FILED
U.S. DISTRRIClTeiCAORUKRATNSAS
IN THE UNITED STATES DISTRICT COURT EASTERN OlSi
FOR THE EASTERN DISTRICT OF ARKANSAS SEP 2 7 ,000
PINE BLUFF DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION

)

)

Plaintiff,

)

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)

AFFILIATED FOODS SOUTHWEST, INC.)

D/BIA THRIFTWAY FOODS, INC.

)

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)

Defendant.

)

5- 0 0-C -00 CIVIL ACTION NO.
COMPLAINT JURY TRIAL DEMAND

NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964,42 U.S.C.§2000e et seq. and Title I of the Civil Rights Act of 1991,42 U.S.C.§1981a, to correct unlawful employment practices on the basis of sex and to provide appropriate relief to Jackquline Stokes and other female employees who have been adversely affected by such practices. The Commission alleges that Jackquline Stokes and other female employees were sexually harassed by Jerome Sanders, manager; that the harassment was so pervasive, egregious and persistent that it constituted a pattern and practice of sex discrimination against the female employees; and that Respondent is vicariously liable for the sexual harassment perpetrated on Jackquline Stokes and other female employees by Jerome Sanders and for the consequences arising from this unlawful discrimination.

I

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C.§§ 451,1331,1337,1343 and 1345. This action is authorized and instituted pursuant to Section 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 Section 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 Eastern District of Arkansas, Pine Bluff Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C.§ 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Affiliated Foods Southwest, Inc., d/b/a Thriftway Foods, Inc. of Pine Bluff (the "Employer"), has continuously been an Arkansas corporation doing business in the State of Arkansas and the City of Pine Bluff, and has continuously had at least 15 employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b),(g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b),(g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Jackquline Stokes filed a charge with the Commission alleging violations of Title VII on the basis of sex (female) by
2

Defendant Employer. All conditions precedent to the institution ofthis lawsuit have been fulfilled.
7. Since at least 300 days prior to February 12, 1998, when Stokes filed her charge, Defendant Employer has engaged in and continues to engage in unlawful employment practices at and through its facility in Pine Bluff, Arkansas, in violation of Section 703 of Title VII, 42 U.S.C. §2000e-2. The unlawful employment practices include:
A. That Jackquline Stokes, a female employee of Defendant's business, was subjected to sexually explicit comments and touching in an unwelcome way throughout her employment. This conduct was engaged in by Jerome Sanders, Defendant's manager.
B. That other female employees were likewise SUbjected to similar unwelcome sexual harassment by Jerome Sanders, Defendant's manager.
C. That the unwelcome harassment by Jerome Sanders was done publicly and humiliated female employees standing nearby.
D. That Jackquline Stokes complained to management about the offensive conduct but Defendant failed to take any appropriate action.
8. This demeaning and persistent conduct by Defendant constitutes a pattern and practice of discriminatory treatment toward female employees because of their sex.
9. The effect of the practices complained of in paragraph 7 above has been to adversely affect the employment status of Jackquline Stokes and other females because of their sex.
10. Defendant has failed to promulgate any policy prohibiting sexual harassment in the workplace or to disseminate to its employees any policy prohibiting sexual harassment in the workplace.
3

11. Defendant is vicariously liable for discrimination perpetrated upon Stokes and the class of females by Jerome Sanders, its supervisory employee.
12. The unlawful employment practices complained of in paragraph 7 above were and are intentional.
13. The unlawful employment practices complained of in paragraph 7 above were and are being done with malice or with reckless indifference to the federally protected rights of Jackquline Stokes, and other females.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participating with it, from engaging in sexual harassment and any other employment practices which discriminates on the basis of sex (female). B. Order Defendant Employer to institute and carry out policies, practices, and programs which prohibit sexual harassment in the workplace and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Jackquline Stokes and other female employees by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices including, but not limited to, reimbursement ofthe value oflost benefits, raises and bonuses; expungement of personnel records; satisfactory employment references; reinstatement of female employees, as appropriate; or frontpay in lieu of reinstatement, if appropriate.
4

D. Order Defendant Employer to make whole Jackquline Stokes and other females by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including job search expenses and medical expenses covered by Defendant's employee benefit plan, in amounts to be determined at trial.
E. Order Defendant Employer to make whole Jackquline Stokes and other females by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including pain and suffering, emotional distress, humiliation and inconvenience in amounts to be determined at trial.
F. Order Defendant Employer to pay Jackquline Stokes and other females punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest, including ordering Defendant to appropriately discipline the offending harasser, up to and including termination, and to document the permanent personnel files of the offending harasser with the disciplinary action taken.
H. Award the Commission its costs for this action.
(Continued on next page)
5

JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
C. GREGORY STEWART General Counsel
GWENDOLYN YOUNG-REAMS Associate General Counsel
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Regional Attorney TN Bar #6283
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TERR BECK Supervisory Trial Attorney TN Bar #9346
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CARSON L. OWEN Senior Trial Attorney TN Bar # 009240
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Trial Attorney OR Bar # 0041524
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1407 Union Ave., Suite 621 Memphis, Tennessee 38104 (901) 544-0102
6

 
 ~~~~~~~SAS
DEC 15 ZOOO IN TEHAESTUENRIWTNEEDDSITSSETTRRANITCEDTSIOVDFIISSAITORRNKICATNSCAOSURTJBAMY ES: 1P~ ~CORb~EpCCLCEERF

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

PLAINTIFF

VS.

CASE NO. 5:00-CV-00356

AFFILIATED FOODS SOUTHWEST, INC. d/b/a THRIFTWAY FOODS, INC.

DEFENDANT

JACKQULINE STOKES

INTERVENOR

COMPLAINT IN INTERVENTION ON BEHALF OF JACKQULINE STOKES

Come now the Intervenor, Jackquline Stokes, by and through her attorneys, Cross, Kearney

& McKissic, and for her Complaint in Intervention, state:

INTRODUCTORY STATEMENT

This is an action to redress employment discrimination based upon sex (sexual harassment;

hostile environment); for retaliation for complaints of sexual harassment, and for a permanent

injunction prohibiting Defendant from engaging in policies and practices contained herein in

violation of 42 U.S.C. §2000e. et. Seq., the Equal Employment Opportunity Act (EEOA) (as

amended by the Civil Rights Act of 1991) and the Arkansas Civil Rights Act of 1993, A.c.A. 16-

123-101, et. seq; and for practices complained of under the Arkansas common law tort of Outrage;

for full loss wages, liquidated damages, benefits, damages for pain and suffering, punitive damages,

costs and attorney's fees, and any and all other benefits to which the Plaintiff would have been

entitled had she not been the victim of sexual harassment and retaliation, and for emotional distress

resulting from the Defendant's behavior.

JURISDICTION 1. The jurisdiction ofthis Court is invoked pursuantto 28 U.S.C. §§ 1331, 1343(3) and (4), and under 42 U.S.c. § 2000e, et seq., the Equal Employment Opportunity Act. Plaintiff also seeks relief under Title VII of the 1964 Civil Rights Act, and the Civil Rights Act of 1991 as the same pertains to discrimination based on sex, sexual harassment and retaliation; and for a declaratory judgment under 28 U. S.C. §§ 2201 and 2202, declaring thatthe Defendant has discriminated against her in the terms and conditions of her employment. This Court also has jurisdiction over the Plaintiff's state law claims brought pursuant to the Arkansas Civil Rights Act of 1993, A.c.A. 16123-101, et seq. And for the torts of Outrage pursuant to the plenary power ofthis Court toinvoke its pendant jurisdiction over causes of action arising under Arkansas law. Plaintiffclaim an unconditional right to Intervene in this action pursuant to Rule 24(a) ofthe Federal Rules of Civil Procedure. See also EEOC v. Century LL.C., 142 F.R.D. 494 (D.C. KanI992); EEOC v. Contour Chair Lounge Co., 596 F. 2d 809 (8th Cir. 1979); Nevilles v. EEOC, 511 F. 2d 303 (8th Cir. 1975); 42 U.S.C. 2000e-5(f)(1). 2. Plaintiff filed a timely charge of discrimination with the Equal Employment Opportunity Commission (EEOC) on or about February 11, 1998. On or about September 27, 2000, the EEOC initiated this lawsuit. All conditions precedent to the institution of this Intervention and the initial EEOC lawsuit have been fulfilled.
PARTIES 3. Intervention, Jackquline Stokes, is and was at all times relevant hereto a citizen of the United States and a resident of Pine Bluff, Jefferson County, Arkansas, and is a protected person within the meaning of 42 U.S.C. §2000e-2 and the Arkansas Civil Rights Act of 1993, A.c.A. 16123-101, et seq.

4. At all relevant times, Defendant, Affiliated Foods, corporation doing business in the State ofArkansas and the City ofPine Bluffand has continuously had at least fifteen (15) employees.
5. At all relevant times, Defendant Employer has continuously been and is now an employer engaged in an industry affecting commerce within the meaning of §70 1(b), (g), and (h) of Title VII, 42 U.S.C. §§2000e(b), (g), and (h).
