Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 1 of 6
c:v- UNGARO~ C~l'JAGE~

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION
))9 7 - 6 5 3 1 EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION,

Plaintiff,

)

Civil Action No.

)

v.

)

COMPLAINT

)

QUADOMAIN RECREATION ASSOCIATION, INC.

)

JURY TRIAL DEMAND

)

'. ''

)

________________D_e_f_e_n_d_a_n_t_. _____

)
)

\ .

(~

--· ·.> \

NATURE OF THE ACTION

"' S' 1\

i

C)

This is an action under Title VII of the Civil Rights Adf1 of

1964 and Title I of the Civil Rights Act of 1991, to correct

unlawful employment practices on the basis of sex, and to make

whole Carmel Marengo, who was adversely affected by such practices.

Bernard Markowitz, as President of the Recreation Board, subjected

Ms. Marengo to a sexually hostile working environment.

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337, and 1345. This action is authorized and instituted pursuant to § 706 (f) (1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f) (1) and (3) ("Title VII") and § 102 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 Southern District of Florida, Fort Lauderdale Division.

Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 2 of 6
PARTIES 3. Plaintiff, Equal Employment Opportunity Commission (the "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 § 706 (f) (1) and (3) of Title VII, 42 U.S.C. § 2000e-5 (f) (1) and
( 3)
4. At all relevant times, Defendant, Quadomain Recreation Association, Inc. (the Employer), has continuously been a Florida corporation doing business in the State of Florida and the City of Hollywood and has continuously had at least fifteen employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of § 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, Carmel Marengo filed a charge with the Commission alleging violations of Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least May of 1993, Defendant Employer, engaged in unlawful employment practices at its Hollywood facility, in violation of § 703 (a) (1) of Title VII, 42 U.S.C. § 2000e-2 (a) (1). Defendant subjected Carmel Marengo to unwelcome sexual harassment which was sufficiently severe and pervasive to affect the terms and conditions of her employment and create a hostile and abusive work
2

Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 3 of 6
environment. Carmel Marengo was subjected to sexual harassment in the form of physical and/or sexually explicit remarks and requests, and the seeking of sexual favors. 8. The effect of the practices alleged in paragraph 7 has been to deprive Carmel Marengo of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex. 9. The unlawful employment practices alleged in paragraph 7 was intentional. 10. The unlawful employment practices alleged in paragraph 7 above was done with malice or reckless indifference to the federally protected rights of Carmel Marengo.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its owners, successors, assigns and all persons in active concert or participation with it, from engaging in sexual harassment and any employment practice which discriminates on the basis of sex. B. Order Defendant Employer to institute and carry out policies, practices and programs which provide equal employment opportunities for female employees, and which eradicate the effects of its past and present unlawful employment practices.
c. Order Defendant Employer to make whole Carmel Marengo, by
providing compensation for past and future non-pecuniary losses,
3

Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 4 of 6
resulting from the unlawful employment practices described in paragraph 7, including but not limited to emotional pain, suffering, loss of enjoyment of life, inconvenience, and humiliation in amounts to be determined at trial. D. Order Defendant Employer to pay Carmel Marengo punitive damages for its malicious or reckless conduct described in paragraph 7, in an amount to be determined at trial. E. Grant such further relief as the Court deems necessary and proper in the public interest. F. 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, C. GREGORY STEWART General Counsel ROSALIND D. GRAY Deputy General Counsel EVE G. LOWE Acting Regional Attorney THOMAS E. ELFERS Acting Supervisory Trial Attorney
SHONFIELD Senior Trial Attor Florida Bar No. 0988626 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
4

Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 5 of 6 Miami District Office One Biscayne Tower Two Biscayne Blvd. Miami, Florida 33131 Telephone: (305) 530-6003
5

Case 0:97-cv-06531-WPD Document 1 Entered on FLSD Docket 05/01/1997 Page 6 of 6

r;p~~~~~~~~~~i117f p=~ a ~ £ t by~ Un~ted c~U. ~rpose Tho JS44 <•••I co•er sheet ond the mformotion contooned hereon noother

or o

r

rules of court ThiS form, approved by the JudiCII/ Conference of the

St•tes in September 1974, il requ•red for the UH' of the

llxcopt • pro•Miod of initiattno the civil doeket

shoot. ISEE INSTRUCTIONS ON THE REVERSE OF THE FORM. I

I (a) PLAINTIFFS

DEFENDANTS

Equal Enployrrent <w:>rt:unity Crnmission

Qladanain Recreation Association, Inc.

