Case 6:99-cv-01181-JA Document 1 Filed 09/16/1999 Page 1 of 5

:--.~. IN THE UNITED STATES DISTRICT COURT _, !':JS 0
FOR THE MIDDLE DISTRICT OF FLORIDA. ': ,1; 16'

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ORLANDO D I V I S I O N , .... -". 4;,;1/1"'\

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EQUAL EMPLOYMENT OPPORTUNITY

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COMMISSION,

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Plaintiff,
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) CIVIL ACTION NO. qq-II g/-Ci v-Or/-/9,
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MEDICAL CENTER RADIOLOGY GROUP OF ) DRS. CURRY, HARDING, GEORGE & ELISCU, )

COMPLAINT

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JURY TRIAL DEMANDED

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INJUNCTIVE RELIEF SOUGHT

Defendant.

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NATURE OF THE 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 retaliation, and to

provide appropriate reliefto Mr. Joseph J. Waechter who was adversely affected by such practices.

As stated with greater partiCUlarity in paragraph 7, the Commission alleges that Mr. Waechter was

retaliated against by his employer, Medical Center Radiology Group ofDrs. Curry. Harding, George

& Eliscu, P.A.. ("Medical Radiology"), for complaining ofsexual harassment that certain employees

were being subjected to by Dr. Hedrick Rivero, chiefexecutive officer ofMedical Radiology. The

retaliation consisted ofsubjecting Mr. Waechter to adverse terms and conditions ofemployment, as

well as discharge.

JURISDICTION AND VENUE

1. Jurisdiction ofthis Courtisinvokedpursuantto 28U.S.C. §§451. 1331. 1337, 1343

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Case 6:99-cv-01181-JA Document 1 Filed 09/16/1999 Page 2 of 5
and 1345. This action is authorized and instituted pursuant to Section 706(t)(l) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(t)(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 ofthe Untied States District Court for the Middle District ofFlorida, Orlando Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission ("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(t)(l) and (3) of Title VII, 42 U.S.c. § 2000e-5(t)(1) and (3). 4. At all relevant times, Medical Radiology has continuously been doing business in the State of Florida and the City of Orlando, and has continuously had at least 15 employees. 5. At all relevant times Medical Radiology 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 before the institution of this lawsuit, Mr. Joseph J. Waechter filed a charge with the Commission alleging violations of Title VII by Medical Radiology. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least November of 1997, Defendant Employer engaged in unlawful employment practices at its Orlando, Florida location in violation of Section 703(a) and Section
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Case 6:99-cv-01181-JA Document 1 Filed 09/16/1999 Page 3 of 5
704(a) of Title VIT, 42 U.S.C. §2000e-2(a) and §2000e-3(a): a. In or about November and December of 1997, Mr. Waechter observed, and certain employees reported to him incidents ofsexual harassment, in the form of unwelcome physical and verbal conduct that were carried out by Dr. Hedrick Rivero, the chief executive officer ofMedical Radiology. b. On or about December 8, 1997, Mr. Waechter complained to representatives of Medical Radiology of the unlawful sexual harassment. Thereafter, Defendant retaliated against Mr. Waechter for complaining ofthe unlawful sexual harassment by subjecting him to adverse terms and conditions of employment, including unfavorable work schedules andjob assignments, and subsequently discharged him from his position as Medical Radiology's administrator.
8. The effect of the conduct complained of in paragraph 7 above has been to deprive Mr. Waechter of equal employment opportunities and otherwise adversely affect his status as an employee because of his good faith opposition to what he believed to be unlawful employment practices.
9. The unlawful employment practices complained of in paragraph 7 above were intentional.
10. The unlawful employment practices complained ofin paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Mr. Waechter.
PRAYER FOR RELIEF
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Case 6:99-cv-01181-JA Document 1 Filed 09/16/1999 Page 4 of 5
Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, their officers, successors, assigns, and all persons in active concert or participation with them, from engaging in sexual harassment and any other employment practice which discriminates on the basis ofan employee's opposition to an unlawful employment practice. B. Order Defendant, to institute and carry out policies, practices, and programs which provide equal employment opportunities for its employees, and which eradicate the effects ofits past unlawful employment practices. C. Order Defendant to make whole Mr. Waechter, by providing appropriate back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative reliefnecessary to eradicate the effects of its unlawful employment practices, including but not limited to reinstatement and rightful place promotion or front pay. D. Order Defendant to make whole Mr. Waechter, by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including out of pocket losses in amounts to be determined at trial. E. Order Defendant to make whole Mr. Waechter, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained ofin paragraph 7 above, including emotional pain, suffering, inconvenience, humiliation, and loss of enjoyment of life, in amounts to be determined at trial. F. OrderDefendant to pay Mr. Waechter punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
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Case 6:99-cv-01181-JA Document 1 Filed 09/16/1999 Page 5 of 5
G. Grant such further relief as the Court deems necessary and proper in the public
interest.
H. Award the Commission its costs of this action.
JURy TRIAL DEMAND
The Commission requests a jury trial on all questions offact raised by its complaint.
C. GREGORY STEWART General Counsel Designate
GWENDOLYN YOUNG REAMS Associate General Counsel
DELNER FRANKLIN-THOMAS Regional Attorney
GILBERT CARRILLO
Trial Attorney Florida Bar Number: 0083054
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Miami District Office One Biscayne Tower Two South Biscayne Boulevard Miami, Florida 33131-1805 Telephone: (305) 530-6012 Facsimile: (305) 536-4494