FACTS 6. From on or about August of 1995 and continuing, Defendant, by and through its agents and employees, has engaged in unlawful employment practices at its Pine Bluff, Arkansas facility, in violation of 42 U.S.C. §2000e-2(a). The unlawful practices include, but are not limited to discrimination against each of the individual Plaintiffs on the basis of their sex in that each was subjected to a sexual hostile work environment. 7. The harassment included, but was not limited to, sexual touching, sexual explicit words, sexual jokes, abusive language, and requests for sexual favors. 8. The unlawful practices complained of herein were and are intentional. Further, the Defendant at all relevant times acted with malice or reckless indifference to the rights of Plaintiffs. 9. As a result of the Defendant's conduct, Plaintiff has suffered psychological and emotional distress, lost wages, lost benefits and other opportunities associated with their employment, and other expenses, for which she seeks damages as set forth, infra.
COUNT I VIOLATIONS OF TITLE VII, 1964 CIVIL RIGHTS ACT,
SEXUAL DISCRIMINATIONIHARASSMENT 10. Intervenor restate and incorporate by reference the preceding paragraphs of her Complaint as set forth herein word for word.

11. The Defendant, by and through its agents and employees, has discriminated against lackquline Stokes, and sexually harassed her because ofher sex (female) in that Plaintiffas sUbjected to a sexually hostile work environment. Further, the intentional and consistent sexual harassment and the failure ofthe Defendant to adequately remedy the situation, despite knowledge thereof, also contributed to the sexually hostile working environment, which detrimentally affected the working conditions of the Plaintiffs and would have detrimentally affected a reasonable person in their positions.
COUNT II RETALIATION IN VIOLATION OF 42 U.S.C. §2000e. et.seq. 12. Intervenor restate and incorporates by reference the preceding paragraphs of their Complaint as if set forth herein word for word. 13. As the direct result of1ackquline Stokes' complaint ofsexually inappropriate conduct in the workplace to her superiors, she was subjected to retaliation, as set forth, supra, all in violation of 42 U.S.C. §2000e, et.seq.
COUNT III VIOLATION OF THE ARKANSAS CIVIL RIGHTS ACT 14. Intervenor restate and incorporate herein by reference the preceding paragraphs of her Complaint as if set forth herein verbatim. 15. The acts and omissions alleged herein are in violation of the Arkansas Civil Rights Act of 1993, A.C.A. 16-123-101, et. seq., in that the Intervenor was subjected to discrimination in the terms and conditions of her employment as the result of a sexually hostile environment and retaliation, for which they seek the relief set forth, infra.
COUNT IV

OUTRAGE 16. Intervenor restates and incorporates by reference the preceding paragraphs of her Complaint as if set forth herein word for word. 17. The actions of Defendant were an intentional infliction of emotional distress constituting the tort of outrage under the common law of the state of Arkansas. 18. Defendant intentionally discriminated against, subjected Plaintiffto a sexually hostile work environment and retaliated against Plaintiff for complaints thereof, and knew or should have known that their acts were extreme and outrageous and would cause humiliation and emotional distress. The conduct of Defendant, by and through its agents and servants, is beyond all possible bounds of decency and is utterly intolerable in a civilized society. These actions of the Defendant were the cause of severe emotional distress of Plaintiff and such distress was of such a nature that no reasonable person should be expected to endure it.
DAMAGES 19. Interventor restate and incorporate by reference paragraphs 1 through 18, supra. 20. Intervenor, Jackquline Stokes, has suffered individual damages in an amount in excess ofthe minimum amount for federal diversity jurisdiction ($75,000 each) to be determined by a jury for the following elements.
[a] Loss ofemployment compensation, benefits, and promotional opportunities, including salary rases commensurate with performance;
[b] Loss of reputation and self-esteem; [c] Mental anguish and emotional distress; and [d] Other expenses incurred. Additionally, Intervenor request punitive damages to be awarded in an amount to be

