Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 1 of 6

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IN TIlE UNITED STATES DISTRICf COURT FOR THE DISTRICT OF NEW JERSEY

EQUALEMPLOYMENTOPPOR~TY

)

COMMISSION,

)

)

Plaintiff,

)

)

>.

)

)

FAST BOLT CORPORATION,

)

)

)

Defendant.

)

)

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 and Title r of the Civil

Rights Act of 1991 to correct unlawful employment practices on the basis ofsex (pregnancy), and

to provide appropriate relief to Andrea Pitts who was adversely affected by such practices. AE,

alleged with greater particularity in pill"agraph 7 below, the Commission alleges that Defendant

Employer FllSt Bolt Corporation discriminated against Andrea Pitts because ofher sex (pregnancy)

when, shortly after notifying Defendant of her pregnancy, Ms. Pills' was teJUlinated from het:

employment. AE, a result of the di:;criminalion, Ms. Pitts suffered back pay losses and emotional

distress damages.

Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 2 of 6
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked PllIBuant to 28 U.S.C. §§ 451, 1331, 1337, 1343
and 1345. This action is authorized and instituted pursuant to 706 (f)(I) and (3) of Title VII of the Civil Rights Act ofl964, as amended, 42 U.S.C. §2000e·S(f)(I) and (3)("Title VII") and Section 102
of the Civil Rights Act of 1991, 42 U.S.c. § 1981"2. The employment practices alleged to be unlawful were committed wilhin the
jurisdiction of the United States District Court fur the District of New Jersey. PARTIES
3. Plaintiff, the Equal Employrnent Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enfun:ement of Title VII, and is expressly authorized to bring this action by Section 706(f)(I) and (3) ofTitle VII, 42 U.S.C. § 20DOe-S(f)(I) and (3).
4. At all relevant times, Defendant, Fast Bolt Corporation (Fast Bolt) (the "Employer"), has continuOU$ly been doing business in the State ofNew Jersey and the City ofHackensak, and has continuously had at least 15 employees.
5_ At all relevant times, Defendant Employer has continuoU$ly been an employer
engaged in an industry affecting comrnen:e within the meaning ofSectioru; 701(b), (g) and (b) of Title VII, 42 U.S.c. §§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior lD the institution of this lawsuit, Andrea Pitts filed 8. charge with the Cortunission alleging violatioru; ofTitle VII by Defendant Employer. All conditioru;
,

Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 3 of 6

precedent to the institution of !his lawsuit have been fulfilled.

7. Since at least on or about October 12, 2005, Defendant Employer has engaged in

unlawful employment practices Eft its Hackensack, New Jersey facility, by unIawfuHysubjecting Ms.

Pitts to discrimination because of her sex in violation ofSectiou 703(a)(1) of Title VII, 42 U.S.C.

§ 2000e-2(a)(1). These unlawful practices include, but are not limited to, !he following:

(a) In or about April 2004, Andrea Pitts began her employment with Defendant as a

temporary employee performing clerical duties as an office clerk.

(b) On orabont July 12, 2004, Defendant offered Ms. Pitts a permanent position as afile

clerk and as a fill-in receptionist, which she accepted.

(e)

Throughout Ms. Pitts' employment, Defendant advised her that her work wm;

satisfactory, and she never received any criticism of her performance or discipline.

(d) On or about October 4, 2004, Ms. Pitts informed Defendant's Manager that she was

pregnant.

(e) On or about October 8, 2004, Ms. Pitts advised Defendant's Manager that her

pregnsncywas a high risk pregnsncy, and as a result, she ueeded to undergo a medical procedure

on or about October 13, 2004. Ms. Pitts notified Defendant's manager that her medical procedure

required her to Ulke a week oft from won::, and Defendant's Manager approved Ms. Pius' request

for medical leave.

(n

On or about October 12, 2004, one day prior to Ms. Pius' scheduled medical

procedure, Defendant terminated her employment. Defendant informed Ms. Pitts that she was going

to be replaced by a part-time employee wbo was tben a bigh school student.

8. The effect of the practices complained of in paragraph 7(a)-(f) above bave been to 3

Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 4 of 6
deprive Andrea Pitts of equal employment opportunities and othe('Wise adversely affect her status as an employee, because of her sex.
9. The unlawful employment practices compl.a.ined orin paragraphs 7(a)-(f) abovewere intentional.
10. The unlawful employment practices compl.a.ined ofin paragraphs 7(a)-(f) above were done with malice or with reckless indifference to the federallyprotecled rights of Andrea Pitts.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoiningDefenrllmt Employer, il5 officers, successors, assigns, and all persons in active concert orpamcipalion with it, from engaging in sex discrimination any other eraployment practice which discriminates on the basis of sex. B. Order Defendant Employer to institute and carryout policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects ofits past and present unlawful employment practices. C. Order Defendant Employer to mBke whole Andrea Pitts, by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other aflim:w.tive relief necessary to eradicate the effects of its unlawful employment practices. D. Order Defendant Employer to make whole Andrea Pitts, by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 7(a) - (I) above, including job search expenses and medical benefits, in amounts to be determined at trial.

Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 5 of 6
E. Order Defendant Employer to mEike whole Andrea Pitts by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices oomplained of in paragraphs 7(a)-(f) above, including emotional pain, suffering, loss of enjoyment of life, and humiliation, in amounls to be determined at trial.
F. Onler Defendant Employer to pay Andrea Pitts punitive damages for its malicious and reckless conduct described in paragraphs 7(a)-(f) above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
H. Award the Commission its oosts of this action.