S :\LEGAL \ Waechter\Pleadings\Complaint.2

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 Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 1 of 11
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FOR THE MIDDLE DISTRICT OF FLORIDA

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CIVIL ACTION NO.

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MEDICAL CENTER RADIOLOGY CENTER )

OF DRS. CURRY, HARDING, GEORGE

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& ELISCU, P.A.

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CONSENT DECREE

1. This Consent Decree (the "Decree") is made and entered

into by and between Plaintiff, the Equal Employment Opportunity

Commission (hereinafter referred to as the "Commission" or "EEOC")

and Defendant Medical Center Radiology Group of Drs. Curry,

Harding, George & Eliscu, P.A. (hereinafter referred to as "Medical

Center Radiology Group"). The Commission and the Medical Center

Radiology Group are collectively referred to herein as "the

Parties."

2. On September 16, 1999, EEOC initiated this action by

filing its Complaint against Medical Center Radiology Group.

EEOC's Complaint alleged that Medical Center Radiology Group

violated Title VII of the Civil Rights Act of 1964, as amended,

including but not limited to, amendments authorized by the Civil

Rights Act of 1991, 42 U.S.C. Section 2000e et seq. ("Title VII") .

The Complaint arose out of the allegations in an EEOC charge filed

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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 2 of 11
by Joseph Waechter against Medical Center Radiology Group. 3. On November 29, 1999, the Medical Center Radiology Group
filed its Answer to EEOC's Complaint, denying its actions were discriminatory in any way.
4. In the interests of resolving this matter, to avoid the costs of litigation, and as a result of having engaged in comprehensive settlement negotiations, the Parties have agreed that this action should be finally resolved by the entry of this Decree. This Decree is final and binding upon the Parties, their successors and assigns.
5. The Parties agree that this Decree resolves all claims against Medical Center Radiology Group arising out of EEOC Charge Number 150-98-3523, and the Complaint filed in this action, and constitutes a complete resolution of all claims that were made by the Commission against Medical Center Radiology Group in this action or that existed against Medical Center Radiology Group in this action. The Parties further agree that this Decree does not resolve any Charges of Discrimination, if any, that may be pending with the EEOC other than the Charges referred to in this paragraph.
6. This Decree constitutes the complete agreement between the EEOC and Medical Center Radiology Group with respect to the matters referred to herein. No representations or inducements to compromise this action have been made, other than those recited or referenced in this Decree. No waiver, modification or amendment of
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 3 of 11
any provision of this Decree shall be effective unless made in writing, approved by all parties to this Decree and approved or ordered by the Court.
NOW, THEREFORE, the Court having carefully examined the terms and provisions of this Consent Decree, and based on the pleadings filed by the parties, it is ORDERED, ADJUDGED AND DECREED THAT:
7. This Court has jurisdiction of the subject matter of this action and over the parties for the purposes of entering and enforcing this Decree.