determined by a jury also in excess of the minimum Federal Diversity Jurisdictional amount

($75,000.00).

WHEREFORE, Intervenor pray that this Court grant the following relief against the

Defendant herein:

[a] Grant a jury trial for determination ofwhether the actions of the Defendant violated

the rights of the Plaintiff as guaranteed by Title VII of the Civil Rights Act of 1964 and the Civil

Rights Act of 1991, as well as the protections afforded under 42 U.S.C. §2000e, et.seq, and in

violation of the Arkansas Civil Rights Act of 1993, A.C.A. 16-123-101, et.seq.;

[b] For a declaratory judgment that the acts of the Defendant violated the rights of the

Plaintiff as guaranteed by Title VII ofthe 1964 Civil Rights Act and the protections afforded under

42 U.S.C. §2000e, et.seq., and in violation ofthe Arkansas Civil Rights Act of A.C.A. 16-23-101,

et. seq.; [c]

Grant a permanent injunction preventing Defendant from engaging in the policies and

practices complained of in violation of both 42 U.S.C. §2000e, et. seq., and Title VII of the Civil

Rights Act of 1964 and the Civil Rights Act of 1991 and in violation of the Arkansas Civil Rights

Act of 1993, A.C.A. 16-123-101, et. seq.;

[d] Award full lost wages, and interest thereon; [e] Award punitive damages for the wilful, intentional and wanton discriminatory

actions; [f] Award compensatory damages for pain and suffering, mental anguish, medical and

psychiatric expenses and all other damages to which Plaintiff is entitled; [g] Award attorney's fees and costs as allowed under 42 U.S.C. §2000e-5(k); and

[h] Grant Plaintiff all other relief the Court deems necessary and proper.

INTERVENOR DEMAND A JURY TRIAL.

Respectfully submitted,

cf1~ BY:

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I:

1/A- L

GENE E. McKISSIC

I

CROSS, KEARNEY & McKISSIC Attorneys at Law Post Office Box 6606 Pine Bluff, Arkansas 71611 Telephone No. (870) 536-4056

' -

CERTIFICATE OF SERVICE

I, Gene E. McKissic, hereby certify that I have mailed a true and correct copy ofthe foregoing document via United States mail, postage pre-paid, to the following counsel of record:

Mr. Spencer F. Robinson Attorney at Law Post Office Box 8509 Pine Bluff, Arkansas 71611

Mr. C. Gregory Stewart

General Counsel

Equal Employment Opportunity Commission

1407 Union Avenue, Suite 621

Memphis, Tennessee 38104

on this 21 st day of November, 2000.

t<~~~

GENE E. McKISSIC

~~,

 
 I .

FAS1l!~~~~ij~~SAS

IN THE UNITED STATES DISTRICT COuRT FEB 26 2001

EASTERN DISTRICT OF ARKANSAS JAMES ~cCORMACK CLER~

PINE BLUFF DIVISION

By: ~CLERf

EQUAL EMWLOYMENT OPPORTUNITY COMMISSION

PLAINTIFF

VS.

NO. 5:00CV00356 SWW

AFFILIATED FOODS SOUTHWEST, INC. d/b/a THRIFTWAY FOODS, INC.

DEFENDANT

JACQULINE STOKES

INTERVENOR

CONSENT DECREE

The Equal Employment Opportunity Commission (hereinafter referred to as the "EEOC") filed the above-referenced Complaint on September 27, 2000, against Affiliated Foods, Inc., d/b/a Thriftway Foods, Inc. to enforce the provisions of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.§2000e et seq., and the Civil Rights Act of 1991,42 U.S.C. §1981a.
Jacquline Stokes was subsequently allowed to intervene and acknowledges through the signature of her attorney, Gene McKissic, her concurrence to the terms ofthis Consent Decree.
The EEOC alleged that Defendant engaged in unlawful employment practices by subjecting Jacquline Stokes and other female employees to a sexually hostile work environment.
This Consent Decree does not constitute an admission by the Defendant of the allegations of the Complaint. The Defendant denies that it engaged in the unlawful employment practices alleged

-2-
by the EEOC. However, all parties to this action desire to avoid the additional expense and delay in the litigation ofthis case.
In the event this Consent Decree is not approved or does not become final, then it shall not be admissible in evidence in any subsequent proceeding in this action, unless the proceeding is brought to enforce the Decree.
The Court has reviewed the terms of the Consent Decree in light of the applicable laws and regulations, the statements and representations of counsel for all parties, and hereby approves the Consent Decree.