Case 2:05-cv-04325-FSH-PS Document 1 Filed 09/06/2005 Page 6 of 6
JURY TRIAL DEMAND The Commission requests ajury trial on all questions of fact raised by its complaint.
Respectfully submitted,
ERIC S. DREIBAND
General Counsel
JAMESL. LEE Deputy General Counsel
GWENDOLYN YOUNG RE,..MS
A&sociate General Counsel
J"6~. n~ Ol?y~ I
Supervisory Trial Attorney
1d&Wll~.~ DAWN M. EDGE Trial Attorney EQUALEMPLOYM£NT OrPORTUN1TyCOMMISSION Philadelphia District Office 21 South 5" Street, Suite 400 PhiiadelphiEl., PA 19106 (215)440·2687 (215)440-2848 (FAX)
6

 
 Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 1 of 9

Halsband & Ginsberg, LLP 39 Hudson Street, 4th Floor Hackensack, NJ 07601 (201) 487-6249 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY -------------------------------------------------X

ANDREA PITTS,

-against-

Plaintiff,

FAST BOLT CORPORATION and ROBERT LICHT,

Defendants. -------------------------------------------------X

COMPLAINT JURY TRIAL DEMANDED Civil Action No. 2:05-cv-04325 (FSH) (PS)

Plaintiff, Andrea Pitts, residing at 84 Stuyvesant Road, Teaneck, New Jersey 07666, by her attorneys, Halsband & Ginsberg, LLP, as and for her Complaint against the Defendants Fast Bolt Corporation and Robert Licht, alleges as follows:

Jury Demand 1. Plaintiff demands a trial by jury of all issues in this action.
Nature of Action 2. Plaintiff seeks to recover damages against Defendants Fast Bolt Corporation (“Fast Bolt”) and Robert Licht (“Licht”) for unlawful employment practices, in particular, discrimination and termination based upon Plaintiff’s gender and sex (pregnancy), and for unlawful retaliation against Plaintiff, in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000(e) et seq. (hereinafter, “Title VII”) and the New Jersey Law Against Discrimination, N.J.S.A. 10:5-1, et seq. (hereinafter, “NJLAD”).

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 2 of 9
Jurisdiction and Venue 3. This Court has subject matter jurisdiction over Plaintiff’s claims in this action pursuant to 28 U.S.C. § 1331, 1367, Title VII, and pursuant to principles of pendent jurisdiction. 4. Plaintiff timely filed a charge of discrimination against Fast Bolt with the Equal Employment Opportunity Commission (hereinafter “EEOC”). On June 13, 2005, the EEOC issued its Determination, finding, among other things, that Fast Bolt violated Title VII, in that Fast Bolt subjected the Plaintiff to unlawful pregnancy discrimination. In addition, on June 13, 2005, the EEOC issued its Notice of Right Sue with respect to the Plaintiff’s claims for retaliation under Title VII. 5. All conditions precedent to the institution of this lawsuit have been fulfilled. On September 6, 2005, the EEOC commenced an action against Fast Bolt in the United States District Court for the District of New Jersey. The name and civil action number of this lawsuit are Equal Employment Opportunity Commission v. Fast Bolt Corporation, 05-CV-04325. 6. Each of the Defendants reside, are found, transact business, have agents, and are within the jurisdiction of this Court for the purpose of service of process. 7. Venue is proper in this district pursuant to 28 U.S.C. § 1391.
Parties 8. Plaintiff Andrea Pitts is an adult female resident of the County of Bergen, State of New Jersey. 9. Upon information and belief, Fast Bolt is, and all times mentioned hereinafter was, a privately held domestic corporation duly licensed and authorized to do business pursuant to the laws of the State of New Jersey.
2

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 3 of 9
10. Upon information and belief, Fast Bolt has its principal place of business in South Hackensack, New Jersey, and employs 15 or more persons. At all times mentioned herein, Fast Bolt engaged in the business of making and/or distributing fasteners.
11. Fast Bolt is an “employer” subject to the requirements of Title VII, as defined in 42 U.S.C. § 2000e(b).
12. Fast Bolt is also an “employer” under the NJLAD. 13. Upon information and belief, Licht is currently a resident of the County of Bergen, State of New Jersey. 14. At all times mentioned herein, Licht was employed as a supervisor of Fast Bolt’s facility in Hackensack, New Jersey. 15. At all times mentioned herein, Licht was an employee, representative, and agent of Fast Bolt. 16. At all times mentioned herein, Licht was Plaintiff’s immediate supervisor. 17. At all times mentioned herein, Fast Bolt is responsible for the acts and actions of Licht, its supervisor, employee, agent and representative, under theories of respondeat superior and pursuant to case law.
Statement of Facts 18. In or about April 2004, Fast Bolt employed the Plaintiff as an office assistant at its office located at 200 Louis Street, South Hackensack, New Jersey. 19. At all times herein, the Plaintiff performed her duties competently and satisfactorily. 20. Fast Bolt did not issue the Plaintiff any written warnings about her work performance. 21. Fast Bolt did not issue the Plaintiff any verbal warnings about her work performance.
3