GENERAL INJUNCTIVE PROVISIONS 8. Medical Center Radiology Group, its officers, managers, employees, agents and partners, are enjoined from discriminating against any employee who opposes any of Defendant's practices which the employee believes to be a violation of Title VII; who files a charge of discrimination with the EEOC alleging violation(s) of such statute; who cooperates with the EEOC in the investigation and/or prosecution of any charge of discrimination; or who cooperated in the investigation or prosecution of this case. 9. Medical Center Radiology Group, its officers, managers, employees, agents and partners, agree that it will not engage in any conduct which violates Title VII of the Civil Rights Act of 1964, as amended, by adversely affecting the terms and conditions of any individual's employment or by discharging an employee for opposing or participating in any Title VII statutorily protected
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 4 of 11
activity. TRAINING
10. Medical Center Radiology Group has established a written policy of compliance with Title VII. A copy of Medical Center Radiology Group Title VII compliance policy has been provided to the EEOC and Medical Center Radiology Group certifies that a complete copy of its Title VII policy has been provided to all its current employees at all of its facilities. Medical Center Radiology Group further agrees that all new employees will be provided a copy of the policy as part of the new employee orientation process.
11. In order to further insure the effective implementation of Medical Center Radiology Group's anti-discrimination policies, Medical Center Radiology Group will conduct training for all of its managers and supervisory personnel at its corporate facility, in Orlando, Florida, on all aspects of Title VII. Such training will be at least two hours in length and shall be conducted within three months of the entry of this Decree and on a yearly basis I thereafter, throughout the duration of this decree. Medical Center Radiology Group agrees to provide the EEOC, at least two weeks notice before it conducts its training session(s) I date(s) of the training, copies of all training material to be used at the training session, the name of the individual (s) who will be providing the training material and a list of the names and titles
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 5 of 11

of each employee who will be in attendance at the training.

Additionally, Medical Center Radiology Group agrees that the EEOC

shall, at its discretion, be in attendance at the training

session(s) .

DEVELOPMENT OF COMPLAINT PROCEDURE

12. The Medical Center Radiology Group will develop a plan

for the creation of an ombudsperson position. This position will

exist for no less than the three year duration period of this

Consent Decree. The purpose of this position will be to create a

non-threatening outlet to report complaints of discrimination based

on sex, race, religion, color, national origin, age, and/or

disability without fear of retaliation. An investigation and

complaint resolution protocol will be created for use by this

position. The individual selected for the ombudsperson position is

subject to EEOC approval.

A. This plan will be submitted to the EEOC within thirty days

from entry of the consent decree;

B. The plan will be implemented thirty days after the parties

agree upon it;

C.

The investigation and complaint protocol will be

documented in Medical Center Radiology Group's handbook and posted

in a conspicuous locations to be agreed upon;

