IN THE UNITED STATES DISTRICT COJJ#$TIC'oxQC FOR THE SOUTHERN DISTRICT OF I L L I ~ S Y
EAST SAINT LOUIS DIVISION
Y

EQUAL EMPLOE'MENT OPPORTUNITY )

COMMISSION,

Plaintiff,

1

)

v.

1

1

JOE HOTZE FORD, INC.

1

)

)

Defendants.

)

CIVIL ACTION NO.
COMPLAINT JURY TRIAL DEMAND

--

NATURE OF THE ACTION

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

2000e et seq. ("Title VII"), and Title I of the Civil Rights Act of 1991,42 U.S.C. tj 198la, to

correct unlawfil employment practices on the basis of sex, and to provide appropriate relief to a

class of employees who were adversely affected by such practices. Plaintiff, the United States

Equal Employment Opportunity Commission ("EEOC" or "Commission"), alleges that

Defendants Joe Hotze Ford, Inc. ("Joe Hotze Ford") discriminated against Kristen Deyo

("Deyo"), Judy Giles ("Giles") and a class of female employees by subjecting them to

harassment because of their sex. This Commission also alleges that Defendant Joe Hotze Ford

constructively discharged Deyo and a class of female employees. This Commission also alleges

Defendant Joe Hotze Ford discriminated against Giles by retaliating against her by terminating

her after she opposed conduct in the workplace that violated Title VII.

JURISDICTION AND VENUE
1. Jurisdiction of this court is invoked pursuant to 28 U.S.C. $9 45 1, 1331, 1337,
1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(l) and (3) of
Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 5 2000e-5(f)(l) and (3), and Section 102 of the Civil Rights Act of 1991,42 U.S.C. 5 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 Southern District of Illinois, East St. Louis Division.
PARTIES 3. The EEOC is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring
this action by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. $5 2000e-5(f)(l) and (3).
4. At all relevant times, Defendant Joe Hotze Ford has continuously been and is now doing business in the State of Illinois and the City of Salem, and has continuously had at least fifteen (15) employees.
5. At all relevant times, Defendant Joe Hotze Ford 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. 5 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Deyo and Giles filed charges with the Commission alleging violations of Title VII by Defendant Joe Hotze Ford. All conditions precedent to the institution of this lawsuit have been fulfilled.

7. Since at least 2004, Defendant has engaged in unlawful employment practices at its dealership in Salem, Illinois, in violation of Section 703(a)(l) of Title VII, 42 U.S.C. tj 2000e2(a)(l). Such unlawful employment practices include, but are not limited to: subjecting Deyo, Giles and a class of female employees to harassment because of their sex; retaliating against Giles by terminating her employment after she opposed conduct protected by Title VII; and constructively discharging Deyo and a class of female employees.
8. The effect of the practices complained of in paragraph seven (7) above has been to deprive Deyo, Giles and a class of female employees of equal employment opportunities and otherwise adversely affect their status as employees because of their sex.
9. The u n l a h l employment practices complained of in paragraph seven (7) were and are intentional.
10. The unlawful employment practices complained of in paragraph seven (7) above were and are done with malice or with reckless indifference to the federally protected rights of Deyo, Giles and a class of female employees.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Joe Hotze Ford, 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 sex or race; B. Order Defendant Joe Hotze Ford to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices;

C. Order Defendant Joe Hotze Ford to make whole Deyo and a class of female employees by providing appropriate back pay with pre-judgment 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 Joe Hotze Ford to make whole Deyo and a class of female employees by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described above, in amounts to be determined at trial;
E. Order Defendant Joe Hotze Ford to make whole Deyo and a class of female employees by providing compensation for past and future non-pecuniary losses, including emotional pain, suffering, inconvenience, loss of enjoyment of life and humiliation, in amounts to be determined at trial;
F. Order Defendant Joe Hotze Ford to pay Deyo and a class of female employees punitive damages for its malicious andlor reckless conduct described 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.
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.