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND lloiVOLVED

AITORNEYS (FIRM NAME, ADDRESS, AND T LEPHONE NUMBER)
Rachel Shonfield ( 305) 530-6003 EEOC, 1 Biscayne Tower, Suite 2700 2 S. Biscayne Blvd., MjanL FL 33131 (d) CIRCLE COUNTY WHERE ACTION AROSE: DADE MONROE BROWARD PALM BEACH, MARTIN,

AITORNEYS (IF KNOWN)
ST. LUCIE, INDIAN RIVER,

OKEECHOBEE, HIGHLANDS

IX 1 U.S. Government
Plaintiff
0 2 U.S. Government Defendant

(PlACE AN..: IN ONE 80.1: ONLY)
0 3 Federal Question (U S. Government Nol a Party)
0 4 Dlve,..lty (lndocate Cotozenship of Parties on llem Ill)

Ill. CITIZENSHIP OF PRINCIPAL PARTIES

11'\-'a All.a."' ONE-

(For Diversity Cases Only)

f<llll .....,~. N«> ONE aox ~DER..-TJ

PTF DEF

n

c.o rn

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Citizen ol Thia Stata

01 01

Citizen of Another Stata 02 02

Citizen or Subject of • Foreign Country

03 03

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Incorporated and Pi1Qctp.l
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IV. CAUSE OF ACTION ,crrE T><E us CIVIl srArun UNDER -0< •ou""" flUNG AHO WRITE A-· srAreweNT Of CAU9E. This i s an action Uliiet T i t l e VII ooNOrcrrEJURISOICTIONAl.STAruresUNL.EssOIVERSITY) of the Civil Rights Act of 1964, as arended, a:np-·~tl~-- I ~f the
Civil Rights Act of 1991 to correct unlawful enployrrent practices on the ~s g~ $x.

IVa. 3 days estimated (for both sides) to try entire case.

()'1

v. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY)

A CONTRACT
C 110 Insurance C 120 ~anne :::J 130 ........ Act 0 140 Negohabi<J lnSU\JIT>flf11 C:: 150 Recovery of Owoerpayment
& Entorcemenr of .I•Jdgrnent
CJ 151 Medtc.ate Act
B 0 152 Recovery ol Delouned Sruoent Loans IEliCI Veoterans)
B ::::J 153 R..,.ery ol O.orpaymenl of Veterans Be-neftts 0 160 Sloe~ Suds :::J 190 Other Conlrtc1 0 195 Contr.ct Product ~
A REAL PROPERTY
0 210 Land Condemnaloon
B ::::J 220 Forec-.re
::::l 230 Reno Le... & Eoectmeno
0 240 Toots 10 Und 0 245 Toot Proouct uabokly 0 2SJO AI Other Reo! P<operly

VI. ORIGIN

~ 1 Ongonal

0

Proceedong

A

TORTS

B FORFEITUREMNAITY

A IAHKRUPTCY

A RTMFA rTAT\11tS

PERSONAL INJURY 0 310 Airplane

p....,., PERSONAL INJURY

0 362

k1juty-

::::J 315 A.rplano P.oduct

Med MolprtctJce

l..lobi.ly
:::J 320 Aouul. Libel &

0 385 Pe<IO<WIIlfU'YProouct i.J&bollly

Slon<>er
:::J 330 F~ral Empioyers

0 368 ..._los Pe<sonal ln,ury Product

l..lobi.ly

i.J&bollly

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:::J M5 Manne Product
~ly
0350 0355 Product l.Jollollly

PERSONAL PROPEr.TY 0 370 Other Froud
B 03711iv!rolfllondlnQ
0 380 Other Pe<IO<W
Property o.n._

0360 Olhe<Pe<IO<W ln,ury

0 385 Property o.n._ Proouct u-.y

A CML RIGHTS

B PRISONER PETlTIONS

i441llollnQ 442 Employmenl
0443 HoulonQ/
AlxommodoiiOns
0 444 Woloro 0 440 Oihe< CMI A91ts

0 510 "'"""r'410 - · Senlenoo
Habeas ColpJs
0530 Generll 0535 Death Penalty
I*C 540 Mancllmus & oo-
0 550_civ1l Rlgbta
•A or 8

ES =~ ~;:~~ & Drug
D 625 Drug Related Seizure of
Pooperty 21 USC 881
D 630 Liquor Laws
0 640 R R & Trud<
C 650 ~rline Regs :::J660~~~~

