UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF MARYLAND NORTHERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

10 S. Howard Street

)

Third Floor

)

Baltimore, Maryland 21201

)

)

Plaintiff,

)

)

v.

)

)

PROLEASE HR,INC.

)

d/b/a Prolease

)

7361 Calhoun Place

)

Suite 510

)

Rockville, Maryland 20855

)

)

INTRAFORCE

)

3620 Commerce Drive

)

Suite 715

)

Baltimore, Maryland 21227

)

)

VALLEYWOOD INDUSTRIES, INC. )

d/b/a Pallet Masters

)

6517 Landay Avenue

)

Baltimore, Maryland 21237

)

)

Defendants. )

)

Civil Action No. COMPLAINT
JURY TRIAL DEMAND

NATURE OF ACTION

This is an action under 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 and to make

whole Lisa Rager, who was subjected to a sexually hostile work

environment while she was employed by Defendants, and who was

constructively discharged by Defendants because of her sex.

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. Sections 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. Section 2000e, et seq. ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981A. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the District of Maryland, Northern Division.
PARTIES 3. Plaintiff, the 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 Section 706 (f)(1) and (3) of Title VII, 42 U.S.C. Section 2000e5(f)(1) and (3). 4. At all relevant times, Defendant Prolease HR, Inc., has continuously been and is now a Delaware corporation doing business in Baltimore. 5. At all relevant times, Defendant Prolease HR, Inc., has had at least fifteen employees. 6. At all relevant times, Defendant Prolease HR, Inc., has continuously been an employer engaged in an industry affecting
2

commerce under Section 701(b), (g), and (h) of Title VII, 42 U.S.C. Section 2000e-(b), (g), and (h).
7. 4. At all relevant times, Defendant Intraforce has continuously been and is now a Delaware corporation doing business in Baltimore.
8. At all relevant times, Defendant Intraforce has had at least fifteen employees.
9. At all relevant times, Defendant Intraforce has continuously been an employer engaged in an industry affecting commerce under Section 701(b), (g), and (h) of Title VII, 42 U.S.C. Section 2000e-(b), (g), and (h).
10. At all relevant times, Defendant Valleywood Industries, Inc., has continuously been and is now a Maryland corporation doing business in Baltimore.
11. At all relevant times, Defendant Valleywood Industries, Inc., has had at least fifteen employees.
12. At all relevant times, Defendant Valleywood Industries, Inc., has continuously been an employer engaged in an industry affecting commerce under Section 701(b), (g), and (h) of Title VII, 42 U.S.C. Section 2000e-(b), (g), and (h).
STATEMENT OF CLAIMS 13. All conditions precedent to the institution of this lawsuit have been fulfilled. 14. Since at least March, 2002, Defendant Employers have
3

engaged in unlawful employment practices at the Baltimore Pallet Masters facility, in violation of Sections 703(a) of Title VII, 42 U.S.C. Section 2000e-2. The practices include the following:
a. Subjecting Lisa Rager to a hostile and offensive work environment by condoning the sexually harassing and discriminating behavior of Ms. Rager’s supervisor, William Seibert. Incidents of harassment committed by Seibert and condoned by Defendants include, but are not limited to, grabbing Ms. Rager from behind while she was operating an electric saw; touching Ms. Rager inappropriately when he spoke with her, such as by putting his arm around her, pulling her close to him, and brushing up against her; slapping her on the behind; asking her to go to a strip bar with him during their lunch hour; insisting that she give him a key to the bathroom she used exclusively; banging on the door and jiggling the knob while she was using the bathroom; calling her demeaning names, such as “baby” and “honey”; and making inappropriate comments, such as telling her that she was his “girl,” asking her, “Are you going to be my baby?”, “Do you want to be my honey?” and “When are we going to go out?”
b. Deliberately creating intolerable working conditions for Lisa Rager by subjecting her to verbal and physical harassment, degradation, humiliation, and unsafe working conditions, and by ignoring her complaints about her supervisor’s
4

harassing conduct, all on the basis of her gender, and all of which resulted in her constructive discharge.
15. The unlawful employment practices complained of above were intentional.
16. The unlawful employment practices complained of above were done with malice or with reckless indifference to the federally protected rights of Lisa Rager.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns and all persons in active concert or participation with them, from engaging in gender discrimination, including sexual harassment; B. Order Defendants to institute and carry out policies, practices, and programs which provide equal employment opportunities for females, and which eradicate the effects of past and present unlawful employment practices; and C. Grant such further injunctive relief as the Court deems proper. With regard to Defendants Prolease HR, Inc., and Intraforce the Commission respectfully requests that this Court:1
1Defendant Valleywood Industries, Inc., is currently a reorganized debtor in a Chapter 11 case, In re Valleywood Industries, Inc., No. 01-64665-ESD filed in the U.S. Bankruptcy
5