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 4 of 9
22. As a result of her satisfactory work performance, Fast Bolt made the Plaintiff a permanent employee on or about July 12, 2004.
23. On or about October 4, 2004, the Plaintiff advised her manager, Robert Licht, that she was pregnant.
24. On or about October 8, 2004, the Plaintiff further advised Licht that her doctor informed her that her pregnancy was high risk and that she needed a medical procedure on October 13, 2004 pertaining to her pregnancy. The Plaintiff also told Licht that she would need one week off from work for this medical procedure.
25. Licht approved the Plaintiff’s request for the one week of time off due to her pregnancy.
26. However, on October 12, 2004, Licht, Kim McLaughlin, Defendant’s Chief Financial Officer, and Ed Zavkas, Defendant’s Vice President, terminated the Plaintiff’s employment.
27. During the October 12, 2004 meeting, the Defendant told the Plaintiff that her work performance was entirely satisfactory, but that they suddenly preferred to have Licht’s son perform her job.
28. In response, the Plaintiff opposed what she perceived to be pregnancy discrimination. The Plaintiff asked the Defendants whether her pregnancy was the reason for this abrupt termination, which occurred only one week after she informed the Defendants of her pregnancy and one day before her medical procedure.
29. The Defendants abdicated their duty to investigate whether pregnancy discrimination was occurring and ignored her opposition to said discrimination. They affirmed their termination of the Plaintiff’s employment, in retaliation against the Plaintiff.
4

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 5 of 9
30. The real reason for the Defendants’ decision to terminate the Plaintiff was because the Defendants did not want to continue to employ her due to her pregnancy. Indeed, the Plaintiff would have been eligible for health and various other benefits from Fast Bolt only a few weeks later, in November 2004.
31. The effect of the unlawful employment practices complained of above has been to deprive the Plaintiff of equal employment opportunities and otherwise adversely affect her status as an employee, because of her sex.
32. The unlawful employment practices complained of above were intentional. 33. As a consequence of the foregoing, the Defendants harassed, retaliated against, and terminated the Plaintiff because of her pregnancy and her opposition to the Defendants’ discrimination and harassment, in violation of the Pregnancy Discrimination Act under Title VII and the NJLAD. 34. As a result of the Defendants’ unlawful actions, the Plaintiff has suffered lost pay and benefits, humiliation, embarrassment, and physical distress and mental anguish.
AS AND FOR PLAINTIFF’S FIRST CLAIM FOR RELIEF UNDER TITLE VII AGAINST FAST BOLT FOR UNLAWFUL DISCRIMINATION AND TERMINATION
35. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 36. By and through their course of conduct as alleged above, Fast Bolt and its agents willfully violated Title VII by harassing Plaintiff, denying her equal terms and conditions of employment, and terminating Plaintiff based on her pregnancy 37. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial.
5

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 6 of 9
AS AND FOR PLAINTIFF’S SECOND CLAIM FOR RELIEF UNDER TITLE VII AGAINST FAST BOLT FOR RETALIATION
38. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 39. By and through their course of conduct as alleged above, Fast Bolt and its agents willfully violated Title VII by terminating Plaintiff and harassing the Plaintiff in retaliation for her opposition to being denied equal terms and conditions of employment based on her pregnancy. 40. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial. AS AND FOR PLAINTIFF’S THIRD CLAIM FOR RELIEF UNDER THE
NJLAD AGAINST FAST BOLT FOR UNLAWFUL DISCRIMINATION AND TERMINATION
41. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 42. By and through their course of conduct as alleged above, Fast Bolt and its agents willfully violated the NJLAD by harassing Plaintiff, denying her equal terms and conditions of employment, and terminating Plaintiff based on her pregnancy. 43. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial.
AS AND FOR PLAINTIFF’S FOURTH CLAIM FOR RELIEF UNDER THE NJLAD AGAINST FAST BOLT FOR RETALIATION 44. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 45. By and through their course of conduct as alleged above, Fast Bolt and its agents willfully violated the NJLAD by terminating Plaintiff and harassing the Plaintiff in retaliation for her opposition to being denied equal terms and conditions of employment based on her pregnancy.
6

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 7 of 9
46. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial.
AS AND FOR PLAINTIFF’S FIFTH CLAIM FOR RELIEF UNDER THE NJLAD AGAINST LICHT FOR AIDING AND ABETTING UNLAWFUL DISCRIMINATION
47. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 48. By and through his course of conduct as alleged above, Licht willfully violated the NJLAD by aiding and abetting the unlawful discrimination against the Plaintiff based on her pregnancy. 49. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial.
AS AND FOR PLAINTIFF’S SIXTH CLAIM FOR RELIEF UNDER THE NJLAD AGAINST LICHT FOR RETALIATION 50. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 51. By and through his course of conduct as alleged above, Licht willfully violated the NJLAD by terminating Plaintiff and harassing the Plaintiff in retaliation for her opposition to being denied equal terms and conditions of employment based on her pregnancy. 52. As a consequence thereof, Plaintiff has been caused to suffer injuries and damages in amounts to be determined at trial.
PRAYER FOR RELIEF WHEREFORE, the Plaintiff prays that this Court:
(a) accepts jurisdiction over this matter; (b) impanels and charges a jury with respect to the claims for relief;
and (c) awards the following damages against Defendants:
7

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 8 of 9

i. Back pay, front pay, and all benefits along with pre and post judgment interest in amounts to determined at trial;
ii. Punitive, liquidated and compensatory damages including, but not limited to, damages for pain and suffering, anxiety, humiliation, physical injuries and emotional distress in order to compensate her for the injuries she has suffered and to signal to other employers that discrimination in employment is repulsive to legislative enactments in amounts to be determined at trial,
iii. Attorney’s fees, costs and expenses as provided for by the applicable statutes;
iv. Require Defendants to offer and, if accepted by Plaintiff, to reinstate her to the same position from which they discriminatorily terminated her; and,
v. Any other relief which this Court deems just and equitable.