0 690 Other

A

LABOR

-0710F~~rl.OI>orAct
BO 720 I.JiboriMgmt
0 730 I.Jibor/Mgmt Roc>onlnQ &

0

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...._, Ac1
0 790 Other Ubor

B0 791 Errc>i Reo Inc Secunty Act

0 422 AI>P.al 28 usc 1511

0

4

2283 usc-

157

A P'IIOPERTY RIGHTS

0 820 (A)pynghls 0 830 POiont 0 840 TrodetNII<

B SOCIAL SECURITY
0 M1 HIA (138511) 0 862 tiled< u.ng 18231 0 863 DKWC/DtWW (~)) 0 864 SSID Tille XVI
0 M5 RS1 (o005illll

A FEDERAL TAX SUITS
0 870 luH IUS. PWntil Of Del-}
0 871 IRS- Third Pony 26 usc 711(»

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0 950 c:or-•oy ol

---- * 0890 ON<~ *A or B

(PLACE AN x IN ONE BOX ONLY)

Transferred from

Appeal to Otstnct 0 7 Judge from

2 Removed from 03Remandedfrom 04 Refi.led 0 5 another distnct

0 8 Multidistrict

Magistrate

State Court

Appellate Court

(specify)

UtigatJon

Judgment

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTlON

COMPLAINT:

0 UNDER F.R.C.P 23

DEMAND$

Check YES only if dem811ded in complaint:

JURY DEMAN,D:

0 YES 0 NO

VIII. RELATED CASE(S) (See onstructions): IF ANY

JUDGE - - - - - - - - - - - - D O C K E T NUMBERt___ _ _ _ _ _ _ _ _ __

DATE

SIGNATURE OF

UNITED STATES DISTRICT COURT
S/F I·2 REV. 6/90

Date Paid: _ _ _ _ _ _ __ 11/ifp:_ _ _ __

 
 Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 1 of 8

c\-'\ ~. t'et.'?- '-·

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a'\ f~S \1 ~. 1IN THE_ UNITED STATES DISTRICT

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,u-.n 1"-t."'

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

Plaintiff,

)

)

v.

)

)

QUADOMAIN RECREATION

)

ASSOCIATION, INC.

)

)

________________D_e_f_e_n_d_a_n_t_. _____

) )

Civil Action No. 97-6531-CIV-DIMITROULEAS

CONSENT DECREE
The Plaintiff, the Equal Employment Opportunity Commission ("EEOC"), filed this action on April 30, 1997, alleging a violation of 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 basis of sex. The complaint alleged that the Defendant, Quadomain Recreation Association, Inc., violated the law when it failed to provide Carmel Marengo with a workplace free of unwelcome sexual harassment.
This Consent Decree is designed to resolve the disputes between the parties with regard to this lawsuit. This Consent Decree is being entered by mutual agreement of the parties solely for the purpose of settlement. It is understood and agreed that

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 2 of 8
this Consent Decree is a settlement of disputed claims, and that it shall not constitute an adjudication on the merits of this lawsuit and shall not be construed as an admission by Defendant of any violation of Title VII or any executive order, law, rule or regulation dealing with or in connection with sexual harassment or retaliation or of any other liability.
In consideration of their mutual promises, the EEOC and the Defendant agree as follows. 1. This Court has jurisdiction of the subject matter of this action and the parties. 2. Venue is proper. 3. Defendant, its officers, managers, employees, agents and partners, are permanently enjoined from engaging in any unlawful employment practices based on sex. 4. Defendant, its officers, managers, employees, agents and partners, are permanently enjoined from discriminating against any employee who opposes any of Defendant's practices which the employee believes to be a violation of Title VII; or who files a charge of discrimination with the EEOC alleging violation(s) of such statute; who cooperates with the EEOC in the investigation and/or prosecution of any charge of discrimination; or who cooperated in the investigation or prosecution of this case.
2

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 3 of 8
5. Defendant agrees, within 14 days from entry of the consent decree, to establish a written policy of compliance with Title VII of the Civil Rights Act of 1964 (Title VII) and a sexual harassment policy, with complaint procedures, acceptable to the EEOC. The policy will thereupon be given to all employees of Defendant, and to all other employees upon hire. 6. Defendant agrees to give every employee, including new hires, a fact sheet outlining the protections offered by the Americans With Disabilities Act, Title VII of the Civil Rights Act of 1964, the Age Discrimination Act of 1965, and the Equal Pay Act. 7. In order to further ensure the effective implementation of Defendant's nondiscrimination policy, Defendant agrees to conduct training on prevention of sexual harassment, plus an overview of the other types of discrimination protected against by Title VII, ADEA, ADA, and the EPA, for all of its managers within 30 days after establishment and distribution of the sexual harassment policy, as referenced in paragraph 5. This training shall be provided by the EEOC or another organization approved by the parties and shall last at least 3 hours. Defendant agrees that 30 days after this training session, it will provide the EEOC with a list of the names of the employees in attendance at the training session, the specific subject discussed, and the date of the
3

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 4 of 8

training session. Defendant also agrees to provide the EEOC with

at least two weeks notice before it conducts its training session

and to provide copies of the training materials to the EEOC.