A. Order Defendants to make whole Lisa Rager by providing appropriate back pay with prejudgment interest and front pay in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of their unlawful employment practices;
B. Order Defendants to make whole Lisa Rager by providing compensation for pecuniary and nonpecuniary losses, including emotional pain, suffering, anxiety, depression, embarrassment, degradation, and humiliation;
C. Order Defendants to pay to Lisa Rager punitive damages for their callous indifference to her federally protected right to be free from gender discrimination;
D. Grant such further monetary relief as the Court deems proper; and
E. Award the Commission its costs in this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by the Complaint.
Court for the District of Maryland. Concurrent with the filing of this lawsuit, the EEOC is filing a Motion of Determination of Nondischargeablility, or In the Alternative, for Leave to File an Administrative Claim with the bankruptcy court. If the bankruptcy court grants its motion, the EEOC will amend its complaint (or, if necessary, seek leave to amend) to seek backpay and punitive and compensatory damages against Valleywood Industries, Inc.
6

Respectfully submitted,
GWENDOLYN YOUNG REAMS Associate General Counsel
GERALD S. KIEL Regional Attorney
DEBRA M. LAWRENCE Supervisory Trial Attorney
____________________________ MARIA LUISA MOROCCO Trial Attorney Federal Bar No. 24357 MARIA SALACUSE Trial Attorney Federal Bar. No. 15562 UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 10 S. Howard Street 3rd Floor Baltimore, Maryland 21201 Phone: (410) 962-4260 Fax: (410) 962-4270
7

 
 UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF MARYLAND NORTHERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

10 S. Howard Street

)

Third Floor

)

Baltimore, Maryland 21201

)

)

Plaintiff,

)

)

)

v.

)

)

PROLEASE HR,INC.

)

d/b/a Intraforce

)

7361 Calhoun Place

)

Suite 510

)

Rockville, Maryland 20855

)

)

)

VALLEYWOOD INDUSTRIES, INC. )

d/b/a Pallet Masters

)

6517 Landay Avenue

)

Baltimore, Maryland 21237

)

)

Defendants. )

)

Civil Action No. AMD 03 CV 2240 AMENDED COMPLAINT
JURY TRIAL DEMAND

NATURE OF ACTION

This is an action under 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 and to make

whole Lisa Rager, who was subjected to a sexually hostile work

environment while she was employed by Defendants, and who was

constructively discharged by Defendants because of her sex.

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to 28

U.S.C. Sections 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. Section 2000e, et seq. ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981A.
2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the District of Maryland, Northern Division.
PARTIES 3. Plaintiff, the 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 Section 706 (f)(1) and (3) of Title VII, 42 U.S.C. Section 2000e5(f)(1) and (3). 4. At all relevant times, Defendant Prolease HR, Inc., has continuously been and is now a Delaware corporation doing business in Baltimore. 5. At all relevant times, Defendant Prolease HR, Inc., has had at least fifteen employees. 6. At all relevant times, Defendant Prolease HR, Inc., has continuously been an employer engaged in an industry affecting commerce under Section 701(b), (g), and (h) of Title VII, 42 U.S.C. Section 2000e-(b), (g), and (h). 7. At all relevant times, Defendant Valleywood Industries,
2