Dated: Hackensack, New Jersey October 11, 2005

Respectfully submitted, HALSBAND & GINSBERG, LLP

By: s/Jyoti Mistry Halsband Jyoti Mistry Halsband (JH-9171) Attorneys for Plaintiff Andrea Pitts 39 Hudson Street, 4th Floor Hackensack, New Jersey 07601 (201) 487-6249

8

Case 2:05-cv-04325-FSH-PS Document 4 Filed 10/11/2005 Page 9 of 9 CERTIFICATION PURSUANT TO LOCAL RULE 11.2
I hereby certify that to the best of my information, knowledge and belief that the matter in controversy is not the subject of any other action pending in any court or of any pending arbitration proceeding or administrative proceeding.
HALSBAND & GINSBERG, LLP By: s/Jyoti Mistry Halsband
Jyoti Mistry Halsband (JH-9171) Attorneys for Plaintiff Andrea Pitts 39 Hudson Street, 4th Floor Hackensack, New Jersey 07601 (201) 487-6249
9

 
 Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 1 of 9 ,

EQUAL J2MPLOYMBNI OPI'ORTUNITV COMMISSION

LoCal Office

Newark Area Office I Newark Center, 21't floor

i

Newark, N J 07102·5233

[)awn M Edge 21 S. 5'" Slteet, Suite 400 Philadelphia, PA 19106 Counsel for Plaintiff'

IN THE UNITED STATES DISTRICT COlJRT FOR THE DISTRICT OF NEW JERSEY

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION )

)

Plaintiff,

)

)

~

)

)

F.ASTROLT CORPORATION,

)

)

Defendant.

)

Civil Action No. 05-4325 (FSH)

CONSENT DECREE
This action was instituted by the U.S. Equal Employment OppoItunity Commission ("the
EEOC" or "the Commission") on SeptembeI 6, 2005, against Fastbolt COlpOlation to enforce provisions of Title VI1 of tile Civil Rights Act of 1964, as amended, 42 U.s,C § 2000e et seq., ("Title Vll"). The EEOC filed this Title VII lawsuit on behalf of Andrea Pitts alleging that
Fastbolt Corporation discriminated against Ms. Pitts because of her sex (pregnancy) when, shortly aftet notifYing Defendant of her pregnancy, Ms, Pitts was terminated fi om her
employment
NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: I.. This Consent Decree is entered into by and shall be final and binding between the
EEOC and Defendant Fastbolt Corporation, its directors, officers, agents, employees, successors

...

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 2 of 9

01 assigns and all persons in active concert or participation with it, (hereinafter collectively refen'ed (0 as "Detendant" or "Fastbalt").,
NON·DISCRIMINATION AND NON~RETALIATION 2 This COUlt has jUlisdiction over the parties and subject matter ohhis action, 3, Ddendant, its owners, officen;, agents, employees, successors, assigns, and all persons in active concert 01 participation with it shall comply with all provisions o/Title VII and is enjoined fi:om any violations of Title VII Prohibited discrimination includes, bUl is not limited to, pregnancy 01 othcr disclimination because of sex, and/or conduct plotccted under Section 704(a) ofTilie VII 4 Fastbolt is enjoined flam engaging in any employment practices which retaliates against any person, including but not limited to Andrea Pitts, because of that person's opposition to any practice made an unlawful employment pmcticc WIder Title VII or because that person has made a charge, testified, assisted Ot participated in any m8lUlel' in an investigation, proceeding 01 hearing under litle VII 5.. Fastbolt shall not divulge, directly 01 indircctly, to any identifiable employer 01' potential employer of Andrea Pitts any of the facts or circumstances related to the claims of discrimination against Fastbolt in this case Ot any of the events relating to Ms. Pitts' participation in the litigation of this action unless compelled by legal process to do so or olherwise pursuant to court order.
NON.ADMISSION 6 TIIis Decree, bein,!l; entered with the consent of the EEOC and Defendant, shall not constitute an adjudication or fmding on the merits of tIlis case and shall not be constIUed as an admissio.n III liability by Defendant nOT as a disavowal by the EEOC of the allegations in the
2

'.

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 3 of 9

Complaint. Rather, this Decree i~ being entered into to avoid the further expense, inconvenience,

and distlaction of burdensome and protracted litigation and to compromise othlllwise disputed

claims.

MONETARY RELIEF

7. Defendant will pay to Andrea Pitts the amount of FOity Seven Thousand Five

Hundred DoHms and Zelo Cents ($47,500 . 00) in monetaty relief. Within ten (10) days of entry of this Decree by the COUll, Defendan! ~haJl forward the check made payable to "Halsband &,
Ginsberg, LLP as attomeys for Andrea Pitts" directly to Andrea Pitts' counsel. Defendant shall

simultaneously forwatd a copy of the check to the attomey of recOId fot'the Commission in this

case. An TRS Form 1099-Misc shall be issued to Andrea Pitts tor the calendar year, reflecting

the amoWlt of payment received in that yeat. EQUITABLE RELIEF

Defendant Fastbolt agrees to the following injunctive relief:

8 Within 20 business days aftlll entry of this Decree, Defendant agrees to post and

keep posted in conspicuous places upon its premises at its New Jetsey facility, where notices to

employees and applicants for employment a.re customatily posted, and maintain fOI four (4)

years fiom the date of posting, a copy of the attached Notice made II pmt hlllcofas Exhibit L

Said Notice is to be signed by II responsible official of Defendant and the date of actual posting

to be shown thetcon. Should the Notice become defaced, matted, 01 othelwise made

unreadahle, Defendant will ensure that a new readable copy of the Notice is posted in the same

matUleI as heretofol e specified.