Defendant agrees to allow the EEOC, within EEOC's discretion, to be

in attendance at any such training session.

8. Defendant agrees to post within seven days from the date of

execution of this Consent Decree the notice attached hereto as

Exhibit A.

a. Said notice shall be posted for three years on the

bulletin board located by the employee time clock.

b. At the end of each six month period following the

execution date of this order, Defendant will certify in writing to

Plaintiff whether the notice has remained posted for the entire

preceding six month period.

9. Defendant agrees to provide, in writing, to Plaintiff the

names, addresses, phone numbers and employment status, including

job title, of each employee at Quadomain who has reported that s/he

has been sexually harassed.

Defendant will also provide

information on any investigation of sexual harassment that have

been initiated and the results of such investigation. Such

information shall be reported to the Plaintiff at the expiration of

each six month period, following the execution date of this order.

4

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 5 of 8
All reports will be mailed to the EEOC, 1 Biscayne Tower, Suited 2700, Miami, FL 33131, Att: Rachel Shonfield. 10. Defendant hereby agrees to pay Carmel Marengo $17,000.00, as a payment of compensatory and punitive damages. 11. Within 14 days after the entry of the Court's Order, Defendant will mail, certified mail return receipt, a check for the amount referred to in paragraph 10 to Carmel Marengo at 777 NW 103 Terrace, Pembroke Pines, FL 33026. Concurrent with the mailing of the check, Defendant agrees to copy Plaintiff on the mailing and the certified return receipt. 12. If the Defendant fails to tender the above-mentioned payment, the Defendant shall:
(a) pay interest on the defaulted payment at the rate calculated pursuant to 26 U.S.C. Section 6621(b) until the same is paid; and
(b) bear any additional costs incurred by the EEOC caused by the non-compliance or delay of the Defendant.
13. Defendant agrees to maintain employment applications and such other records as required by Title VII. 14. The terms of this Consent Decree are binding upon any successors, assigns or trustees of the parties. 15. The Court shall retain jurisdiction of this cause for a period
5

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 6 of 8

of three years to monitor this Consent Decree. At the end of three

years, this Decree will expire unless one of the parties petitions

to have it extended.

16. This Consent Decree is designed and entered into by the

parties to fully resolve all claims brought by the EEOC in the

above captioned lawsuit. Nothing in this Consent Decree shall

preclude the EEOC from bringing suit to enforce the terms of this

Judgment; nor shall this Judgment preclude future action by the

EEOC or other persons to remedy any other alleged violations of

Title VII by claims unrelated to Civil Action No. 97-6531-CIV-

DIMITROULEAS. Notwithstanding, all claims relating to the action

are extinguished.

~rt &.., <AcPe~-JJc. ~,

~}

DONE AND ORDERED in Chambers at Mi~, Florlda, this ~

day of August, 1998.

\0\Q~~h!l
WILLIAM P. DIMITROULEAS United States District Judge

Agreed:
FOR THE PLAINTIFF: UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
C. GREGORY STEWART General Counsel

6

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 7 of 8
GWENDOLYN Y. REAMS Associate General Counsel DELNER FRANKLIN-THOMAS Regional Attorney EVE G. LOWE Supervisory Trial Attorney
by: Rachel H. Sho field Senior Trial A torney Florida Bar Number 988626 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Two South Biscayne Blvd. Suite 2700 Miami, Florida 33131 (305) 530-6003 (305) 530-6000
FOR THE DEFENDANT:
P.A. 1390 Brickell Ave. 3rd Floor Miami, FL 33131
7