Respectfully submitted,
JAMES LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel EQUAL EMPLOYMENT OPPORTLTNITY
COMMISSION
Diane I. Smason Supervisory Trial Attorney
Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 500 West Madison Street Suite 2800 Chicago, Illinois 60661 (312) 353-7526

 
 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

Flle,D

EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION,
Plaintiff,
v.

Case No. 06-155

JOE HOTZE FORD, INC.

Judge William D. Stiehl Magistrate Judge Philip M. Frazier

Defendant. )

CONSENT DECREE

THE LITIGATION

1. On February 22, 2006, PlaintiffUnited States Equal Employment Opportunity

Commission (the "EEOC") filed its Complaint in this action alleging that Defendant Joe Hotze

Ford, Inc. ("Joe Hotze Ford" or "Defendant") violated Title VII of the Civil Rights Act of 1964

("Title VTI") and the Civil Rights Act of 1991 by subjecting Charging Parties Kristen Deyo

("Deyo"), Judy Giles ("Giles"), and a class of females employees to harassment because of their

sex; constructively discharging Deyo and a class of female employees; and retaliating against

Giles.

2. As a result of having engaged in comprehensive settlement negotiations, EEOC

and Jo'e Hotze Ford have agreed that this action should be finally resolved by entry of this

Consent Decree. This Decree fully and finally resolves any and all issues and claims arising out

of the Complaint filed by EEOC in this action.

FINDINGS 3. Having examined the terms and provisions of this Decree, and based on the pleadings, record, and stipulations of the parties, the Court finds the following:
A. This COUl1 has jurisdiction of the subject matter of this action and of the parties to this case;
B. The terms of this Decree are adequate, reasonable, equitable and just and the rights of the Charging Parties, the EEOC, Joe Hotze Ford, and the public interest are adequately protected by this Decree; and
C. This Decree conforms with the Federal Rules of Civil Procedure and Title VII, and is not in derogation of the rights or privileges of any person. The entry of this Decree will further the objectives of Title Vil and will be in the best interests of the Charging Parties, EEOC, Joe Hotze Ford, and the public.
NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: NON-DISCRIMINATION
4. Joe Hotze Ford, its directors, officers, agents, assigns, employees, and successors are permanently enjoined from (a) engaging in any employment practice which discriminates on the basis of sex; (b) engaging in or being a party to any action, policy or practice that is intended to or is known to them to have the effect of sexually harassing any female employee; andlor (c) creating, facilitating or tolerating the existence of a work environment that is sexually hostile to female employees.
5. Joe Hotze Ford, its directors, officers, agents, assigns, employees, and successors shall not retaliate in any way against any person because such person has opposed any practice
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made unlawful under Title VII, filed a Charge of Discrimination under Title VII, testified or

participated in any manner in any investigation, proceeding, or hearing under Title VII, or

asserted any rights under or benefited from this Decree.

MONETARY RELIEF FOR CLAIMANTS

6. Joe Hotze Ford shall pay monetary damages totaling $ 150,000.00 to Kristen

Deyo, Kathyrn Winchester, Elisha Charlton and Amanda Huelskoetter (referred to collectively as

"Claimants"). The division of the total monetaryreliefamong the Claimants is as follows:

Kristen Deyo

$75,000

Kathyrn Winchester

$30,000

Elisha Charlton

$30,000

Amanda Huelskoetter

$15,000

7. EEOC will mail a copy of the release agreement (attached hereto as Exhibit A) to

each Claimant. Each Claimant must execute and return a release agreement to EEOC. EEOC

will send to Joe Hotze Ford the executed release agreements it receives from the Claimants.

Within ten (10) business days after receipt by Joe Hotze Ford of the release agreements, Joe

Hotze Ford shall issue and mail by certified mail a check payable to each Claimant in the amount

set forth opposite her name above at the address for that Claimant provided to Joe Hotze Ford by

EEOC. Joe Hotze Ford shall also mail copies of the checks to EEOC.