3

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 4 of 9
TRAlNING 9, Fastbolt agrees to provide annual tJaining sessions, by a trainer 01 vendor applOved by the EEOC, on employee rights and employer obligations under both Title VII and relevant state or local anti.discrimination laws, which will emphasili:e what constitutes unlawful pregnancy disctimination in the workplace, how to keep the company flee flom such discrimination, what constitutes unlawful retaliation and will summari:£e how to conduct a plO1l1pt and effective investigation into allegations, complaints or chmges of discrimination to all ofits managers" supervisors, and Human Resoulces Department cmployees" 10 After entry of this Consent Decree, Fastbolt shall provide training in nccoldance with Paragraph 9 in calendal years 2006" 2007, 2008, and 2009. 11., Fastbolt agrees to ptovide the EEOC with copies of' all pamphlets, rooehules, Outline 01 other written mateda!s ptovidcd to attendees of training sessions, 12, Fastbolt agrees to notifY the Commj~sion as to the date of the training. and providc to Dawn M,. Edge, Esq, infolmation regarding the substantive content presented at the Halning aller the tmining is completed,
RECORD KEEPING 13., l'or a period of foul' YilWS following entry of this Dcclce, Fastbolt shall document and retain in a centlalized file in Human Resources records of each complaint of an incident of discrimination made by any employee, if any, !eflecting the date the complaint was made, who made it, what Wall alleged and the acti()ns, if any, Fastbolt took to resolve the mattel. Fastbolt also shall maintain records of all actions it takes to prevent discrimination at its New Jersey facility during the term of this Consent Decree
4

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 5 of 9
14, Fastbolt shall make all documents 01 records reterred to in f'atagraph 13 available fbI inspection and copying within 10 business days after the EEOC so leques~, and such inspection shall be conducted no more than once a yeat 01 when the EEOC believes that such inspection is reasonably necessaty" In addition, Fastbolt shall make available for interview all
persons in its employ whom the EEOC reasonably requests fOl purposes of verifying compliance
with this Decree and shall pcnuit a representative of the EEOC to enter Fastbolt premises fbI such pwposcs on ten business days advance notice by the EEOC and no mOle than one time in any given calendar year,
15, Nothing in this DeClee shall be constlued to limit any obligation Fastbolt otherwise may have to maintain records under Title VII 01 any other law or regulation" After
expiration ofthis Consent Decree, I'ecords will be maintained by Fastbolt as lequired by law and
COllJlll iss;on regulations,
DISPUTE RESOLUTION 16 In the event either patty to this Declee believes the othel party has failed to comply with any pi ovision(s) of the Decree, the complaining party shall notify the other party of
the alleged non-compliance within 20 days of the alleged non-compliance and afford the alleged non-complying paTty 20 business days to remedy the nun-compliance or satis(y the complaining party that the alleged non-complying party has complied., If the alleged non-complying party has not remedied the alleged non-compliance 01 satisfied the complaining party that it has complied within 20 business days, the complaining party may apply to the Court for apPlopriate relicf
,5

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 6 of 9
MlSCELLANEOUS PROVISIONS
17.. Each party to this DeClee shall beal' its own expenses, CO$ts atld attorney's fees 18. The terms of this Decree ale and shall be binding upon the present and future representatives, agents, directors, officers, successors atld assigns ot Fastbolt in their capacities as reprcsentatives, agents, dircctors and officel s of fo astbolt and not in theit individual capacities. Ihis paragraph shall not be conslrued as placing any limit on remedies available to the COllit in the event any individual is found in contempt fol' a violation ofthis Declee. 19. This Consent Decree shall fully and fmally resolve all claims which wer'e laised by the EEOC in its Complaint in Civil Action No. 05-cv-432S . 20. Ihis Consent Decree shall be filed in the United States District Cowt fox the District of New Jersey and shal! continue in effect for fOUl years.. Dllling this time, this COUlt shall retain jlliisdiction over this matter and the parties tOI' purposes of enforcing compliance with the Decree, including issuing such 01 del'S as may be required to effectuate its purposes. Any application by any party to modify or vacate this Consent Decree during such pedod shall bc made by motion to the COUlt on no less than 30 days notice to the oilier party Should any mateTial disputes under (his Deerce remain urnesolved aftcr this fOUl year period, the term of the Dccree shall be automatically extended (and the Court will Ietain jurisdiction of this mattel to entorce the Consent Decree) until such time as all disputes have been lesolved.
6

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 7 of 9 •

21 . The Clerk of the Distdct Court is hen:by directed to send a file-stamped copy of
this Consent Decree to counsel of record.

