f\LED

t IN THE UNITED STATES DISTRICT COURT MAY 0 2001

r FOR

THE

WESTERN DISTRICT AUSTIN DIVISION

OF

TEXAS

W~Ul"t~n'~N\:1,1t,')t1H9~i~t4~C'JfCf~

IV

PUn CaR

EQUAL EMPLOYMENT OPPORTUNITY §

COMMISSION,

§

Plaintiff,

§

§

v.

§

§

§

ADAMS EXTRACT COMPANY,

§

Defendant.

§

§

COMPLAINT JURY TRIAL DEMAND

NATURE OF ACTION This is an action under Title VII ofthe Civil Rights Act of 1964, as amended, and Title Iof the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of sex, female, and retaliation. This action is also being brought to provide appropriate relief to Tiffany Mulder and other similarly situated females, who were adversely affected by such practices. The Commission alleges that Tiffany Mulder and other similarly situated females were subjected to sexual harassment on the basis oftheir sex, female, in violation ofSection 703(a) ofTitle VII. The Commission further alleges that at least one similarly situated female was constructively discharged as a result of the harassment. The Commission also alleges that at least one similarly situated female was discharged in violation of Section 704(a) of Title VII in retaliation for reporting the sexual harassment.
JURISDICTION AND VENUE 1. Jurisdiction ofthis 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 V.S.c. § 1981a.
I

2. The emp loyment practices alleged to be unlawful were and are now being committed within the jurisdiction ofthe United States District Court for the Western District ofTexas, Austin 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 Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. §2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Adams Extract Company, ("Adams Extract"), has continuously been a Texas corporation doing business in the State ofTexas and the City ofAustin, and has continuously had at least fifteen employees. 5. At all relevant times, Defendant Adams Extract 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, Tiffany Mulder filed a charge with the Commission alleging violations of Title VII by Defendant Adams Extract. All conditions precedent to the institution ofthis lawsuit have been fulfilled. 7. Since at least 1999, Defendant Adams Extract has engaged in unlawful employment practices at its Austin, Texas, facility, in violation ofSection 703(a) of Title VII, 42 U.S.c. §2000e2(a) by subj ecting Tiffany Mulder and other similarly situated females to ahostile work environment of sexual harassment.
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8. Since at least 1999, Defendant Adams Extract engaged in unlawful employment practices at its Austin, Texas facility, in violation ofSection 704(a) ofTitle VIT, 42 U.S.C. §2000e3(a) by discharging a similarly situated female for reporting the sexual harassment.
9. Since at least 1999, Defendant Adams Extract engaged in unlawful employment practices at its Austin, Texas facility, in violation ofSection 703(a) ofTitle VIT, 42 U.S.c. §2000e3(a) by constructively discharging a similarly situated female whose conditions of employment became so intolerable due to the sexual harassment she was forced to resign.
10. The effect ofthe practices complained ofin paragraphs seven, eight and nine above has been to deprive Tiffany Mulder and other similarly situated females of equal employment opportunities and otherwise adversely affect their status as employees because of their sex, female and because the sexual harassment was reported.
11. The unlawful employment practices complained of in paragraphs seven, eight and nine above were and are intentional.
12. The unlawful employment practices complained of in paragraphs seven, eight and nine above were and are done with malice or with reckless indifference to the federally protected rights of Tiffany Mulder and other similarly situated females.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Adams Extract, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in retaliation, retaliatory discharge, constructive discharge, sexual harassment or any employment practice which discriminates on the basis of sex, female.
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B. Order Defendant Adams Extract to institute and carry out policies, practices, and programs which provide equal employment opportunities and a non-hostile work environment for females and individuals who participate in protected activity, and which eradicate the effects of its past and present unlawful employment practices.
C. Order the Employer to make whole Tiffany Mulder by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph seven above, including but not limited to medical expenses and job search expenses, in amounts to be determined at trial.
D. Order the Employer to make whole Tiffany Mulder by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph seven above, including but not limited to emotional pain, suffering, inconvenience, mental anguish, depression, humiliation, loss of confidence and self-esteem, in amounts to be determined at trial.
E. Order the Employer to pay Tiffany Mulder punitive damages for its malicious and/or reckless conduct, in an amount to be determined at triaL
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Commission its costs in this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted,
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GWENDOLYN YOUNG REAMS Associate General Counsel
~~~~
ROBERT B. HARWIN Regional Attorney State Bar No. 076083 (District of Columbia)
~~~·w~~,.J
LINDA GUTIERREZ Supervisory Trial Attorney Texas State Bar No. 08642750
CYN HIACANO Trial Attorney Texas State Bar No. 00790420 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Antonio District Office 5410 Fredericksburg Rd., Ste. 200 San Antonio, TX 78229-3555 Telephone: (210) 281-7619 Telecopier: (210) 281-7669
ATTORNEYSFORPLAINT~F
5