Inc., has continuously been and is now a Maryland corporation doing business in Baltimore.
8. At all relevant times, Defendant Valleywood Industries, Inc., has had at least fifteen employees.
9. At all relevant times, Defendant Valleywood Industries, Inc., has continuously been an employer engaged in an industry affecting commerce under Section 701(b), (g), and (h) of Title VII, 42 U.S.C. Section 2000e-(b), (g), and (h).
STATEMENT OF CLAIMS 10. All conditions precedent to the institution of this lawsuit have been fulfilled. 11. Since at least March, 2002, Defendant Employers have engaged in unlawful employment practices at the Baltimore Pallet Masters facility, in violation of Sections 703(a) of Title VII, 42 U.S.C. Section 2000e-2. The practices include the following:
a. Subjecting Lisa Rager to a hostile and offensive work environment by condoning the sexually harassing and discriminating behavior of Ms. Rager’s supervisor, William Seibert. Incidents of harassment committed by Seibert and condoned by Defendants include, but are not limited to, grabbing Ms. Rager from behind while she was operating an electric saw; touching Ms. Rager inappropriately when he spoke with her, such as by putting his arm around her, pulling her close to him, and brushing up against her; slapping her on the behind; asking her
3

to go to a strip bar with him during their lunch hour; insisting that she give him a key to the bathroom she used exclusively; banging on the door and jiggling the knob while she was using the bathroom; calling her demeaning names, such as “baby” and “honey”; and making inappropriate comments, such as telling her that she was his “girl,” asking her, “Are you going to be my baby?”, “Do you want to be my honey?” and “When are we going to go out?”
b. Deliberately creating intolerable working conditions for Lisa Rager by subjecting her to verbal and physical harassment, degradation, humiliation, and unsafe working conditions, and by ignoring her complaints about her supervisor’s harassing conduct, all on the basis of her gender, and all of which resulted in her constructive discharge.
12. The unlawful employment practices complained of above were intentional.
13. The unlawful employment practices complained of above were done with malice or with reckless indifference to the federally protected rights of Lisa Rager.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns and all persons in active
4

concert or participation with them, from engaging in gender discrimination, including sexual harassment;
B. Order Defendants to institute and carry out policies, practices, and programs which provide equal employment opportunities for females, and which eradicate the effects of past and present unlawful employment practices; and
C. Grant such further injunctive relief as the Court deems proper.
With regard to Defendant Prolease HR, Inc., the Commission respectfully requests that this Court:
A. Order Defendant to make whole Lisa Rager by providing appropriate back pay with prejudgment interest and front pay in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices;
B. Order Defendant to make whole Lisa Rager by providing compensation for pecuniary and nonpecuniary losses, including emotional pain, suffering, anxiety, depression, embarrassment, degradation, and humiliation;
C. Order Defendant to pay to Lisa Rager punitive damages for its callous indifference to her federally protected right to be free from gender discrimination;
D. Grant such further monetary relief as the Court deems proper; and
5

E. Award the Commission its costs in this action.
JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of
fact raised by the Complaint.
Respectfully submitted,
ERIC S. DREIBAND General Counsel
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
/s/
GERALD S. KIEL Regional Attorney (signed by Maria Morocco with permission of Gerald S. Kiel)
/s/
DEBRA M. LAWRENCE Supervisory Trial Attorney (signed by Maria Morocco with permission of Debra M. Lawrence)
/s/ _____________________________ MARIA LUISA MOROCCO Trial Attorney Federal Bar No. 24357
/s/ _____________________________ MARIA SALACUSE Trial Attorney Federal Bar. No. 15562 (signed by Maria Morocco with
6

permission of Maria Salacuse) UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 10 S. Howard Street 3rd Floor Baltimore, Maryland 21201 Phone: (410) 962-4260 Fax: (410) 962-4270
7

 
 IN THE UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND NORTHERN DIVISION

U.S. EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

)

)

PROLEASE HR, INC.

)

VALLEYWOOD INDUSTRIES, INC.

)

)

Defendants.

)

)

)

C.A. No. 03-02240-AMD

CONSENT DECREE

This action was instituted by Plaintiff, the U.S. Equal Employment Opportunity

Commission (the "EEOC" or the "Commission"), against Defendants Valleywood Industries,

Inc., and Prolease HR, Inc., (collectively “Defendants”), alleging that Defendants violated

Section 703(a) of Title VII of the Civil Rights Act of 1964 (“Title VII”), as amended, 42 U.S.C.

§ 2000e-2(a), by subjecting former employee Lisa Rager to sexual harassment and by

constructively discharging her because of her sex.