COUNSEL FOR PLAINIIF F
Jame~ L. Lee Deputy General Counsel
Gwendolyn Young Reruns Associate General Counsel US. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 L Street, NW Washington DC 20507

COUNSEL FOR DEFENDANT
atton, Esquire sel , Denlea, Packman, Catton & erzPC. 1311 Mamaroneck Avenue White Plains, New York 10605 (914) 517-5000
Daif~7)-=--.:D~~_

,./Jac eline H. McNnit ... Regional AttOlney
if:.ti~,~ ~~Cj..
~' Tri_ AUmnoy
DaWl1M~
Tdal Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Philadelphia Distdct Office 21 S. 5th Stleet, Suite 400 Philadelphia, PA 19106 (215) 440-2687

ByilicCourt: ~==;;~~~~~~~~LJ~~ FATI1I S. HOCHB G UNITED STATES DISTRICT JUDGE
7

Datc:

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 8 of 9
EXHIBIT-l

Case 2:05-cv-04325-FSH-PS Document 31 Filed 08/10/2006 Page 9 of 9

•

EQUAL

EMPLOYMENT

OPPORTUNITY

COMMISSION

POSTED PURSUANT TO A CONSENT DECREE BETWEEN THE EEOC AND FASTBOLT CORPORATION

This Notice is being posted pursuant to a Consent Decree entered by the federal court for the District of New Jersey
between the Equal Employment Opportunity Commission (EEOC) and Fastbolt Corporation styled EEOC v. Fastbolt Corporation, Civil Action Number 05-4325, which resolves an EEOC complaint alleging that Fastbolt subjected a female employee to pregnancy discrimination in violation of Title VII of the Civil Rigbts Act of 1964.

the authority to bring lawsuits in federal court to enforce Title VII.
Fastbolt Corporation pledges its commitment to comply with all federal laws prohibiting employment discrimination and will not discriminate or retaliate in any manner against any person because of opposition to any practice declared unlawful under Title VII or because of the filing of a charge, tbe giving oftestimony or assistance, or the participation in any investigation, proceeding, or hearing under Title VII.

Date Posted: Date Expires:
Fastbolt Corporation

Title VII of the Civil Rights Act of 1964, 42 V.S.C §2000e ct seq., as amended ("Title VII"), prohibits discrimination against employees and applicants for employment based upon sex, national origin, race, color or religion. Title VII further prohibits retaliation against employees or applicants who avail themselves of the rigbts under Title VII by engaging in protected activities, such as filing a charge ofdiscrimination and/or testifying or participating in a Commission investigation. The EEOC is the federal agency which investigates charges of unlawful employment discrimination. The EEOC has

If you have a complaint of employment discrimination or qnestions regarding laws prohibiting employment discrimination, you may seek assistance from the Equal Employment Opportunity Commission Office locations and general information may be
obtained on the Internet at
WWW.eeoc.1i!0v or by calling 1-800669-4000 (TDD 1-800-669-6820).

 
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CLOSED, RULE16, SCHEDO
U.S. District Court District of New Jersey [LIVE] (Newark) CIVIL DOCKET FOR CASE #: 2:05-cv-04325-FSH-PS

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. FAST BOLT CORPORATION Assigned to: Judge Faith S. Hochberg Referred to: Magistrate Judge Patty Shwartz Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 09/06/2005 Date Terminated: 06/22/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Mediator ROSEMARY J. BRUNO

represented by ROSEMARY JOAN BRUNO BUCHANAN, INGERSOLL & ROONEY, PC 550 BROAD STREET SUITE 810 NEWARK, NJ 07102-4599 (973) 273-9800 Email: rosemary.bruno@bipc.com TERMINATED: 06/21/2006 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

represented by DAWN M. EDGE U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION PHILADELPHIA DISTRICT OFFICE 21 SOUTH 5TH STREET SUITE 400 PHILADELPHIA, PA 19106-2515 (215) 440-2687 Email: dawn.edge@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

JACQUELINE H. MCNAIR EQUAL EMPLOYMENT OPPORTUNITY COMMISSION PHILADELPHIA DISTRICT OFFICE THE BOURSE BUILDING 21 SOUTH FIFTH STREET SUITE 400 PHILADELPHIA, PA 19106 (215) 440-2688 Email: jacqueline.mcnair@eeoc.gov

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Intervenor Plaintiff Andrea Pitts

LEAD ATTORNEY ATTORNEY TO BE NOTICED
JUDITH A. O'BOYLE EQUAL EMPLOYMENT OPPORTUNITY COMMISSION PHILADELPHIA DISTRICT OFFICE THE BOURSE BUILDING 21 SOUTH FIFTH STREET SUITE 400 PHILADELPHIA, PA 19106-2515 (215) 440-2685 Email: judith.oboyle@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
MARY M TIERNAN U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION THE BOURSE 21 SOUTH 5TH STREET SUITE 400 PHILADELPHIA, PA 19106 215-440-2686 Email: mary.tiernan@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by JYOTI MISTRY HALSBAND HALSBAND & GINSBERG, LLP 39 HUDSON STREET 4TH FLOOR HACKSNSACK, NJ 07601 (201) 487-6249 Email: jmhalsband@optonline.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant FASTBOLT CORPORATION

represented by BARRY BENJAMIN CEPELEWICZ MEISELMAN, DENLEA, PACKMAN, CARTON & EBERZ, PC 1311 MAMARONECK AVENUE WHITE PLAINS, NY 10605 (914) 517-5000 Email: bcepelewicz@mdpcelaw.com

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LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/06/2005 09/07/2005 09/15/2005
09/15/2005
10/11/2005 10/11/2005 10/11/2005 10/12/2005 10/21/2005 10/28/2005
10/28/2005