POSTING OF NOTICE 8. Within five (5) business days following entry of this Decree, Joe Hotze Ford shall post a same-sized copy of the Notice signed by the Court (attached as Exhibit B to this Decree) in
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a conspicuous 10cation easily accessible to and commonly frequented by Joe Hotze Ford's employees for the duration of this Decree. Joe Hotze Ford shall ensure that the postings are not altered, defaced or covered by any other material. Joe Hotze Ford shall certify to EEOC in writing within ten (10) business days after entry of this Decree that the copies of the Notice have been properly posted and the location of each such posting. The Notices shall remain posted for a period of two (2) years from the date of entry of this Decree. Joe Hotze Ford shall permit a representative of EEOC to enter Joe Hotze Ford's premises for purposes of verifying compliance with this Paragraph at any time during nonnal business hours with reasonable prior notice.
TRAINING 9. Joe Hotze Ford shall provide training on the requirements of Title VII as follows:
A. Defendant shall retain and pay for an outside consultant/lecturer ("trainer"), approved by the EEOC, to provide training for all employees (both managerial and non-managerial) during each of the two (2) years covered by this Decree with respect to the prevention and eradication of sexual harassment from the workplace. Joe Hotze Ford shall conduct separate trainings for its owner, Joe Hotze.
B. The owner of Joe Hotze Ford, Joe Hotze, shall receive a minimum of eight (8) hours of individual training from the trainer on the prevention and eradication of sexual harassment from the workplace. The training shall include, but need not be limited to, a detailed discussion of sexual harassment law, the causes of sexual harassment, and the effect of sexual harassment on its victims. In addition to the individual training, Joe Hotze must attend the general training attended by the employees.

C. Joe Hotze Ford shall first provide training to all employees, including the

individual training for the owner, within ninety (90) calendar days of the entry of this Consent

Decree.

D. A registry of attendance for each training shall be retained by Joe Hotze

Ford for the duration of the Consent Decree.

10. Joe Hotze Ford shall obtain EEOC's approval of its proposed trainer prior to each

year's set of training sessions. Joe Hotze Ford shall submit the name, address, telephone number,

resume, and training proposal of the proposed trainer, including all materials anticipated to be distributed during the training, together with the date(s) of the proposed training sessions to

EEOC within thirty (30) calendar days prior to the first day of the proposed date(s) of training.

EEOC shall have fifteen (15) calendar days from the date of receipt of the information described

above to accept or reject the proposed trainer(s). In the event EEOC does not approve Joe Hotze

Ford's designated trainer(s), Joe Hotze Ford shall have thirty (30) calendar days to identify an

alternate trainer. EEOC shall have fifteen (15) calendar days from the date of receipt of the

information described above to accept or reject the alternate trainer. In the event EEOC does not

approve Joe Hotze Ford's alternate trainer, and the parties cannot agree upon a trainer, the

dispute shall be submitted to the Court for final resolution. After EEOC has approved of or

designated a trainer for one year, it is not required to approve 0 for designate the same trainer for future training sessions.

11. Prior to the trainings, the trainer shall be allowed to familiarize himselflherself with the allegations of this case by means of communicating with counsel for either party or

reviewing documents provided by counsel of either party. 12. Joe Hotze Ford agrees to provide EEOC with any and all copies of pamphlets,
brochures, outlines or other written materials provided to the participants of the training sessions. 13. Joe Hotze Ford shall certify to EEOC in writing within five (5) business days after
each required training has occurred that the training has taken place and that the required personnel have attended. Such certification shall include: a) the dates, location and duration of the trainings; b) a copy of the registry of attendance, which shall include the name and position of each person in attendance; and c) a listing of all current employees as of the date of the training.
COMPLAINT MONITOR 14. During the term of the Consent Decree, there shall be an independent Complaint Monitor, who will have the responsibility to investigate independently and confidentially any and all complaints of sexual harassment reported to Joe Hotze Ford or directly to the Complaint Monitor; make recommendations to Joe Hotze Ford regarding the appropriate disciplinary or corrective action to take to resolve a complaint of sexual harassment; and maintain detailed written records of all complaints of sexual harassment, the investigation ofsuch complaints, and the resolution of such complaints. 15. The Complaint Monitor shall be Lisa Yankowitz. In the event Lisa Yankowitz can no longer serve as the Complaint Monitor, Joe Hotze Ford shall have thirty (30) calendar days from the date it is notified that the Complaint Monitor will be unavailable to continue his/her duties for the duration of the Consent Decree to identify to EEOC by name, address, and telephone number a new independent Complaint Monitor. EEOC shall have fourteen (14)