Case 0:97-cv-06531-WPD Document 27 Entered on FLSD Docket 09/02/1998 Page 8 of 8
EXHIBIT A NOTICE
This notice is being posted as part of a Consent Decree entered by the Court in EEOC v. Ouadomain Recreation Association, Civil Action No. 97-6531-CIV-MIDDLEBROOKS. The Consent Decree was entered into by mutual agreement of the parties. As part of the Consent Decree, The Quadomain Association, has agreed that it will not discriminate against employees in violation of Title VII of the Civil Rights Act of 1964 ("Title VII"). Furthermore, Quadomain, assures its employees that it supports Title VII and will not take any action against an individual because he/she has exercised his/her rights under the law to oppose discriminatory acts or to file charges with the EEOC.
This notice shall remain posted for three years from the date signed.
Employees or applicants for employment who have questions about their rights under Title VII or any other federal antidiscrimination law may telephone the Miami District Office of the Equal Employment Opportunity Commission toll free at 1-800-6694000 or (305) 530-6001.
Signed this do+f day of __J~u~~~f-----' 1998.
LEho~
QUADOMAIN RECREATION ASSOCIATION, INC.

 
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U.S. District Court Southern District of Florida (Ft. Lauderdale) CIVIL DOCKET FOR CASE #: 0:97-cv-06531-WPD

CLOSED

Equal Employment v. Quadomain Recreation Assigned to: Judge William P. Dimitrouleas Demand: $0 Cause: 28:0451 Employment Discrimination

Date Filed: 04/30/1997 Jury Demand: None Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Rachel H. Shonfield Equal Employment Opportunity Commission Miami District Office 2 S Biscayne Boulevard 2700 One Biscayne Tower Miami, FL 33131-2483 305-530-6007 LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Defendant
Quadomain Recreation Association, Inc.

represented by Nancy C. Valcarce Walton Lantaff 9350 S Dixie Highway 10th Floor Miami, FL 33156 305-671-1300 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 04/30/1997 04/30/1997
04/30/1997
05/20/1997

#

Docket Text

1 COMPLAINT filed; A-7; RLD (dp, Deputy Clerk) (Entered: 05/01/1997)

Magistrate identification: Magistrate Judge Robert L. Dube (dp, Deputy Clerk) (Entered: 05/01/1997)

2 SUMMONS(ES) issued for Sol Helitzer, Registered Agent for Quadomain Recreation (dp, Deputy Clerk) (Entered: 05/01/1997)

3 ORDER set scheduling conference for 9:30 8/22/97 before Judge Ursula Ungaro-Benages ( signed by Judge Ursula Ungaro-Benages on 5/15/97) CCAP (Former Deputy Clerk) (Entered: 05/30/1997)

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06/05/1997 06/16/1997 06/23/1997
06/30/1997 07/15/1997 07/15/1997 07/18/1997 08/04/1997 08/05/1997
08/08/1997 08/13/1997 08/13/1997 08/20/1997
08/21/1997 08/21/1997 08/22/1997

4 RETURN OF SERVICE executed for Quadomain Recreation on 5/27/97 Answer due on 6/16/97 for Quadomain Recreation (tb, Deputy Clerk) (Entered: 06/23/1997)
5 MOTION by Quadomain Recreation to extend time to file response to plaintiff's complaint (tb, Deputy Clerk) (Entered: 06/25/1997)
6 ORDER granting [5-1] motion to extend time to file response to plaintiff's complaint set answer due for 6/30/97 for Quadomain Recreation ( signed by Judge Ursula Ungaro-Benages on 6/23/97) CCAP (Former Deputy Clerk) (Entered: 07/07/1997)
7 ANSWER to Complaint by Quadomain Recreation (Attorney Nancy C Valcarce), (tb, Deputy Clerk) (Entered: 07/10/1997)
8 ORDER transferring case ( signed by Judge Ursula Ungaro-Benages on 7/15/97) CCAP (tb, Deputy Clerk) (Entered: 07/17/1997)
CASE reassigned to Judge Donald M. Middlebrooks (tb, Deputy Clerk) (Entered: 07/17/1997)
9 MOTION by Equal Employment to strike insufficient defense (tb, Deputy Clerk) (Entered: 07/25/1997)
10 MOTION by Quadomain Recreation to extend time to file response to plaintiff's motion to strike (Former Deputy Clerk) (Entered: 08/07/1997)
11 ORDER granting [10-1] motion to extend time to file response to plaintiff's motion to strike Response to motion reset to 8/13/97 for [9-1] motion to strike insufficient defense ( signed by Judge Donald M. Middlebrooks on 8/5/97) CCAP (Former Deputy Clerk) (Entered: 08/07/1997)
12 STATUS REPORT by Equal Employment, Quadomain Recreation (Former Deputy Clerk) (Entered: 08/13/1997)
13 RESPONSE by Quadomain Recreation to [9-1] motion to strike insufficient defense (Former Deputy Clerk) (Entered: 08/18/1997)
13 MOTION by Quadomain Recreation for leave to amend [7-1] answer (Former Deputy Clerk) (Entered: 08/22/1997)
14 ORDER granting [9-1] motion to strike insufficient defense, granting [13-1] motion for leave to amend [7-1] answer on or before 9/9/97 (signed by Judge Donald M. Middlebrooks on 8/20/97) CCAP (Former Deputy Clerk) (Entered: 08/22/1997)
Scheduling conference held (Former Deputy Clerk) (Entered: 08/25/1997)
Status conference held (Former Deputy Clerk) (Entered: 08/25/1997)
15 Minutes of scheduling and status conferen held before Judge Donald M. Middlebrooks on 8/21/97; set calendar call for 1:15 8/26/98 before Judge Donald M. Middlebrooks , set discovery due for 5/18/98 , set pretrial