The Commission and Defendants desire to resolve this action without the time and

expense of continued litigation, and they desire to formulate a plan to be embodied in a Decree

which will promote and effectuate the purposes of Title VII.

This Decree shall not constitute an adjudication on the merits of the Commission's case

and shall not be construed as an admission by Defendants of any discriminatory practice or as a

waiver by the Commission of any contentions of discrimination.

The Court has examined this Decree and finds that it is reasonable and just and in accordance with the Federal Rules of Civil Procedure and Title VII. Therefore, upon due consideration of the record herein and being fully advised in the premises, it is ORDERED, ADJUDGED AND DECREED:
1. This Decree resolves all issues and claims alleged in the Amended Complaint filed by the Commission in this Title VII action which emanated from the Charge of Discrimination filed by Lisa Rager.
2. This Decree shall be in effect for a period of one year from the date it is entered by the Court.
3. Defendants, their officers, agents, servants, employees, successors, assigns, and all persons acting or claiming to act on their behalf, are hereby enjoined from sexually harassing, and condoning the sexual harassment of, any employee of Valleywood Industries, Inc. The prohibited harassment includes the use of offensive or derogatory comments, or other verbal or physical conduct based on an individual’s sex, which creates an intimidating, hostile, or offensive working environment, or interferes with the individual’s work performance. Such sexbased harassment violates Title VII, which, in part, is forth below:
It shall be an unlawful employment practice for an employer -(1) ... to discriminate against any individual with respect to [her] ... terms, conditions, or privileges of employment, because of such individual’s ... sex .... 42 U.S.C. § 2000e-2(a)(1). Defendants, their officers, agents, servants, employees, successors, assigns, and all persons acting or claiming to act on their behalf are further enjoined from retaliating against any employee of Valleywood Industries, Inc., who complains of sexual harassment, as set forth in the following provision:
2

It shall be an unlawful employment practice for an employer to discriminate against any of his employees ... because he has opposed any practice made an unlawful employment practice by this subchapter, or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this subchapter. 42 U.S.C. § 2000e-3(a). 4. Within twenty days after entry of this Decree, Defendant ProLease HR, Inc., will pay Lisa Rager a total of $30,000. Defendants will issue to Ms. Rager an IRS form 1099 for the 2004 tax year. 5. Within 90 days after the entry of this Decree, all employees of Valleywood Industries, Inc., shall be required to attend a training program lasting at least two hours for managers and at least one hour for non-managerial employees to cover prevention of employment discrimination and compliance with federal anti-discrimination laws. Within seven days after this training has been completed, Defendants will provide certification to Commission counsel of record that such training has been provided, including the identity of the trainer, the date and location of the training, the identities of the trainees, and the length of the training. Defendants will show an orientation videotape that addresses appropriate conduct and preventing harassment in the workplace to its new employees and to all employees promoted to managerial positions. 6. Defendants shall revise its harassment policy in the following manner: by providing the name, address, and telephone number of an official not employed by Valleywood Industries, Inc., who will serve as the recipient of harassment complaints of Valleywood
3

Industries’ employees, investigate these complaints, and recommend appropriate remedial action, if appropriate; by assuring that employees who make complaints of harassment or provide information related to such complaints will be protected against retaliation; by assuring that the complaint process will be confidential and will include a prompt, thorough, and impartial investigation; and by assuring that the employer will take immediate and appropriate corrective action when it determines that harassment has occurred. This policy, once revised and approved as discussed below, will be distributed to all employees of Valleywood Industries, Inc., both managerial and non-managerial, and shall be included in any relevant policies or employee manuals maintained by Valleywood Industries, Inc. The policy will also be posted in a conspicuous and accessible place for all employees of Valleywood Industries, Inc.
a. Within 30 days after entry of the Consent Decree, Defendants shall submit the revised policy to the Commission’s counsel of record for approval by the EEOC. EEOC will then notify Defendants within 14 days as to whether the policy is acceptable. In the event the proposed policy is not acceptable to the EEOC, the parties will confer in good faith and attempt to reach an agreement no later than 10 days after receiving the EEOC’s objection. In the event the parties are unable to reach an agreement they shall submit their dispute to the Court with a request for a referral to a United States Magistrate for mediation.
b. Within seven days after the revised policy has been approved by the EEOC, Defendants will provide certification to Commission’s counsel of record that the revised policy has been distributed and posted in the manner described above.
7. Within ten days after entry of the Consent Decree, Defendants will post
4