 
 -

FILED

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS

MAR 2 8 2002

AUSTIN DIVISION

CLERK, U.S. 0 ,RICT COURT

WESTERN DIS

OF TEXAS

EQUAL EMPLOYMENT OPPORTUNITY §

BY ______~~~~-

COMMISSION,

§

§

Plaintiff,

§

§

v.

§ Civil Action No. AOICA262JN

§

ADAMS EXTRACT COMPANY,

§

§

Defendant.

§

CONSENT DECREE The parties to this Consent Decree are the Plaintiff, United States Equal Employment Opportunity Commission ("EEOC"), and Defendant, Adams Extract Company ("Adams Extract') This Consent Decree resolves the allegations raised by the EEOC in the above-referenced Civil Action No. AO 1CA262JN. The EEOC initiated this lawsuit under Title VII of the Civil Rights Act of 1964, as amended, and Title I of the Civil Rights Act of 1991, to correct alleged unlawful employment practices on the basis of sex, female, and retaliation, and to provide appropriate relief to Tiffany A. Mulder, Beatrice Huddleston, Melanie McClain, and Sherlyn Goff, who the EEOC maintains were adversely affect by these alleged practices. The EEOC alleges that Tiffany Mulder, Beatrice Huddleston, Melanie McClain, and Sherlyn Goff were subject to sexual harassment on the basis of their sex, female, in violation of Section 703(a) of Title VII. The EEOC further alleges that Melanie McClain was constructively discharged as a result of the harassment. The EEOC also alleges that Beatrice Huddleston was discharged in