NOW, THEREFORE, the Court being fully advised in the pretnlses, it IS hereby ORDERED, ADJUDGED AND DECREED:
I. JURISDICTION The United States District Court for the Eastern District of Arkansas, Pine Bluff Division, has jurisdiction over the parties and subject matter of this litigation.
II. SCOPE AND DURATION OF DECREE A. This Consent Decree resolves all issues and claims arising out of the EEOC's Complaint filed in this cause, and the Complaint in Intervention filed by individual Intervenor Jacquline Stokes, alleging unlawful employment policies and practices maintained by Thriftway Foods, Inc. and arising out of Charge No. 251-98-0551 filed by Jacquline Stokes with the EEOC. Notwithstanding any provisions contained in this Decree, this agreement shall not be considered in any manner to be dispositive of any charges now pending before any office of the EEOC other than Charge No. 251-98-0551, but the parties acknowledge that there are no charges pending alleging

-3-
violations of Title VII of the 1964 Civil Rights Act against Defendant Thriftway Foods, Inc., which the parties acknowledge is no longer in business.
B. The provisions of this Consent Decree shall continue to be effective and binding upon the parties to this action for a period of one year from the date of the entry of this Decree, but the parties both acknowledge that upon payment of the sum set forth in this Consent Decree that there will be no further obligations imposed upon the Defendant.
In. NON-DISCRIMINATION PROVISION The parties hereto acknowledge that Thriftway Foods, Inc. in Pine Bluff is no longer in business, having ceased operations in 1998. Consequently, the parties acknowledge that there is no need for any injunctive relief.
IV. INDIVIDUAL RELIEF A. Defendant shall mail checks made payable to Jacquline Stokes, Tanya Davis, Cheryl Dolls, and Carolyn Thomas in the following gross amounts, less legally required withholding for taxes, social security, and any other applicable legally required withholding: Jacquline Stokes $15,000.00; Tanya Davis - $1,250.00; Cheryl Dolls - $1,250.00; and Carolyn Thomas - $15,000.00. Gene McKissic, Ms. Stokes' attorney, will be sent a check for $7,500.00. B. The checks will be mailed to the individuals at the following addresses: Jacquline Stokes, 808 Utah, Pine Bluff, AR 71601; Tanya Davis, 7004 Nell Dr., Pine Bluff, AR 71603; Cheryl Dolls, 1806 W. 320d St., Pine Bluff, AR 71603; and Carolyn Thomas, 1504 West 34th, Pine Bluff, AR 71603. Mr. McKissic's check will be mailed to his office. He will receive a Form 1099 at the conclusion of calendar year 2001.

-4-

C. Photocopies of the checks mailed to Jacquline Stokes, Tanya Davis, Cheryl Dolls, and Carolyn Thomas will be mailed to the attention of Draga Anthony, Equal Employment Opportunity Commission, 1407 Union Avenue, Suite 621, Memphis, 1N 38104. These copies will be mailed at the time that the checks are forwarded to the individuals named in paragraph IV. B.
V. COSTS AND ATTORNEYS' FEES Each of the parties shall bear their own costs, including attorneys' fees. Ms. Stokes specifically acknowledges that she shall be responsible for any additional attorneys' fees or costs associated with her pursuit of her EEOC Charge against the Defendant, this litigation, or any other fees or costs incurred associated with her employment or tennination from employment with the
Defendant over the amount paid to Mr. McKissic as set forth in paragraph IV A.
SO ORDERED TIDS r-x.rv7 r~ DAY OF FEBRUARY, 2001.

,-------.,

THIS DOCUMENT EMTfREO ON DOCKET SflEET IN

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FACP

G!ha)~~ SUSAN WEBBER WRIGHt UNITED STATES DISTRICT JUDGE

FOR THE DEFENDANT:
SPENCER F. ROBINSON Ramsay, Bridgforth, Harrelson
and Starling LLP 11th Floor Simmons First National Building 501 Main Street P. O. Box 8509 Pine Bluff, AR 716161-8509

FOR THE COMMISSION:
G~I!t~/t8
GWENDOLYN YOUNG REAMS Associate General Counsel
Kd~ uJ t Kduut/.Jl3
KATHARINE W. KORES Regional Attorney
J'~&C£

-5-

FOR PLAINTIFF INTERVENOR:
~glfV~
!GENE E. MCKISsiC1 100 South Pine Street P. O. Box 6606 Pine Bluff, AR 71611

TERRY BECK Supervisory Trial Attorney
DQ~oofoNY~
Trial Attorney
~a-=
CARSON L. OWEN Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1407 Union Avenue, Suite 621 Memphis, TN 38104 (901) 544-0102