immediately in all places where notices to employees customarily are posted at Valleywood Industries, Inc., the Notice attached hereto and made a part hereof. Said Notice shall be posted and maintained for a period of 180 days from the date of posting and shall be signed by a responsible official of Defendant Valleywood Industries, Inc., with the date of actual posting shown thereon. Should the Notice become defaced, marred, or otherwise made unreadable, Defendants will ensure that new, readable copies of the Notice are posted in the same manner as heretofore specified. Within 30 days of approval of this Decree, Defendants shall forward to the EEOC’s attorney of record a copy of the signed Notice attached hereto and written certification that the Notice referenced herein has been posted and a statement of the location(s) and date of posting.
8. On the 330th day following the entry of this decree, Defendants will report in writing to the Commission’s counsel of record concerning the implementation of this Decree. The report will include the following information:
Copies of any formal of informal complaints of sexual harassment made by any employee of Valleywood Industries, Inc., and for every complaint, whether oral or written, the name of the complainant, and a detailed explanation of Defendants’ actions taken in response to the complaint, including any investigative and corrective measures taken. The Commission and Defendants shall bear their own costs and attorneys' fees.
5

The undersigned counsel of record in the above-captioned action hereby consent, on

behalf of their respective clients, to the entry of the foregoing Consent Decree.

FOR DEFENDANT:

FOR PLAINTIFF:

/s/ Gerald L. Maatman, Jr.*

/s/ Gerald S. Kiel* Regional Attorney

_______/s/______________ Yvette A. Heintzelman*

/s/ Debra M. Lawrence* Supervisory Trial Attorney

_______/s/_____________ Maria Luisa Morocco*
Trial Attorney

SEYFARTH SHAW, LLP Attorneys for Defendants Valleywood Industries, Inc. and Prolease HR, Inc. 55 East Monroe Street Suite 4200 Chicago, Illinois 60603

U.S EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Baltimore District Office 10 S. Howard Street, 3d Floor Baltimore, Maryland 21201 (410) 962-4260

*signed copy of the consent decree bearing the signatures of Gerald L. Maatman, Jr., Yvette A. Heintelman, Gerald S. Kiel, Debra M. Lawrence, and Maria Luisa Morocco is being maintained at the EEOC’s Baltimore District Office by Maria Luisa Morocco.

SO ORDERED. Signed and entered this 13thday of April

, 2004.

/s/
Andre M. Davis United States District Court Judge

6

 
 District of Maryland (CM/ECF Live 3.0) - Docket Report

https://ecf.mdd.uscourts.gov/cgi-bin/DktRpt.pl?367555313857387-L_3...

U.S. District Court District of Maryland (Baltimore) CIVIL DOCKET FOR CASE #: 1:03-cv-02240-AMD

CLOSED

Equal Employment Opportunity Commission v. Prolease HR, Inc. et al Assigned to: Judge Andre M Davis Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 08/01/2003 Date Terminated: 04/13/2004 Jury Demand: None Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Maria Luisa Morocco US Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14102092730 Fax: 14109624270 Email: maria.morocco@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Debra Michele Lawrence U S Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14102092734 Fax: 14109624270 Email: debra.lawrence@eeoc.gov ATTORNEY TO BE NOTICED

Gerald S Kiel US Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624207 Fax: 14109624270 Email: gerald.kiel@eeoc.gov