-\-
I~

violation of Section 704(a) of Title VII in retaliation for reporting the sexual harassment. Adams Extract denies the allegations and asserts that all individuals are treated in a
fair and consistent manner without regard to sex. The EEOC and Adams Extract wish to settle this action without the risks,
uncertainties and expenses of continued litigation, under the terms in the Decree. IT IS ORDERED, ADJUDGED AND DECREED as follows: 1. This Court has jurisdiction of the subject matter of this action and the
parties, venue is proper, and all administrative prerequisites to the EEOC's filing of this action have been met. The parties stipulate to the Court's jurisdiction.
2. This Decree resolves those claims against Adams Extract raised in the EEOC's complaint in this case. EEOC expressly reserves its right to process and litigate any charges that may in the future be filed against Adams Extract.
3. This Decree is not an admission by Adams Extract of liability, which has been denied, nor is there any finding of discrimination or liability.
4. The duration of this Decree shall be three years from the date of its filing with the Court. This Court shall retain jurisdiction of this action during the period of this Decree and may enter further orders or modifications as may be necessary to effectuate the terms of this Decree.
5. Adams Extract IS enjoined, during the term of this Decree, from discriminating against any employee on the basis of sex, female and from engaging in any other act or practice which has the purpose or effect of unlawfully discriminating against any past, present, or future employee on the basis of sex, including sexual harassment and
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constructive discharge based upon sex. 6. Adams Extract shall provide its employees with a place of employment free
of discrimination on the basis of sex, or gender, and free of unlawful retaliation under Title VII.
7. In the event that Adams Extract or its agents or assigns violate this Consent Decree, EEOC shall have the right to request the Court to fashion a remedy for such violation. The remedy may, but need not, include tolling the term of the Consent Decree for up to the period of the violation.
8. Adams Extract will provide the following EEO training: a. Within 180 days of the date of entry of this Decree, Adams Extract
shall engage attorneys with the firm of Fulbright & Jaworski L.L.P. to provide EEO training to all owners, officers and managerial, supervisory, and non-supervisory employees at the administrative office at the main headquarters of Adams Extract in Austin, Texas, of not less than three hours. The training shall: (a) explain that sexual harassment is unlawful; (b) instruct what conduct may constitute sexual harassment; (c) explain the damaging effects of sexual harassment on its victims, their families, their coworkers , and the workplace environmenC and (d) ensure that supervisors and management personnel know how to enforce the company's anti-harassment policies.
b. During the term of this Consent Decree, Adams Extract will provide similar training consisting of not less than two hours for all officers and all owners, managerial, supervisory and non-supervisory employees in the administrative office at the main headquarters of the Company in Austin, Texas, during each of the
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second and third years of this Decree. c. Within 20 days prior to the date scheduled for this training, Adams
Extract will furnish to the EEOC a written report describing the EEO training, identifying the instructor and describing the instructor's qualifications to conduct such training, along with copies of all training materials, and the EEOC shall have the right to approve of such training and the instructors. Within 20 days after the EEO training has been completed, Adams Extract will provide to the EEOC a written report identifying each individual who attended this training and the date( s) and time of attendance. This training shall be in person and not via the Internet.
9. Adams Extract agrees to post a notice, for at least the duration of this Decree, of its intent to comply with Title VII. This notice is set forth in Exhibit "A," which is attached to this Decree. Adams Extract agrees to post a copy of Exhibit "A" in a conspicuous place at its facilities in Austin, Texas, within ten days after this Decree is approved by the Court and delivered to counsel for the Company.
10. Adams Extract will initiate the following reporting procedures: a. For the duration of this Consent Decree, Adams Extract agrees to
maintain and make available for inspection and copying, by EEOC, non-privileged records (including name, gender, social security number, address and telephone number) of each person who complains, either formally or informally, of sex discrimination and or retaliation. The report of any investigation will not be considered privileged, though legal advice based on the report shall be.
b. Adams Extract will make all documents or records referenced in
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Paragraph lO(a) available for inspection and copying within five (5) business days after
EEOC so requests. In addition, Adams Extract will make available any such complainants
and identified witnesses to any such complaint whom EEOC requests to interview in order
to verify compliance with this Consent Decree and shall permit a representative of EEOC
to meet with such persons on Adams Extract's premises or a mutually agreeable location
for such purposes on five (5) business days advance notice by EEOC.
c. Nothing contained in this Consent Decree shall be construed to
limit any obligation Adams Extract may otherwise have to maintain records under Title
VII, the ADEA, or any other law or regulation.
11. Adams Extract will implement the following "Zero-Tolerance Policy and
Equality Objectives."
a. In addition to the terms concermng the posting required in
Paragraph 9 of this Consent Decree, Adams Extract affirms and will implement the
following "Statement of Zero-Tolerance Policy and Equality Objectives."
Adams Extract maintains a zero-tolerance policy concerning sexual harassment and retaliation. Adams Extract responds swiftly and firmly to any acts of sexual harassment and retaliation of which it becomes aware, regardless of the position held by the alleged harasser within Adams Extract. Adams Extract maintains a disciplinary system that is designed to strongly deter acts of sexual harassment and retaliation and to encourage the reporting of acts of sexual harassment. Any supervisory or managerial employee who allows an act of sexual harassment to be unaddressed will be subject to disciplinary action.
b. Adams Extract shall notify all of its current employees of this policy
within 10 days after the entry of this Consent Decree by providing a copy of this statement