calendar days from the date of receipt of the information described above to accept or reject the new Complain-t Monitor. In the event EEOC does not approve Joe Hotze Ford's proposed Complaint Monitor, Joe Hotze Ford shall have fourteen (14) calendar days to identify an alternate Complaint Monitor. EEOC shall have fourteen (14) calendar days from the date of receipt of the information described above to accept or reject the alternate Complaint Monitor. In the event that the pa11ies cannot agree upon a monitor, the dispute shall be submitted to the Court for final resolution.
16. Joe Hotze Ford shall notify the Complaint Monitor of all complaints of sexual harassment reported to Joe Hotze Ford and shall transmit to the Complaint Monitor all documentation of each such complaint reported to Joe Hotze Ford as soon as practicable and, in any event, no later than the close of the next business day after Joe Hotze Ford receives any such complaint.
17. Joe Hotze Ford shall inform all employees of the appointment and function of the Complaint Monitor, and each individual who makes a complaint (whether oral or written) to Joe Hotze Ford shall receive, upon making a complaint, a written notice informing himJher of the existence and function of the Complaint Monitor. Such notice shall provide the name, telephone number and address at which the Complaint Monitor may be reached.
18. Joe Hotze Ford shall fully cooperate with the Complaint Monitor in connection with hislher efforts to investigate complaints of sexual harassment, including providing prompt and reasonable access to employees, documents, and any other sources of information. The Complaint Monitor, as he/she deems it necessary or appropriate, shall have access all physical
7

locations within the dealership. 19. In the event the Coinplaint Monitor determines that any employee of Joe Hotze
Ford, including Joe Hotze, has engaged in sexual harassment, Joe Hotze Ford will take all necessary and appropriate remedial measures, as recommended by the Complaint Monitor. If Joe Hotze Ford determines that additional remedial measures beyond those recommended by the Complaint Monitor are necessary and appropriate, Joe Hotze Ford may take such additional remedial measures, but must at a minimum take the remedial measures recommended by the Complaint Monitor.
20. Joe Hotze Ford shall be responsible for compensating the Complaint Monitor at hislher full customary rate and shall pay any and all reasonable costs and expenses of the Complaint Monitor that the Complaint Monitor deems necessary or appropriate to fulfill hislher work as the Complaint Monitor.
RECORD KEEPING 21. For a period of two (2) years following entry ofthis Decree, Joe Hotze Ford shall maintain and make available for inspection and copying by the EEOC all documents and records which refer or relate to employee complaints regarding alleged sexual harassment made subsequent to the entry of this Decree. Such records shall include the name of the complainant, the date of the complaint, what was alleged, the names of any witnesses, what actions Joe Hotze Ford took to resolve the complaint, if any, and the resolution of the complaint. 22. Joe Hotze Ford shall make all documents or records referred to in Paragraph 21 above available for inspection and copying within ten (10) business days after the EEOC so

requests. In addition, Joe Hotze Ford shall make available all persons within its employ whom the EEOC reasonably requests for the purpose of verifying compliance with this Decree, and shall pennit the EEOC to enter Joe Hotze Ford's premises during regular business hours for such purpose on five (5) business days' advance business notice by EEOC.
23. Nothing contained in this Decree shall be construed to limit any obligation
Defendant may otherwise have to maintain records under Title vn or any other law or regulation.
REPORTING 24. Joe Hotze Ford shall furnish to EEOC the following reports semi-annually for a period of two (2) years following entry of the Decree. The first report shall be due six (6) months after entry of the Decree. The final report shall be due twenty-three (23) months after entry of the Decree. Each report shall contain:
A. A description of each complaint (oral or written) of sex harassment or discrimination and the resolution of such complaint, occumng within the six (6) month period preceding the report;
B. A certification by Joe Hotze Ford that the Notice required to be posted in Paragraph 8, above, remained posted during the entire six (6) month period preceding the report.
DISPUTE RESOLUTION 25. In the event that either party believes that the other party has failed to comply with any provisions of the Decree. the complaining party shall notify the alleged non-complying party in writing of such non-compliance and afford the alleged non-complying party fifteen (15) calendar days to remedy the non-compliance or satisfy the complaining party that the alleged
9