Gwendolyn Young Reams U S Equal Employment Opportunity Commission

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District of Maryland (CM/ECF Live 3.0) - Docket Report
V. Defendant Prolease HR, Inc. doing business as Prolease
Defendant Intraforce
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https://ecf.mdd.uscourts.gov/cgi-bin/DktRpt.pl?367555313857387-L_3...
City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624260 Fax: 14109622817
represented by Gerald L Maatman, Jr Seyfarth Shaw 55 E Monroe St Ste 4200 Chicago, IL 60603-5803 13122698965 Fax: 13122698869 ATTORNEY TO BE NOTICED
Jenny B Friedman Seyfarth Shaw LLP 55 E Monroe St Ste 4200 Chicago, IL 60603-5803 13122698920 Fax: 13122698869 ATTORNEY TO BE NOTICED
Yvette A Heintzelman Seyfarth Shaw 55 E Monroe St Ste 4200 Chicago, IL 60603-5803 13123468000 Fax: 13122698869 ATTORNEY TO BE NOTICED
Abbey Gail Hairston District of Columbia Public Schools Office of the General Counsel 825 N Capital St NE Room 9095 Washington, DC 20002 12024425000 Fax: 12024425097 Email: abbey.hairston@k12.dc.us ATTORNEY TO BE NOTICED
represented by Gerald L Maatman, Jr (See above for address) ATTORNEY TO BE NOTICED
Yvette A Heintzelman
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District of Maryland (CM/ECF Live 3.0) - Docket Report

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Defendant
Valleywood Industries, Inc. doing business as Pallet Masters

(See above for address) ATTORNEY TO BE NOTICED
Abbey Gail Hairston (See above for address) ATTORNEY TO BE NOTICED
represented by Gerald L Maatman, Jr (See above for address) ATTORNEY TO BE NOTICED
Yvette A Heintzelman (See above for address) ATTORNEY TO BE NOTICED
Abbey Gail Hairston (See above for address) ATTORNEY TO BE NOTICED

Date Filed 08/01/2003 08/01/2003 08/01/2003 09/04/2003 09/04/2003 09/04/2003 09/04/2003 09/12/2003

#

Docket Text

1 COMPLAINT against Intraforce, Prolease HR, Inc., Valleywood Industries, Inc. , filed by Equal Employment Opportunity Commission.(nrm, Deputy Clerk) (Entered: 08/04/2003)
JURY TRIAL DEMAND by Equal Employment Opportunity Commission. (nrm, Deputy Clerk) (Entered: 08/04/2003)
2 REQUEST FOR WAIVER of Service sent to Prolease HR, Inc., Intraforce, Valleywood Industries, Inc. on 08/05/03 by Equal Employment Opportunity Commission. (nrm, Deputy Clerk) (Entered: 08/04/2003)
3 MOTION to Appear Pro Hac Vice the admission of Gerald L. Maatman, Jr. by Intraforce, Prolease HR, Inc., Valleywood Industries, Inc.. (eg, Deputy Clerk) (Entered: 09/04/2003)
4 MARGINAL ORDER granting 3 Motion of Prolease HR, Inc., et al. to Appear Pro Hac Vice the admission of Gerald L. Maatman, Jr.. Signed by Clerk on 9/3/03. (SEE DOCUMENT #3) (eg, Deputy Clerk) (Entered: 09/04/2003)
5 MOTION to Appear Pro Hac Vice the admission of Yvette A. Heintzelman by Intraforce, Prolease HR, Inc., Valleywood Industries, Inc.. (eg, Deputy Clerk) (Entered: 09/04/2003)
6 MARGINAL ORDER granting 5 Motion of Prolease HR, Inc., et al. to Appear Pro Hac Vice the admission of Yvette A. Heintzelman. Signed by Clerk on 9/3/03. (SEE DOCUMENT #5)(eg, Deputy Clerk) (Entered: 09/04/2003)
7 WAIVER OF SERVICE of Summons Returned Executed by Equal Employment Opportunity Commission. Prolease HR, Inc. waiver sent on 9/4/2003, answer due

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09/12/2003 09/26/2003
10/03/2003
10/13/2003 10/13/2003 10/13/2003
10/27/2003 10/27/2003 10/27/2003 10/28/2003 11/11/2003 11/12/2003 01/15/2004
01/15/2004
02/04/2004
02/04/2004 02/06/2004