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08/22/1997
08/22/1997 08/22/1997
09/09/1997 09/09/1997 12/19/1997 12/19/1997
01/05/1998 06/02/1998
06/02/1998 06/25/1998 07/21/1998

conference for 9:00 8/11/98 before Judge Donald M. Middlebrooks , set Jury trial for 8/31/98 before Judge Donald M. Middlebrooks Court Reporter Name: Randy Belsvik (Former Deputy Clerk) (Entered: 08/25/1997)
16 SCHEDULING ORDER setting Deadline for filing of all motions by 6/17/98 Discovery cutoff 5/18/98; (signed by Judge Donald M. Middlebrooks on 8/21/97) CCAP (Former Deputy Clerk) (Entered: 08/25/1997)
17 ORDER referring case to mediation. 15 days to appoint mediator (signed by Judge Donald M. Middlebrooks on 8/21/97) CCAP (Former Deputy Clerk) (Entered: 08/25/1997)
18 NOTICE of Hearing: set Jury trial for 9:00 8/31/98 before Judge Donald M. Middlebrooks , set pretrial conference for 9:00 8/11/98 before Judge Donald M. Middlebrooks , set calendar call for 1:15 8/26/98 before Judge Donald M. Middlebrooks (Former Deputy Clerk) (Entered: 08/25/1997)
19 AMENDED ANSWER and AFFIRMATIVE DEFENSES to Complaint by Quadomain Recreation : amends [7-1] answer (Former Deputy Clerk) (Entered: 09/10/1997)
20 NOTICE of Vacation from 9/15/97 to 9/26/97 by Quadomain Recreation (Former Deputy Clerk) (Entered: 09/10/1997)
21 MOTION with memorandum in support by Equal Employment to extend scheduling order deadlines (ra, Deputy Clerk) (Entered: 12/31/1997)
22 ORDER granting [21-1] motion to extend scheduling order deadlines, however trial date is not changed. Any dispositive motion must be filed by 7/1/98 (signed by Judge Donald M. Middlebrooks on 12/19/97) CCAP (ra, Deputy Clerk) (Entered: 12/31/1997)
23 STIPULATION by Quadomain Recreation In Re: substitution of counsel with Nancy Valcarce replacing David K. Tharp as counsel of record (wc, Deputy Clerk) (Entered: 01/09/1998)
24 ORDER reassigning case to the calendar of Judge William P. Dimitrouleas for all further proceedings ( signed by Judge Donald M. Middlebrooks on 6/1/98) CCAP (wc, Deputy Clerk) (Entered: 06/04/1998)
CASE reassigned to Judge William P. Dimitrouleas (wc, Deputy Clerk) (Entered: 06/04/1998)
25 NOTICE of unavailability from August 7, 1998 up to including August 19, 1998 by Quadomain Recreation (ea, Deputy Clerk) (Entered: 07/06/1998)
26 ORDER resetting Calendar call set for 10:00 9/4/98; Jury trial set for 9/8/98 (signed by Judge William P. Dimitrouleas on 7/21/98) CCAP (ea, Deputy Clerk) (Entered: 07/24/1998)

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27 CONSENT DECREE forr Quadomain Recreation, Equal Employment (signed by Judge William P. Dimitrouleas on 8/31/98 CCAP (mh, Deputy Clerk) (Entered: 09/02/1998)
CASE CLOSED. Case and Motions no longer referred to Magistrate. (ea, Deputy Clerk) (Entered: 10/02/1998)

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