non-complying party has cOinplicd. lithe alleged non-complying party has not remedied the alleged non-compliance or satisfied the complaining party that it has complied within fifteen (15) calendar days, the complaining party may apply to the Court for appropriate relief.
DURATION OF DECREE AND RETENTION OF JURISDICTION 26. All provisions of this Decree shall be in effect (and the Court will retain jurisdiction of this matter to enforce this Decree) for a period of two (2) years immediately following entry of the Decree, provided, however, that if, at the end of the two (2) year period, any disputes under Paragraph 25. above, remain umesolved, the term of the Decree shall be automatically ex tended (and the Court will retain jurisdiction of this matter to enforce the Decree) until such time as all such disputes have been resolved. 27. If Joe Hotze Ford is sold or otherwise conveyed to an individual andlor entity with whom Joe Hotze has no personal, familial or financial relationship prior to expiration of the Consent Decree, EEOC will not oppose a motion filed with the Court by Defendant requesting an order terminating the Consent Decree if, after the sale is consummated, the following provisions are met:
A. The purchaser(s) andlor successor(s) shall submit to EEOC an affidavit from an individual authorized to bind the purchaser or successor and an opinion of counsel, both in form and substance acceptable to EEOC, to the effect that Joe Hotze has no financial, operational, or any other involvement in the successor dealership after the sale is consummated; and
B. Joe Hotze shall submit to EEOC an affidavit, both in form and substance

acceptable to EEOC, to the effecllhat Joe Hotze has no financial, operational, or any other involvement in the successor dClIlel'ship after the sale is consummated.
28. In the event that all of the provisions in Paragraph 27 are met, the termination of the Consent Decree shall take place no earlier than the date of the sale of Joe Hotze Ford is consummated.
29. In the event that all of the provisions in Paragraph 27 are met, Joe Hotze Ford must still comply with the individual training of Joe Hotze and the first annual training of all employees under Paragraph 9(B) and 9(C), respectively.
30. Under no circumstances will the monetary relief provisions in Paragraph 6 be terminated regardless of when. or if, Joe Hotze Ford is sold or conveyed.
MISCELLANEOUS PROVISIONS 31. The tel111S of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns and successors of Joe Hotze Ford. 32. Each party to this Decree shall bear its own expenses, attorney's fees, and costs. 33. If any provision(s) of the Decree are found to be unlawful, only such provision(s) shall be severed, and the remainder of the Decree shall remain in full force and effect. 34. When the Deere!.: requires the submission by Defendant of documents to the EEOC, they shall be mailed to: ;\;11'011 Decamp, Joe Hotze Ford Settlement, Equal Employment Opportunity Commission, Chi..:ago District Office, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661. When the Decree requires the submission by the EEOC of documents, they shall bemailedto:lamesF.Best.25E.WashingtonStreet.Suite210.Chicago.IL 60602.
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For the EQUAL EMPLOYMENT OPPORTUNITY COMMISSIO~
1801 L Street, N.W. Washington, D. C 10507

RONALD COOPER General Counsel

JAMES LEE Deputy General Counsel

For the EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 500 W. Madison St., Ste. 2800 Chicago, ll., 60661 (312) 353-
ey for laintiff EMPLOYMENT OPPORTUNITY
,",Hll.~SSION
icago District Office 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 Telephone: (312) 353-8551 Fax: (312) 353-8555 E-Mail: john.hendrickson@eeoc.~ov
~~~~
Diane 1. Smason ARDC # 6626130 Attorney for Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Chicago District Office 500 West Madison Street, Suite 231)0 Chicago, 111inois 60661 Telephone: (312) 353-7526 Fax: (312) 353-8555 E-Mail: diane.smason@eeoc.go\