to all of its current employees. c During the term of this Consent Decree, Adams Extract shall notity
all employees hired after the entry of this Consent Decree of this policy by providing this Zero Tolerance Policy to each new employee.
12. Adams Extract agrees to provide a neutral reference in the form of the dates of employment, position held and last rate of pay in accordance with Adams Extract Policy for Tiffany A Mulder to anyone inquiring as to her work history with Adams Extract, including prospective employers who may request such a reference. Adams Extract also agrees not to disclose the filing of this Complaint, or the underlying charges filed by Mulder, Huddleston, McClain and Goff, to any prospective employers who may inquire to Adams Extract about their work history with Adams Extract. This provision shall survive the expiration of the Decree.
13. Adams Extract, in settlement of this dispute, shall pay to Tiffany A. Mulder the sum of Thirty-two Thousand Dollars ($32,000). This shall be accomplished as follows: Three Thousand Dollars ($3,000) shall be paid when this Decree is approved, nine semiannual payments of Three Thousand Dollars ($3,000), and six months thereafter a single final payment of Two Thousand Dollars ($2,000). Payment shall be mailed directly to Tiffany A. Mulder at P.O. Box 146, Wimberly, Texas 78676. The payment shall be made within 14 days after this Decree has been entered by the Court. A copy of the settlement checks and any accompanying transmittal documents shall be forwarded to Robert B. Harwin, Regional Attorney, San Antonio District Office, United States Equal Employment Opportunity Commission, 5410 Fredericksburg Road, Suite 200, San
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Antonio, Texas 78229. 14. The terms of this Decree shall be binding upon the EEOC and Adams
Extract, their agents, officers, employees, servants, successors, and assigns, as to the issues resolved here.
15. The parties to this Decree shall bear their own costs and attorney's fees incurred in this action. The parties agree that pursuant to Section 706(k) of Title VII, 42 USC, ~ 2000e·5(k), there is no "prevailing party" on this action or proceeding.
SO ORDERED AND ENTERED ZS-lh day of_~-----=-r.4-+--,,---,¥-_
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1ktaEO;L~G Dated: March 18,2002 0--.'
BRIAN State Bar No, 08439800 THOMAS NESBITT State Bar No, 24007738
FULBRIGHT & JAWORSKI, L.L.P, 600 Congress Ave, Suite 2400 Austin, Texas 78701 Tel: (512)474~5201 Fax: (512)536~4598
ATTORNEYS FOR DEFENDANT ADAMS EXTRACT