11/3/2003. (eg, Deputy Clerk) (Entered: 09/12/2003)
8 Correspondence from Clerk re: "ECF" Warning Letter mailed to counsel. (eg, Deputy Clerk) (Entered: 09/12/2003)
9 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Valleywood Industries, Inc. waiver sent on 9/24/2003, answer due 11/24/2003. (Morocco, Maria) (Entered: 09/26/2003)
10 AMENDED COMPLAINT against Intraforce, Prolease HR, Inc., Valleywood Industries, Inc., filed by Equal Employment Opportunity Commission. (Attachments: # 1 certificate of service)(Morocco, Maria) (Entered: 10/03/2003)
11 ANSWER to Amended Complaint by Intraforce, Prolease HR, Inc..(Hairston, Abbey) (Entered: 10/13/2003)
12 MOTION for Extension of Time to File Answer by Valleywood Industries, Inc.. Responses due by 10/30/2003 (Hairston, Abbey) (Entered: 10/13/2003)
13 PAPERLESS ORDER granting 12 MOTION for Extension of Time to File Answer. Signed by Judge Andre M Davis on Ocotber 13, 2003. (Judge Davis) (Entered: 10/13/2003)
14 ANSWER to Amended Complaint by Valleywood Industries, Inc..(Hairston, Abbey) (Entered: 10/27/2003)
15 Local Rule 103.3 Disclosure of Corporate Affiliations and Financial Interests. (Hairston, Abbey) (Entered: 10/27/2003)
16 Local Rule 103.3 Disclosure of Corporate Affiliations and Financial Interests. (Hairston, Abbey) (Entered: 10/27/2003)
17 SCHEDULING ORDER:. Signed by Judge Andre M Davis on 10/28/03. (eg, Deputy Clerk) (Entered: 10/28/2003)
18 Correspondence re: PARTIES' REPORT IN RESPONSE TO THE COURT'S SCHEDULING ORDER (Heintzelman, Yvette) (Entered: 11/11/2003)
19 Correspondence re: Corrected Parties' Report In Response to the Courts Scheduling Order (Hairston, Abbey) (Entered: 11/12/2003)
20 Joint MOTION for Protective Order by Equal Employment Opportunity Commission. Responses due by 2/2/2004 (Attachments: # 1)(Morocco, Maria) (Entered: 01/15/2004)
21 ORDER granting 20 Motion for Protective Order and ENTERING CONFIDENTIALITY ORDER. Signed by Judge Andre M Davis on January 15, 2004. (Judge Davis) (Entered: 01/15/2004)
22 Emergency MOTION to Quash Defendants' Subpoena to Dr. Robert Vising by Equal Employment Opportunity Commission. Responses due by 2/23/2004 (Attachments: # 1 # 2 # 3 # 4)(Morocco, Maria) (Entered: 02/04/2004)
23 Correspondence re: Motion to Quash. (Judge Davis) (Entered: 02/04/2004)
24 MOTION to Appear Pro Hac Vice the admission of Jenny B. Friedman by Prolease HR, Inc.. (eg, Deputy Clerk) (Entered: 02/06/2004)

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District of Maryland (CM/ECF Live 3.0) - Docket Report

https://ecf.mdd.uscourts.gov/cgi-bin/DktRpt.pl?367555313857387-L_3...

02/06/2004
02/11/2004 02/12/2004 03/11/2004 04/12/2004 04/13/2004

25 MARGINAL ORDER granting 24 Motion of Prolease HR, Inc. to Appear Pro Hac Vice the admission of Jenny B. Friedman. Signed by Clerk on 1/6/04. (FOR DOCUMENT #25 SEE DOCUMENT #24) (eg, Deputy Clerk) (Entered: 02/06/2004)
26 STIPULATION TO WITHDRAW SUBPOENA AND MOTION TO QUASH by Equal Employment Opportunity Commission, Intraforce, Prolease HR, Inc., Valleywood Industries, Inc.. (Friedman, Jenny) (Entered: 02/11/2004)
27 MARGINAL ORDER withdrawing 22 Motion to Quash. Signed by Judge Andre M Davis on February 12, 2004. (Judge Davis) (Entered: 02/12/2004)
28 STATUS REPORT by Equal Employment Opportunity Commission, Intraforce, Prolease HR, Inc., Valleywood Industries, Inc.. (Friedman, Jenny) (Entered: 03/11/2004)
29 PROPOSED Consent Decree by Equal Employment Opportunity Commission. (Attachments: # 1)(Morocco, Maria) (Entered: 04/12/2004)
30 CONSENT DECREE and APPROVAL. Signed by Judge Andre M Davis on 4/13/04. (eg, Deputy Clerk) (Entered: 04/13/2004)

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