~~~~~ aron R. DeCamp ARDC # 6282725 Attorney for Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Chicago District Office 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 Telephone: (312) 353-7582 Fax: (312)353-8555 E-Mail: aaron.decamp@eeoc.gov
12

For JOE HOTZE FORD, INC

JOE HOTZE
P.o. Box 340 Salam. 1162881
Ph.: (618) 548-1711 Fax: (618)548-6753 Einail: joehotze@yahoO.com

ENTER:

DATE:

e William D. Stiehl United States District Judge
The Honorable Judge Philip M. Frazier United States Magistrate Judge

13

EXHIBIT A

RELEASE In consideration for $ _ _ _ paid to me by Joe Hotze Ford, Inc., in connection with the resolution of EEOC v. .Ioe Hotze Ford. Inc., 06-155 (S.D. ILL.), I waive my right to recover for any claims of sexual harassment and/or constructive discharge arising under Title VII of the Civil Rights Act of 1964, -+:2 U.S.C. § 2000e et seq. and the Civil Rights Act of 1991, 42 U.S.C. §1981a, that I had against loe Hotze Ford prior to the date of this release and that were included in the claims alleged til EEOC's complaint in EEOC v. Joe Hotze Ford, Inc., 06-155.
Signature

EXHIBITB

NOTICE TO ALL JOE HOTZE FORD EMPLOYEES
This Notice is being posted pursuant to a Consent Decree entered by the federal court in EEOC v. Joe Hotze Ford. Inc., Case No. 06-155, resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against Joe Hotze Ford.
In its suit, the EEOC alleged that Joe Hotze Ford discriminated against female employees by subjecting them to a sexually hostile work environment, constructively discharging them, and retaliating against one of them. In its Answer, Joe Hotze Ford denied the allegations in the Complaint.
To resolve the claims against Joe Hotze Ford, Joe Hotze Ford and the EEOC have entered into a Consent Decree which provides, among other things, that:
1) Joe Hotze Ford will make a monetary payment to the claimants in the lawsuit;
2) Joe Hotze Ford is enjoined from discriminating against women on the basis of sex and from subjecting women to sexual harassment;
3) Joe Hotze Ford is enjoined from retaliating against any person because (s)he opposed any practice made unlawful by Title VII, filed a Title VII charge of discrimination or participated in any Title VII proceeding;
4) Joe Hotze Ford will provide mandatory training to all of its employees regarding sexual harassment, including individualized training to the owner, Joe Hotze.
EEOC enforces the federal laws against discrimination in employment on the basis of disability, race, color, religion, national origin, sex, and age. If you believe you have been discriminated against, you may contact EEOC at (312) 353-2713. 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 two (2) years from the date below and must not be altered, defaced of covered by any other material. Any questions about this Notice or compliance with its terms may be directed to: Joe Hotze Ford Settlement, EEOC, 500 West Madison Street, Suite 2800, Chicago, IL '06"61.

 
 CM/ECF - U.S. District Court:ilsd - Docket Report

https://ecf.ilsd.uscourts.gov/cgi-bin/DktRpt.pl?718173050828964-L_35...

CJRA_B, CLOSED
U.S. District Court Southern District of Illinois (East St. Louis) CIVIL DOCKET FOR CASE #: 3:06-cv-00155-WDS-PMF

Equal Employment Opportunity Commission v. Joe Hotze Ford, Inc. Assigned to: Judge William D. Stiehl Referred to: Mag Judge Philip M. Frazier Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 02/21/2006 Date Terminated: 02/09/2007 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Aaron R. DeCamp Equal Employment Opportunity Commission - Chicago, IL 500 West Madison Street Suite 2800 Chicago, IL 60661 312-353-7582 Fax: 312-353-8555 Email: aaron.decamp@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Diane I. Smason Equal Employment Opportunity Commission - Chicago, IL 500 West Madison Street Suite 2800 Chicago, IL 60661 312-353-7525 Email: Diane.Smason@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gwendolyn Y. Reams Equal Employment Opportunity Commission - St. Louis, MO 1222 Spruce Street Room 8.100 St. Louis, MO 63103 314-539-7915 LEAD ATTORNEY ATTORNEY TO BE NOTICED

