendant Employer to make whole Natalia Vistinis by providing compensation for past and pecuniary losses resulting from the unlawful employment practices described in paragraphs 7(a) through (h), including but not limited to out of pocket losses, in amounts to be determined at trial.
H. Order Defendant Employer to make whole Natalia Vistinis by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of m paragraphs 7(a) through (h), including pain and suffering, humiliation, embarrassment, anxiety and inconvenience, in amounts to be determined at trial.
Grant such further relief as the Court deems necessary and proper in the public interest.
K. Award the Commission the costs of this action.

Case 2:06-cv-O2873-VVY Document 1 Filed 06/30/2006 Page 7 of 7
yLTRy TRZAL DEMAND The Commission r~uests a jury trial on all qaostions of fact raised by its complaint.
James L. Lee Deputy General Counsel Gw~ndolyn Young Reams Associate General Counsel Washington, D.C. EQUAL EMPLOYMENT OPPORTUNITY
mbrm A. O’BO’ LE
Supervisory Trial Attorney
R_A~IEL ~ SMITH -Trial Attorney U.S. EEOC, Philadelphia D~$~¢t Office 21 S. 5~ S~t, Suite 400 Phil~eIphi~ PA 19106 (215) 440-2642 (direr) (215) ~0-2828(f~)

 
 UNITED STATES DISTIUCT COURT EASTERN DISTRICT OF PENNSYLVANIA

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Plaintiff,
v.
ROSS STORES, INC. Defendant.

1 1

)

Civil Action No. 06- 2873

)
1

1

CONSENT DECREE

1

1

INTRODUCTION
A. This action was instituted by the United States Equal Employment Opportunity Commission (the "EEOC" or the "Commission") on or about June 30, 2006 against Ross Stores, Inc. under Title VII of the Civil Rights Act of 1964 and Title 1 of the Civil Rights Act of 1991 ("Title VII"). The EEOC alleged that Defendant Ross Stores, Inc., ("Ross Stores" or "Defendant"), discriminated against Natalia Vistinis because of her national origin, Russian, when Defendant unlawfidly denied her a pay raise after a promotion. As a result of the allegedly unlawful failure to properly promote, the EEOC alleged that Ms. Vistinis suffered income losses as well as emotional distress damages. B. This Consent Decree is entered into by the EEOC and Defendant Ross Stores. This Consent Decree shall be final and binding between the EEOC and Defendant Ross Stores, its directors, officers, agents, employees, successors or assigns and all persons in active concert or participation with it, (hereinafter collectively referred to as ("Ross Stores" or "Defendant")). C. The Commission and Defendant do hereby agree to the entry of this Consent Decree, which shall fully and finally resolve all claims which were raised by the EEOC in its Complaint in Civil Action No. 06-CV-2873. This Consent Decree shall not constitute an adjudication of or

finding on the merits of the case and shall not be construed as a violation of Title VII by Ross Stores, which in fact Ross Stores denies.
Upon consent of the parties to this action, it is hereby ORDERED, ADJUDGED and DECREED that:
NON-DISCRIMINATION AND NON-RETALIATION 1. This Court has jurisdiction over the parties and the subject matter of this action. 2. Defendant is enjoined from engaging in any employment practices which retaliate in any manner against any person, including but not limited to, Natalia Vistinis, because of that person's opposition to any practice alleged or believed to be unlawful under Title VII or because of the filing of a charge, the giving of testimony or assistance, or the participation in any manner in any investigation, hearing or proceeding under Title VII. 3. Defendant shall not divulge, directly or indirectly, except as required by law, to any employer or potential employer of Natlia Vistinis, any of the facts or circumstances related to her charge of discrimination against Defendant, or any of the events relating to her participation in the litigation of this matter. 4. Ross Stores shall expunge from the personnel files of Natalia Vistinis any documents and/or related papers pertaining to the charge of discrimination filed by Natalia Vistinis with the Commission. 5. Defendant shall comply fully with all provisions of Title VII. Nothing in this Consent Decree, either by inclusion or exclusion, shall be construed to limit the obligations of Defendant under Title VII or the EEOC's authority to process or litigate any charge of discrimination which may be filed against Ross Stores in the future.