Respectfully submitted,
GWENDOL YN YOUNG REAMS Acting Deputy General Counsel
~~<
ROBERT B, HARWIN Regional Attorney D,C. State Bar No, 0760873
~~~~
LINDA GUTIERREZ Supervisory Trial Attorney
lfitt~~C~ Te1s State ~ar No. 08642750
CYN HIAM. C 0 Trial Attorney Texas State Bar No. 00790420
EQUAL EMPLOYMENT OPPORTUNITY CO:MMISSION
San Antonio District Office 5410 Fredericksburg Rd., Ste. 200 San Antonio, TX 78229-3555 (210) 281-7673 (210) 281~7669 FAX
ATTORNEYS FOR PLAINTIFF EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

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NOTICE TO ALL EMPLOYEES
ADAMS EXTRACT COMPANY SUPPORTS FEDERAL LAW REQUIRING THERE BE NO DISCRIMINATION AGAINST ANY APPLICANT OR EMPLOYEE BECAUSE OF HIS OR HER RACE, COLOR SEX NATIONAL ORIGIN. RELIGION. AGE OR DISABILITY AND REAFFIRMS ITS COMMITMENT NOT TO DISCRIMINATE AGAINST ANY APPLICANT OR EMPLOYEE ON ANY TERM OR CONDITION OF EMPLOYMENT, NOR TO ALLOW HARASSMENT OF ANY EMPLOYEE BECAUSE OF HIS OR HER SEX
ADAMS EXTRACT COMPANY WILL NOT DISCRIMINATE AGAINST ANY EMPLOYEE FOR OPPOSING EMPLOYMENT DISCRIMINATION OR FOR FILING OR PARTICIPATING IN A CHARGE OF EMPLOYMENT DISCRIMINATION,
IF YOU BELIEVE YOU ARE BEING DISCRIMINATED AGAINST IN ANY TERM OR CONDITION OF YOUR EMPLOYMENT BECAUSE OF YOUR RACE. RELIGION. COLOR. NATIONAL ORIGIN. SEX. AGE. OR DISABILITY. OR THAT YOU ARE BEING SUBJECT TO HARASSMENT OR THAT YOU ARE BEING RETALIATED AGAINST FOR HAVING ENGAGED TN TITLE VII·PROTECTED ACTIVITY. YOU MUST REPORT THE DISCRIMINATION OR HARASSMENT. YOU SHOlJLD MAKE THE REPORT TO YOUR DIRECT SUPERVISOR. HOWEVER. ADAMS EXTRACT UNDERSTANDS THAT IT WILL SOtv1ETIMES BE INAPPROPRIATE TO MAKE A REPORT TO YOUR DIRECT SUPERVISOR. FOR EXAMPLE. THE REPORT MAY RELATE TO YOUR DIRECT SUPERVISOR OR SOMEONE WHO IS PERSONAL FRIENDS WITH YOUR DIRECT SUPERVISOR. UNDER THESE OR SIMILAR CIRCUMSTANCES. IF IT WOULD BE INAPPROPRIATE TO MAKE SUCH A REPORT TO YOUR DIRECT SUPERVISOR. YOU MUST REPORT THE DISCRIMINATION. RETALIATION OR HARASSMENT TO THE HUMAN RESOURCES MANAGER. IF IT WOULD BE INAPPROPRIATE TO MAKE SUCH A REPORT TO THE HUMAN RESOURCES MANAGER. YOU MUST MAKE A REPORT TO ANOTHER SUPERVISOR OR MANAGER FOR ADAMS EXTRACT. IF IT WOULD BE INAPPROPRIATE TO MAKE A REPORT TO ANY OF THE INDIVIDUALS DESIGNATED ABOVE, YOU MAY MAKE A REPORT TO THE LAW OFFICE OF GAUL AND DUMONT AT 105 SOUTH ST. MARY'S, SUITE 950, SAN ANTONIO, TEXAS 78205, TELEPHONE 210·225·0685. THIS FIRM IS AN OUTSIDE CONSULTANT WHOSE JOB IS TO ENFORCE ADAMS EXTRACT'S POLICY OF NON·DISCRIMINATION, COMPLAINTS MAY BE MADE IN WRITING OR BY TELEPHONE.
COMPANY POLICY REQUIRES THAT YOU REPORT ANY DISCRIMINATION, HARASSMENT OR RETALIATION TO ADAMS EXTRACT. YOU MAY ALSO MAKE A REPORT TO THE UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, 5410 FREDERICKSBURG ROAD, SUITE 200. SAN ANTONIO, TEXAS 78229·3550. (210) 281·7600 OR
(SOO) 669·4()O().
NO RETALIATORY ACTION MAY BE TAKEN AGAINST YOU FOR SEEKING ASSISTANCE, FILING A CHARGE, OR COMMUNICATING WITH THE UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.
EEOC ENFORCES TITLE VII OF THE CIVIL RIGHTS ACT OF 1964. WHICH PROHIBITS EMPLOYMENT DISCRIMINATION BASED ON RACE. COLOR. RELIGION. SEX OR NATIONAL ORIGIN: THE AGE DISCRIMINATION IN EMPLOYMENT ACT: THE EQUAL PAY ACT: PROHIBITIONS AGAINST DISCRIMINATION AFFECTING INDIVIDUALS WITH DISABILITIES: SECTIONS OF THE CIVIL RIGHTS ACT OF 1991. AND TITLE I OF THE AMERICANS WITH DISABILITIES ACT. WHICH PROHIBITS DISCRIMINATION AGAINST PEOPLE WITH DISABILITIES IN THE PRIVATE SECTION AND STATE AND LOCAL GOVERNMENTS.
EXHIBIT A

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

https://ecf.txwd.uscourts.gov/cgi-bin/DktRpt.pl?357113946839412-L_3...

U.S. District Court [LIVE] Western District of Texas (Austin) CIVIL DOCKET FOR CASE #: 1:01-cv-00262-JRN

CLOSED