ef UNITED STATES DISTRICT COURT Eastern District of Arkansas
U.S. Court House 600 West Capitol, Suite 402 Little Rock, Arkansas 72201-3325
February 26, 2001
* * MAILING CERTIFICATE OF CLERK * *
Re: 5:00-cv-00356.
True and correct copies of the attached were mailed by the clerk to the following:
Katharine W. Kores, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104
Terry Beck, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104
Carson L. Owen, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104
Draga G. Anthony, Esq. Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104
Spencer F. Robinson, Esq. Ramsay, Bridgforth, Harrelson & Starling 11th Floor Simmons Building 501 Main Street Post Office Box 8509 Pine Bluff, AR 71611-8509
Gene E. McKissic, Esq. Cross, Kearney & McKissic 100 South Pine Street, Suite B Post Office Box 6606

Pine Bluff, AR .-. 611- 6606
Date:

James W. McCormack, Clerk BY:

 
 CM/ECF - ARED - LIVE - Docket Report

https://ecf.ared.uscourts.gov/cgi-bin/DktRpt.pl?119481764651934-L_3...

DISC, JFF, TERMED
U.S. District Court Eastern District of Arkansas (Pine Bluff) CIVIL DOCKET FOR CASE #: 5:00-cv-00356-SWW

EEOC v. Affiliated Foods Assigned to: Judge Susan Webber Wright Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/27/2000 Date Terminated: 02/26/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Carson L. Owen Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0133 Email: carson.owen@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Draga G. Anthony Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 722-2556 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Katharine W. Kores Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0135 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Terry Beck Equal Employment Opportunity Commission - Memphis 1407 Union Avenue Suite 621

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V. Defendant Affiliated Foods Southwest, Inc. doing business as Thriftway Foods Inc
Intervenor Jackquline Stokes

Memphis, TN 38104 (901) 544-0138 Email: terry.beck@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Spencer F. Robinson Ramsay, Bridgforth, Harrelson & Starling Post Office Box 8509 Pine Bluff, AR 71611-8509 (870) 535-9000 Email: spencerrobinson@ramsaylaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Gene E. McKissic Brown & McKissic, LLP 116 West 6th Avenue Post Office Box 6116 Pine Bluff, AR 71601 870-534-6332 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/27/2000 10/13/2000 10/18/2000
11/21/2000 12/05/2000 12/11/2000 12/18/2000

#

Docket Text

1 COMPLAINT with jury demand; no summons were issued (tjj) (Entered: 09/27/2000)
2 ANSWER by defendant Affiliated Foods (former empl) (Entered: 10/16/2000)
3 SCHEDULING ORDER by Chief Judge Susan W. Wright; jury trial set for 9:30 5/14/01 in PINE BLUFF; discovery due 3/30/01; pretrial info sheet due 4/13/01 (cc: all counsel) (former empl) (Entered: 10/18/2000)
4 MOTION to intervene Jackquline Stokes and combined brief in support thereof (former empl) Modified on 12/19/2000 (Entered: 11/22/2000)
5 ANSWER by defendant Affiliated Foods to complaint in intervention of Jackquline Stokes (former empl) Modified on 12/08/2000 (Entered: 12/06/2000)
6 ORDER by Chief Judge Susan W. Wright granting Jackquline Stokes' motion to intervene [4-1] (cc: all counsel) (former empl) (Entered: 12/11/2000)
7 INTERVENOR'S complaint by intervenor Jackquline Stokes with JURY DEMAND (former empl) (Entered: 12/19/2000)

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02/26/2001

8 CONSENT DECREE by Chief Judge Susan W. Wright; this Consent Decree resolves all issues and claims filed in this cause & arising out of Charge No. 251-98-0551 filed by Jacquline Stokes; this Consent Decree shall be binding upon the parties to this action for a period of one year from the date of the entry of this Decree; defendant to mail checks to Jacquline Stokes in the amount of $15,000.00, Tanya Davis in the amount of $1,250.00, Cheryl Dolls in the amount of $1,250.00 and Carolyn Thomas in the amount of $15,000.00 and to Gene McKissic, Ms. Stokes' attorney in the amount of $7,500.00; each party to bear own costs, including attorneys' fees; case terminated (cc: all counsel) (former empl) (Entered: 02/26/2001)

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