James L. Lee Equal Employment Opportunity Commission - St. Louis, MO

1 of 5

6/5/2007 3:35 PM

CM/ECF - U.S. District Court:ilsd - Docket Report
V. Defendant Joe Hotze Ford, Inc.
2 of 5

https://ecf.ilsd.uscourts.gov/cgi-bin/DktRpt.pl?718173050828964-L_35...
1222 Spruce Street Room 8.100 St. Louis, MO 63103 314-539-7915 LEAD ATTORNEY ATTORNEY TO BE NOTICED
John C. Hendrickson Equal Employment Opportunity Commission Cook County 500 West Madison Street Suite 2800 Chicago, IL 60661 312-353-7525 LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Lori A. Vanderlaan Best, Vanderlaan et al. - Wheaton 1776 B South Naperville Road Suite 104 Wheaton, IL 60187 630-752-8000 Email: lvanderlaan@bestfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Aneta H. Pavlovich Best, Vanderlaan et al 25 East Washington Street Suite 210 Chicago, IL 60602 312-819-1100 Fax: 312-819-8062 Email: apavlovich@bestfirm.com ATTORNEY TO BE NOTICED
James F. Best Best, Vanderlaan et al. 111 East Wacker Drive Suite 3021 Chicago, IL 60601 312-819-1100 Email: jbest@bestfirm.com ATTORNEY TO BE NOTICED
6/5/2007 3:35 PM

CM/ECF - U.S. District Court:ilsd - Docket Report

https://ecf.ilsd.uscourts.gov/cgi-bin/DktRpt.pl?718173050828964-L_35...

Date Filed 02/21/2006 02/28/2006 03/01/2006 04/26/2006 05/15/2006 05/15/2006 05/15/2006 05/16/2006 05/16/2006 05/31/2006
06/07/2006
06/07/2006 06/16/2006 07/10/2006

#

Docket Text

1 COMPLAINT against Joe Hotze Ford, Inc. , filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(trb ) (Entered: 02/22/2006)
2 NOTICE of Appearance by Aaron R. DeCamp on behalf of Equal Employment Opportunity Commission (DeCamp, Aaron) (Entered: 02/28/2006)
3 NOTICE of Appearance by Diane I. Smason on behalf of Equal Employment Opportunity Commission (Smason, Diane) (Entered: 03/01/2006)
4 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Joe Hotze Ford, Inc. waiver sent on 3/15/2006, answer due 5/15/2006. (DeCamp, Aaron) (Entered: 04/26/2006)
5 STRICKEN AT DOCUMENT 8. NOTICE of Appearance by Lori A. Vanderlaan on behalf of Joe Hotze Ford, Inc. (Vanderlaan, Lori) Modified on 5/16/2006 (bkc). (Entered: 05/15/2006)
6 ANSWER to Complaint with Jury Demand by Joe Hotze Ford, Inc..(Vanderlaan, Lori) (Entered: 05/15/2006)
7 NOTICE by Joe Hotze Ford, Inc. re 6 Answer to Complaint (Vanderlaan, Lori) (Entered: 05/15/2006)
8 NOTICE STRIKING ELECTRONICALLY FILED DOCUMENTS No. 5 Entry of Appearance. See attached document for specifics. (bkc) (Entered: 05/16/2006)
9 NOTICE OF ERRORS AND/OR DEFICIENCIES re 7 Notice (Other) filed by Joe Hotze Ford, Inc. See attached document for specifics. (bkc) (Entered: 05/16/2006)
10 CJRA TRACK B assigned: Final Pretrial Conference set for 6/18/2007 at 1:30 PM in East St. Louis Court House before Judge William D. Stiehl. Jury Trial set for the presumptive trial month of July, 2007 in East St. Louis Court House before Judge William D. Stiehl. (skp) (Entered: 05/31/2006)
11 NOTICE of Scheduling and Discovery Conference set for 7/12/2006 09:15 AM before Judge Philip M. Frazier via telephone. Counsel for plaintiff is responsible for placing the conference call. The telephone number for the Court is 618-439-7750. Lead counsel must participate in the conference. (krm) (Entered: 06/07/2006)
12 ORDER REGARDING DISCOVERY. Signed by Judge Philip M. Frazier on 6/5/2006. (krm) (Entered: 06/07/2006)
13 NOTICE of Appearance by Lori A. Vanderlaan on behalf of Joe Hotze Ford, Inc. (Vanderlaan, Lori) (Entered: 06/16/2006)
14 NOTICE of Appearance by James F. Best on behalf of Joe Hotze Ford, Inc. (Best, James) (Entered: 07/10/2006)