EEOC v. Adams Extract Co. Assigned to: Honorable James R. Nowlin Demand: $0 Cause: 42:2000 Job Discrimination (Sex) Plaintiff Equal Employment Opportunity Commission
V. Defendant Adams Extract Co.

Date Filed: 05/01/2001 Date Terminated: 03/28/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Cynthia M. Cano The Law Office of Jeffrey A. Goldberg 9901 IH-10 West Suite 690 San Antonio, TX 78230 (210) 690-2200 Fax: 210/690-0438 Email: cmc_goldberglaw@sbcglobal.net LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Brian Strother Greig Fulbright & Jaworski L.L.P. 600 Congress Ave. Suite 2400 Austin, TX 78701 (512) 536-4510 Fax: 512/536-4598 Email: bgreig@fulbright.com TERMINATED: 11/22/2002 LEAD ATTORNEY
Sean E. Breen Herman, Howry & Breen, LLP 1900 Pearl St. Austin, TX 78705-5408 (512) 474-7300 Fax: 512/474-8557 Email: sbreen@hermanhowry.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Thomas A. Nesbitt Fulbright and Jaworski L.L.P. 600 Congress Avenue Suite 2400 Austin, TX 78701 512-536-2472 Fax: 512-536-4598 Email: tnesbitt@fulbright.com TERMINATED: 11/22/2002 LEAD ATTORNEY

Date Filed 05/01/2001 05/01/2001 05/02/2001 06/22/2001 08/13/2001 08/22/2001 08/23/2001
10/29/2001
10/30/2001
11/01/2001
11/01/2001 11/16/2001 03/22/2002 03/27/2002

#

Docket Text

Case assigned to Honorable James R. Nowlin (mc2) (Entered: 05/02/2001)
1 Complaint filed. Filing Fee: waived (Pages: 5) (mc2) (Entered: 05/02/2001)
Court file prepared and forwarded to Judge Nowlin. (mc2) (Entered: 05/02/2001)
2 Waiver of Service by Adams Extract Co. ; Notice and Request Mailed on 6/14/01 ; Answer due on 8/13/01 for Adams Extract Co. (mc2) (Entered: 06/22/2001)
3 Answer by Adams Extract Co. (mc2) (Entered: 08/14/2001)
4 Joint motion by EEOC, Adams Extract Co. to extend time for submission of proposed scheduling order (mc2) (Entered: 08/23/2001)
5 Order granting joint motion to extend time for submission of proposed scheduling order [4-1] until 11/12/01. (Noticed 8/23/01.) (mc2) (Entered: 08/23/2001)
6 Second Joint motion by EEOC, Adams Extract Co. to extend time - to extend deadline for submission of proposed scheduling order (mc2) (Entered: 10/30/2001)
7 Order denying joint motion to extend time - to extend deadline for submission of proposed scheduling order [6-1]. (Noticed 10/31/01.) (mc2) (Entered: 10/31/2001)
8 Scheduling order setting Joining of parties, amending of pleadings on 3/18/02 Deadline for filing of all motions 4/30/02 Discovery cutoff 4/15/02 ; Alternate Dispute Resolution Report due by 11/15/01 (fe) (Entered: 11/02/2001)
9 Joint discovery/case management plan (submitted by plaintiff and defendant). (mc2) (Entered: 11/02/2001)
10 Alternate Dispute Resolution Report filed by EEOC, Adams Extract Co., Party(s) do not agree to Alternate Dispute Resolution (mc2) (Entered: 11/16/2001)
11 Order set docket call for 1:30 4/3/02 (td) (Entered: 03/22/2002)
12 Joint motion by EEOC, Adams Extract Co. to enter consent decree (mc2) (Entered: 03/27/2002)

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03/28/2002
03/28/2002 03/28/2002 11/19/2002 11/22/2002

13 Consent judgment for EEOC against Adams Extract Co. (Pages: 7) enjoining defendant from discriminatory practices..., each party to bear own costs and attorney's fees... (Noticed 3/29/02.) (mc2) (Entered: 03/29/2002)
14 Judgment for EEOC against Adams Extract Co. (Pages: 1) (see consent judgment above). (Noticed 3/29/02.) (mc2) (Entered: 03/29/2002)
Case closed (mc2) (Entered: 03/29/2002)
15 Unopposed Motion by Adams Extract Co. for Brian S. Greig and Thomas A. Nesbitt to withdraw as attorney (mc2) (Entered: 11/20/2002)
16 Order granting motion for Brian S. Greig and Thomas A. Nesbitt to withdraw as attorney [15-1] and substituting Sean E. Breen. (Noticed 11/22/02.) (mc2) (Entered: 11/22/2002)

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