MONETARY RELIEF 6. Defendant agrees to pay monetary relief in the total amount of $20,000.00, subject to tax withholding obligations, to Natalia Vistinis in full settlement of the claims against Defendant which were raised in the Commission's Complaint. If Ross Stores does not comply and fails to pay the designated amount set forth in this Paragraph, the Court will enter a judgment for the entire amount remaining due, plus costs, and interest to be paid at the legal rate, compounded daily. The check should.be mailed to Natalia Vistinis at the following address: 115 Silve Street, Silverdale, PA 18962, by certified mail, return receipt requested. Defendant will mail a photocopy of each check to the EEOC, to the attention of Rachel M. Smith, Trial Attorney, EEOC, The Bourse, 21 South Fifth Street, Suite 400, Philadelphia, PA 19106-2515, within five days of the date of mailing the check to Ms. Vistinis.
POSTING OF NOTICE 7. Within ten (10) business days after entry of this Decree, or as soon as practicable, Ross Stores shall post same-sized copies of the Notice attached as Exhibit 1 to this Decree on all bulletin boards located at its Lansdale, PA facility usually used by Defendant for communicating with employees. The notice shall remain posted for one (1) year from the date of entry of this Decree. Counsel for Ross Stores shall provide a copy of the Notice, and an indication of the date and location of its posting, to the EEOCYsPhiladelphia District Office, attention, Rachel Smith, Trial Attorney, within ten (10) days of the posting. Defendant shall permit a representative of the EEOC to enter Defendant's premises for purposes of verifying compliance with this Paragraph at any time during normal business hours with prior notice. Defendant shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other

material. Should the posted copies become defaced, removed, marred, or otherwise illegible, Ross Stores agrees to as soon as practicable post a readable copy in the same manner as hereto specified.
NON-DISCRIMINATION POLICIES AND COMPLAINT PROCEDURES 8. Ross Store's policy or policies against discrimination and complaint procedures shall be drafted in plain and simple language. Ross Stores shall ensure that its policy or policies against discrimination and related complaint procedures meet the following minimum criteria: (a) State that Ross Stores: (i) prohibits discrimination against employees on the basis of national origin; and (ii) prohibits retaliation against employees for opposing employment practices they reasonably believe are discriminatory or for participating in an investigation by the EEOC or a state or local governmental agency of a charge of discrimination under Title VII; (b) Include a complaint procedure designed to encourage employees to come forward with complaints regarding violations of its policy or policies against discrimination which shall meet the following minimum criteria: (i) provide effective mechanism(s) for reporting incidents of discrimination and retaliation; (ii) provide that the complaints of discrimination can be made either in writing or verbally; (iii) identify employees to whom an employee can make a complaint; (iv) encourage prompt reporting by employees; and (v) provide assurances that complainants shall not be subjected to retaliation; (c) Provide for prompt investigation of complaints of discrimination; (d) Provide for prompt communication to the complaining party of the results of the investigation and any remedial actions taken or proposed; and (e) Provide for discipline up to and including discharge of an employee or supervisor

who violates Ross Stores" policy or policies against discrimination and for increasingly severe discipline of repeat offenders.
9. Ross Stores shall distribute to all of its employees and newly-hired employees at its Lansdale, PA facility, its policy or policies against discrimination and retaliation within 90 days after entry of this Consent Decree.
10. Within 90 days after entry of this Consent Decree, Ross Stores shall advise Rachel M. Smith, Trial Attorney, EEOC's Philadelphia District Office, that its policy or policies against discrimination have been distributed to current employees within the District in which Ms. Vistins worked via paycheck enclosure and that new employees will receive these policies by way of Ross Stores' Employee Handbook, with an opportunity to acknowledge receipt. Ross Stores will retain copies of any acknowledgment of receipt form for an employee in the employee's personnel file.
SUPERVISOR ACCOUNTABILITY 12. Ross Stores shall promote supervisor accountability by the following conduct:
(a) Providing annual anti-discrimination training to all of its supervisory and managerial personnel as set forth in Paragraph 13;
(b) Disciplining, up to and including discharge, any supervisor or manager who violates Ross Stores' policy or policies against discrimination;
(c) Imposing on all managers and supervisory personnel a duty to administer their work areas to ensure compliance with Ross Stores' policy or policies against discrimination; and