#

Docket Text

1 COMPLAINT against FAST BOLT CORPORATION JURY DEMAND, filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.(lm2, ) (Entered: 09/07/2005)
Summons Issued as to FAST BOLT CORPORATION.Days Due - 20. (MAILED TO COUNSEL) (lm2, ) (Entered: 09/07/2005)
2 MOTION to Intervene by Andrea Pitts. (Attachments: # 1 Brief in support of motion# 2 Declaration in Support of Motion# 3 Exhibit A to Declaration in Support of Motion# 4 Exhibit B to Declaration in Support of Motion# 5 Exhibit C to Declaration in Support of Motion# 6 Text of Proposed Order # 7 Certificate of Service)(HALSBAND, JYOTI) (Entered: 09/15/2005)
Set/Reset Deadlines as to 2 MOTION to Intervene. Motion Hearing set for 10/11/2005 10:00 AM in Newark - Courtroom 1 before Judge Faith S. Hochberg. (PLEASE BE ADVISED THAT THIS MOTION WILL BE DECIDED ON THE PAPERS UNLESS OTHERWISE NOTIFIED BY THE COURT). (dh, ) (Entered: 09/22/2005)
3 ORDER granting 2 Motion to Intervene; Andrea Pitts is granted leave to file a complaint as a pltf. Said complaint shall be filed no later than 10/14/05, etc.. Signed by Judge Patty Shwartz on 10/7/05. (jd, ) (Entered: 10/11/2005)
4 Intervenor COMPLAINT, filed by Andrea Pitts.(HALSBAND, JYOTI) (Entered: 10/11/2005)
5 SUMMONS Returned Executed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. FAST BOLT CORPORATION served on 9/30/2005, answer due 10/20/2005. (jd, ) (Entered: 10/12/2005)
6 ORDER extending time to answer until 10/28/2005. Signed by Judge Faith S. Hochberg on 10/12/2005. (lm, ) (Entered: 10/13/2005)
7 ORDER extending time for defendants to answer until 11/11/2005. Signed by Judge Faith S. Hochberg on 10/20/2005. (lm, ) (Entered: 10/21/2005)
8 MOTION for Entry of Judgment under Rule 54(b), MOTION for Leave to Appear Pro Hac Vice by FAST BOLT CORPORATION. (Attachments: # 1 Statement in lieu of brief# 2 Certification of Barry B. Cepelewicz, Esq.# 3 Certification of David S. Douglas, Esq.# 4 Certification of Jeffrey I. Carton, Esq.# 5 Text of Proposed Order admitting J. Carton and D. Douglas# 6 Certificate of Service re Motion pro hac vice)(CEPELEWICZ, BARRY) (Entered: 10/28/2005)
9 ANSWER to Complaint by FAST BOLT CORPORATION. (Attachments: # 1 Statement Rule 7.1# 2 Certificate of Service re Answer)(CEPELEWICZ, BARRY) (Entered: 10/28/2005)

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11/01/2005 11/09/2005 11/09/2005 11/11/2005 12/01/2005 12/01/2005 01/13/2006 01/20/2006 01/24/2006
01/24/2006
03/16/2006 03/16/2006
03/20/2006

10 ORDER granting 8 Motion for Leave to Appear Pro Hac Vice as to Jeffrey I. Carton and David s. Douglas. Signed by Judge Patty Shwartz on 11/1/05. (jd, ) (Entered: 11/01/2005)
Pro Hac Vice fee as to Davis S. Douglas: $ 150.00, receipt number 334742 (jd, ) (Entered: 11/09/2005)
Pro Hac Vice fee as to Jeffrey I. Carton: $ 150.00, receipt number 334743 (jd, ) (Entered: 11/09/2005)
11 ANSWER to Intervenor Complaint by FAST BOLT CORPORATION. (Attachments: # 1 Certificate of Service Answer to Andrea Pitts Complaint)(CEPELEWICZ, BARRY) (Entered: 11/11/2005)
12 SCHEDULING ORDER setting Scheduling Conference for 1/20/2006 10:00 AM in Newark - Courtroom 10 before Magistrate Judge Patty Shwartz. Signed by Judge Patty Shwartz on 12/1/05. (aa, ) (Entered: 12/02/2005)
13 SCHEDULING ORDER setting Scheduling Conference for 1/20/2006 10:00 AM in Newark - Courtroom 10 before Magistrate Judge Patty Shwartz. Signed by Judge Patty Shwartz on 12/1/05. (aa, ) (Entered: 12/02/2005)
14 NOTICE of Appearance by MARY M TIERNAN on behalf of EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (TIERNAN, MARY) (Entered: 01/13/2006)
Minute Entry for proceedings held before Judge Patty Shwartz : Scheduling Conference held on 1/20/2006. (aa, ) (Entered: 02/03/2006)
15 Pretrial SCHEDULING ORDER: Settlement Conference set for 7/21/2006 10:30 AM before Magistrate Judge Patty Shwartz. Telephone Conference set for 5/31/2006 09:30 AM before Magistrate Judge Patty Shwartz. Final Pretrial Conference set for 10/31/2006 10:00 AM before Magistrate Judge Patty Shwartz. Discovery due by 8/15/2006. Motions due by 9/16/2006.. Signed by Judge Patty Shwartz on 1/20/06. (jd, ) (Entered: 01/24/2006)
16 ORDER REFERRING CASE to Mediation purs to LCVR 301.1. Rosemary Bruno, Esq. shall serve as mediator; all proceedings in this civil action are hereby stayed from 3/30/06 through 5/27/06; Telephone Conference set for 5/31/2006 09:30 AM before Magistrate Judge Patty Shwartz.. Signed by Judge Patty Shwartz on 1/20/06. (jd, ) (Entered: 01/24/2006)
17 STIPULATION To Amend Defendant's Name by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. (EDGE, DAWN) (Entered: 03/16/2006)
20 STIPULATION AND ORDER that the name of the Deft in this action be changed from "Fast Bolt Corporation" to "Fastbolt Corporation" and that, all subsequent court pleadings, the name of the deft be "Fastbolt Corporation". Signed by Judge Patty Shwartz on 3/16/06. (jd, ) (Entered: 03/22/2006)
18 ORDER amending 16 Order Referring Case to Mediation; Telephone Conference set for 5/31/2006 09:30 AM before Magistrate Judge Patty Shwartz.. Signed by Judge Patty Shwartz on 3/17/06. (jd, ) (Entered: 03/20/2006)