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07/12/2006
07/13/2006 07/17/2006 08/28/2006 09/06/2006 11/13/2006 11/14/2006
12/06/2006 12/06/2006 02/09/2007

16 Minute Entry for proceedings held before Judge Philip M. Frazier: Scheduling and Discovery Conference held on 7/12/2006. Status Conference set for 11/13/2006 09:00 AM before Judge Philip M. Frazier. Counsel for plaintiff to initiate the conference call between the Court(618-439-7750) and counsel. In the interim, plaintiff is to locate and identify putative victims of the alleged discrimination. It is the Court's intention to select a date for a settlement conference during the hearing on 11/13/2006. (Court Reporter N/A.) (krm) Modified on 8/28/2006 (krm). (Entered: 07/17/2006)
15 NOTICE of Appearance by Aneta H. Pavlovich on behalf of Joe Hotze Ford, Inc. (Pavlovich, Aneta) (Entered: 07/13/2006)
17 SCHEDULING AND DISCOVERY ORDER: Discovery to be completed by 3/5/2007. Dispositive Motions to be filed by 3/23/2007. Signed by Judge Philip M. Frazier on 7/12/2006. (Attachments: # 1 Joint Report of Parties)(krm) (Entered: 07/17/2006)
18 NOTICE of Hearing: Discovery Dispute Conference set for 9/6/2006 11:00 AM via telephone before Judge Philip M. Frazier. Counsel for Plaintiff to initiate the conference call between the Court (618-439-7750) and counsel. (krm) TEXT ENTRY ONLY. NO DOCUMENT WILL BE MAILED. (Entered: 08/28/2006)
19 Minute Entry for proceedings held before Judge Philip M. Frazier: Discovery Dispute Conference held on 9/6/2006. Defendant to provide information by 9/15/2006. (Court Reporter N/A.) (krm) (Entered: 09/07/2006)
20 Minute Entry for proceedings held before Judge Philip M. Frazier: Status Conference held on 11/13/2006. Settlement Conference set for 12/6/2006 09:30 AM before Judge Frazier in Benton. Separate order to enter. (Court Reporter N/A.) (krm) (Entered: 11/13/2006)
21 ORDER FOR AND NOTICE OF SETTLEMENT CONFERENCE: Settlement Conference set for 12/6/2006 at 9:30 AM in U.S. Courthouse, Courtroom No. 2, 301 West Main St., Benton, Illinois, before Mag Judge Philip M. Frazier.Settlement Statements are to be submitted to Judge Frazier on or before 11/29/2006 (see instructions for submission in this order). Signed by Judge Philip M. Frazier on 11/14/06. (mta) (Entered: 11/14/2006)
22 ORDER that case has settled and giving counsel 60 days to consummate settlement. Vacating all Court dates. Signed by Judge William D. Stiehl on 12/6/06. (skp) (Entered: 12/06/2006)
23 Minute Entry for proceedings held before Judge Philip M. Frazier: Settlement Conference held on 12/6/2006; case settled; 60-day Order of Dismissal to enter. (Court Reporter N/A.) (mta) (Entered: 12/06/2006)
24 CONSENT DECREE executed by all parties. (See document for specifics) Signed by Judge William D. Stiehl on 2/9/07. (skp) (Entered: 02/09/2007)

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