(d) Requiring all managers and supervisors to report any incidents and/or complaint of discrimination of which they become aware to the President of Ross Stores, a supervisor, or a manager.
TRAINING 13. Defendant shall provide training on the requirements of Title VII on the following terms: a. Defendant agrees to provide a training session in calendar year 2007, to all managers in the Ross Stores District in which Ms. Vistinis worked by a trainer or vendor approved by the EEOC to provide training on an employee's rights under Title VII, and the employer's obligations under Title VII, with an emphasis on what constitutes unlawful and differential treatment of employees of various national origins in the workplace, and how to keep Defendant free of such forms of discrimination; b. Each training session will include a presentation by a high ranking official of Ross Stores, emphasizing Ross Stores7commitment to prevent discrimination; c. Defendant shall first provide training in accordance with Paragraph 13(a) by no later than July 31,2007. 14. In addition to the training described in Paragraph 13, on a biennial basis, through at least 2009, Defendant will continue to provide training to all Managers and supervisors in its Human Resources Department who are responsible for workers employed at Ross Stores, regarding conducting a prompt and effective investigation into allegations, complaints, or charges of employment discrimination. 15. The training described in Paragraph 13 and 14 shall be provided by ELT, Inc., which the EEOC has approved.

17. Ross Stores shall certify to the EEOC in writing within five (5) business days
after the training has concluded that the training has taken place and that the required personnel have attended. Such certification shall include: (i) the dates and duration of the training session; and (ii) a copy of the registry of attendance, which shall include the name and position of each person receiving training.
DISPUTE RESOLUTlON 18. In the event that either party to this Decree believes that the other party has failed to comply with any provision(s) of the Decree, the complaining party shall notify the other party of the alleged non-compliance within ten (10) days of the alleged non-compliance and shall afford the alleged non-complying party ten (10) business days to remedy the non-compliance or to satisfy the complaining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged non-compliance within ten (10) business days, the complaining party may apply to the Court for appropriate relief.
MlSCELLANEOUS PROVlSlONS 19. Each party to this Decree shall bear its own expenses, costs and attorneys' fees. 20. The terms of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns, and successors of Defendant in their capacities as representatives, agents, directors and officers of Ross Stores, and not in their individual capacities. This Paragraph shall not be construed as placing any limit on remedies available to the Court in the event that any individual is found to be in contempt for a violation of this Decree. 21. This Consent Decree shall fully and finally resolve all claims which were raised by the EEOC in its Complaint in Civil Action No. 06-CV-2873.

22. This Consent Decree shall be filed in the United States District Court for the Eastern District of Pennsylvania and shall continue to be in effect for a period of two (2) years. Any application by any party to modify or vacate this Consent Decree during such period shall be made by motion to the Court on no less than thirty (30) days notice to the other party.
23. The Court retains jurisdiction over this case in order to enforce the terms of the Consent Decree.
24. The Clerk of the District Court is hereby directed to send a file-stamped copy of this Consent Decree to counsel of record.

For Plaintiff EEOC:
Ronald S. Cooper General Counsel
James L. Lee Deputy General Counsel
Gwendolyn Young Reams Associate General Counsel Washington, D.C. EQUALEMPLOYMENOTPPORTUNITCYOMMISSION

f ~ $ n kConley, Es
Littler Mendels ,P.C. Three Parkway 1601 Market Street, Suite 1400 Philadelphia, PA 19102-1321

facquel&e H. McNair Regional Attorney

4
~bdithA. 07Boyle Supervisory Trial Attorney
fu!df l ,&L,i&
dachel M. Smith Trial Attorney EQUALEMPLOYMENOTPPORTUNITCYOMMISSION Philadelphia District Office 21 S. 5th Street, Suite 400 Philadelphia, PA 19106

IT IS ORDERED:
BY THE COURT: WILLIAM H. YOHN UNITED STATES DISTRICT JUDGE

DATE:

EXHIBIT 1
NOTICE TO ALL ROSS STORES EMPLOYEES
This Notice is being posted pursuant to a Consent Decree entered by the Federal Court in EEOC, et al. v. Ross Stores Civil Action Number 06-2873 (E.D.PA), resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against Ross Stores ("Ross Stores").
Title VII of the Civil Rights Act of 1964, 42 U.S.C. Section 2000e, et seq., as amended, ("Title VII"), prohibits discrimination against employees and applicants for employment based upon race, color, sex, religion or national origin. Title VII further prohibits retaliation against employees or applicants who avail themselves of their rights under Title VII by engaging in protected activities, such as opposing employment practices believed to be discriminatory, filing a charge of discrimination andlor testifying or participating in a Commission investigation. The EEOC is a federal agency which investigates charges of unlawful employment discrimination. The EEOC has authority to bring lawsuits in Federal Court to enforce Title VII.
In its lawsuit, the EEOC alleged that Ross Stores discriminated against an employee because of her national origin, Russian, when Defendant allegedly denied her a pay raise after a promotion. The Defendant denies these allegations.
To resolve the case, Ross Stores and the EEOC have entered into a Consent Decree which provided, among other things, that: (1) Ross Stores paid monetary relief; (2) Ross Stores will not discriminate on the basis of national origin; (3) Ross Stores will not retaliate against any person because he or she opposed any practice made unlawful by Title VII, filed a charge of discrimination, participated in any Title VII proceeding, or asserted any rights under the Consent Decree; and (4) Ross Stores will train all employees at its Lansdale, PA facility regarding national origin discrimination and Ross Stores's policy prohibiting national origin discrimination.
If you believe you have been discriminated against, you may contact the EEOC at (215) 4402600. The EEOC charges no fees and has employees who speak languages other than English.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
This Notice must remain posted for one (1) year from the date below and must not be altered, defaced or covered by any other material. Any questions about this Notice or compliance with its terms may be directed to the: Regional Attorney, EEOC Philadelphia
District Office, 21 South sthStreet, Philadelphia, PA 19

By:

$ f ~ c h LBy:

For: kqu&~mployment

For:

Commission

 
 United States District Court Eastern District of Pennsylvania - Docket Report

Page 1 of 2

CLOSED, STANDARD
United States District Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:06-cv-02873-WY

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Date Filed: 06/30/2006

v. ROSS STORES, INC.

Date Terminated: 01/03/2007

Assigned to: HONORABLE WILLIAM H. YOHN, JR

Jury Demand: None

Cause: 42:1981 Civil Rights

Nature of Suit: 442 Civil Rights: Jobs

Jurisdiction: Federal Question

Plaintiff
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

represented by JACQUELINE H. MCNAIR EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 21 S. 5TH ST STE 400 PHILADELPHIA, PA 19106 215-440-2687 LEAD ATTORNEY ATTORNEY TO BE NOTICED

JUDITH A. O'BOYLE EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 21 S. 5TH ST STE 400 PHILADELPHIA, PA 19106 215-440-2687 Email: judith.oboyle@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

RACHEL M. SMITH EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 21 S. 5TH ST. STE. 400 PHILA, PA 19106 215-440-2688 Email: rachel.smith@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant

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United States District Court Eastern District of Pennsylvania - Docket Report

Page 2 of 2

ROSS STORES, INC.

represented by FRANK J. CONLEY LITTLER MENDELSON, P.C. THREE PARKWAY 1601 CHERRY ST., SUITE 1400 PHILADELPHIA, PA 19102 267-402-3010 Email: fconley@littler.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 06/30/2006 06/30/2006 06/30/2006 09/19/2006 09/20/2006
10/19/2006 01/03/2007

#

Docket Text

1 COMPLAINT against ROSS STORES, INC. , filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.(ks, ) (Entered: 06/30/2006)

1 Summons Issued as to ROSS STORES, INC.. Forwarded To: Counsel on 6/30/06 (ks, ) (Entered: 06/30/2006)

DEMAND for Trial by Jury by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. (ks, ) (Entered: 06/30/2006)

2 NOTICE of Appearance by FRANK J. CONLEY on behalf of ROSS STORES, INC. with Certificate of Service (CONLEY, FRANK) (Entered: 09/19/2006)

3 ORDER THAT THE DEFENDANT ROSS STORES, INC. SHALL FILE A RESPONSE TO PLAINTIFF'S COMPLAINT ON OR BEFORE 10/19/2006. SIGNED BY JUDGE WILLIAM H. YOHN JR. ON 9/20/06. 9/20/06 ENTERED AND COPIES MAILED AND E-MAILED. (jpd) (Entered: 09/20/2006)

4 ANSWER to Complaint together with of Defendant Ross Stores, Inc., ANSWER to Complaint together with of Defendant Ross Stores, Inc. by ROSS STORES, INC..(CONLEY, FRANK) (Entered: 10/19/2006)

5 CONSENT DECREE AND ORDER. SIGNED BY JUDGE WILLIAM H. YOHN JR. ON 1/3/07. 1/3/07 ENTERED AND COPIES MAILED AND E-MAILED.(jpd) (Entered: 01/03/2007)

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