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03/20/2006
03/22/2006
04/07/2006 04/11/2006 05/02/2006 05/31/2006 06/01/2006
06/02/2006 06/05/2006 06/22/2006 07/25/2006 07/27/2006

19 ORDER that the request to extend the deadline to complete the depositions needed for a meaningful mediation session is granted; Amended Pretrial SCHEDULING ORDER: Settlement Conference set for 7/21/2006 10:30 AM before Magistrate Judge Patty Shwartz. Final Pretrial Conference set for 10/31/2006 10:00 AM before Magistrate Judge Patty Shwartz. Discovery due by 8/15/2006. Motions due by 9/16/2006. Proposed Pretrial Order due by 10/24/2006.. Signed by Judge Patty Shwartz on 3/17/06. (jd, ) (Entered: 03/20/2006)
21 ORDER on Informal Application & Second Amended Pretrial SCHEDULING ORDER: Settlement Conference set for 7/21/2006 10:30 AM before Magistrate Judge Patty Shwartz. Telephone Conference set for 5/31/2006 09:30 AM before Magistrate Judge Patty Shwartz. Final Pretrial Conference set for 10/31/2006 10:00 AM before Magistrate Judge Patty Shwartz. Discovery due by 8/15/2006. Motions due by 9/16/2006. Proposed Pretrial Order due by 10/24/2006.. Signed by Judge Patty Shwartz on 3/22/06. (jd, ) (Entered: 03/23/2006)
23 ORDER on in informal application for a Joint Stipulated PROTECTIVE ORDER. Signed by Judge Patty Shwartz on 4/7/06. (jd, ) (Entered: 04/13/2006)
22 ORDER on informal appliction re: document requests, etc.. Signed by Judge Patty Shwartz on 4/10/2006. (mn, ) (Entered: 04/11/2006)
24 STATUS REPORT ORDER Status Report due by 5/22/2006. Signed by Judge Faith S. Hochberg on 5/2/2006. (lm, ) (Entered: 05/03/2006)
Minute Entry for proceedings held before Judge Patty Shwartz : Telephone Conference held on 5/31/2006. (aa, ) (Entered: 06/02/2006)
25 ORDER on Informal Application & Third Amended Pretrial SCHEDULING ORDER: Settlement Conference set for 7/21/2006 10:30 AM before Magistrate Judge Patty Shwartz. Final Pretrial Conference set for 10/31/2006 10:00 AM before Magistrate Judge Patty Shwartz. Dispositive Motions due by 9/16/2006. Proposed Pretrial Order due by 10/24/2006.. Signed by Judge Patty Shwartz on 5/31/06. (jd, ) (Entered: 06/01/2006)
27 ORDER granting request to extend time to submit joint status report. Joint status report due 6/23/2006. Signed by Judge Faith S. Hochberg on 6/2/2006. (lm, ) (Entered: 06/05/2006)
26 Second Amended ORDER of reference to Mediation; mediation shall take place 6/15/06 subject to availability of the mediator; all proceedings in the civil action are hereby stayed for 6/6/06 through 6/15/06. Signed by Judge Patty Shwartz on 6/1/06. (jd, ) (Entered: 06/05/2006)
28 ORDER DISMISSING CASE as settled, w/out costs and w/out prejudice. Signed by Judge Faith S. Hochberg on 6/22/06. (jd, ) (Entered: 06/22/2006)
29 STIPULATION of Dismissal with Prejudice by Andrea Pitts. (Attachments: # 1 Letter to Clerk of the Court re Joint Stipulation of Dismissal with Prejudice and Proposed Order of Dismissal# 2 Proposed Order of Dismissal with Prejudice)(CEPELEWICZ, BARRY) (Entered: 07/25/2006)
30 ORDER of dismissal with prejudice. Signed by Judge Faith S. Hochberg on 7/26/06. (jd, ) (Entered: 07/27/2006)

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08/10/2006 12/07/2006 12/07/2006
01/10/2007

31 ORDER/CONSENT DECREE . Signed by Judge Faith S. Hochberg on 8/4/06. (jd, ) (Entered: 08/10/2006)
32 MOTION Relief For Damages Pursuant to Entry of Default by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. (Attachments: # 1 Exhibit Exhibt A# 2 Certificate of Service)(EDGE, DAWN) (Entered: 12/07/2006)
Set Deadlines as to 32 MOTION Relief For Damages Pursuant to Entry of Default. Motion Hearing set for 1/8/2007 before Judge Faith S. Hochberg. (Please be advised that this motion shall be decided on the papers unless otherwise notified by the court) (jd, ) (Entered: 12/08/2006)
33 Letter from Plaintiff EEOC regarding inadvertent filing of Motion for Damages re 32 MOTION Relief For Damages Pursuant to Entry of Default. (EDGE, DAWN) (Entered: 01/10/2007)

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