D. This document will include language explaining that

complaining to the ombudsperson in no way curtails an individual's

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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 6 of 11
federally protected right to make a charge of discrimination to the EEOC;
E. The names of any individuals making complaints of discrimination based on sex and retaliation, to the ombudsperson, their contact information, and nature of the complaint, will be reported to the EEOC on a quarterly basis for three years following entry of the consent decree;
F. If an individual or the Commission is unsatisfied with the handling of a complaint of discrimination, the parties will meet in an attempt to resolve the matter. If a resolution cannot be met in this manner, the Court through this decree orders that the parties seek mediation over the matter. If mediation fails the Commission may bring the matter before the Court for injunctive relief.
POSTING 13. Medical Center Radiology Group will post within seven days from the Court's execution of this Decree an 11" x 17" size copy of the Notice attached hereto as Exhibit A. Said notice shall be posted at all Medical Center Radiology Group facilities for the duration of this Decree in conspicuous locations accessible to all employees.
MONITORING 14. Medical Center Radiology Group will retain all employment records relating in any way to any complaint, allegation and investigation of sex discrimination or retaliation at any of
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 7 of 11
Medical Center Radiology Group's facilities for the duration of this Decree and as required by law.
15. Medical Center Radiology Group will certify to the EEOC every six (6) months throughout the duration of this Decree that it is in compliance with all aspects of this Decree. The first such certification will be due no later than February I, 2001. With each such certification, the Medical Center Radiology Group will provide the EEOC with the name, address and phone number of any person who alleges they have been subjected to sexual harassment or retaliation while working at any of the Medical Center Radiology Group's facilities during the preceding six (6) months. Medical Center Radiology Group will also state its actions taken in response to each such allegation. Medical Center Radiology Group will provide, upon request by the Commission any and all documentation associated with each such complaint.
16. Medical Center Radiology Group will retain copies of all sexual harassment complaints along with the results of internal investigations for the duration of this Decree, and shall make the same available to the EEOC for inspection on a bi-annual basis, at the EEOC's request.
MONETARY RELIEF 17. Medical Center Radiology Group shall pay Joseph Waechter a lump sum in the amount of $114,400, which represents back pay, less amounts required to be withheld for federal, state, and local
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 8 of 11
income taxes, and the sum of $800.00 which represents attorney fees. Medical Center Radiology Group will also issue an I.R.S. form and W-2, and shall be responsible for the payment of the employer's share of any federal, state, or local taxes, and social securi ty wi thholdings. Addi tionally, Medical Center Radiology Group shall pay to Joseph Waechter a lump sum of $50,000, which represents compensatory and punitive damages and shall issue a form 1099 itemizing same. Both payments shall issue within fifteen (15) calendar days from the Court's execution of this Decree, and shall be made by certified check and forwarded to Joseph Waechter at his home address, by certified mail with a return receipt requested. Said copies shall be forwarded to the attention of Kenneth L. Gillespie, EEOC Trial Attorney, U.S. Equal Employment Opportunity Commission, 2 South Biscayne Boulevard, Suite 2700, Miami, Florida 33131.
18. If the Medical Center Radiology Group fails to tender the above-mentioned payments as set forth in paragraph 17, then the Medical Center Radiology Group shall pay interest on the defaulted payment at the rate calculated pursuant to 26 U. S. C. Section 6621 (b) until the same is paid, and bear any additional costs incurred by the EEOC caused by the non-compliance or delay of the Defendant.
ENFORCEMENT OF DECREE 19. The Commission and Medical Center Radiology Group will
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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 9 of 11

make best efforts to effectuate the terms of this Decree.

20. The Commission shall have independent authority to seek

the judicial enforcement of any aspect, term or provision of this

Decree.

COSTS

21. Each Party shall bear its own costs and attorneys' fees

associated with this litigation.

DURATION OF CONSENT DECREE

22. The duration of this Decree shall be three (3) years from

the date of entry of the Decree.

~~

23. This case will be dismissed with prejudice. H0i"ver the

Ur cort will r1ain juri~iction to )nforce this Co sent Decree

~ring the~ree year~riod that;faid Decree is i eff ct.

SO ORDERED, ADJUDGED AND DECREED, this 1/

t1,,~
day of .Jttne,

2000.

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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 10 of 11

AGREED TO: FOR THE PLAINTIFF, UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

by: G9J!)j{fJ~ Gilbert Carrillo

Date:

I t

Acting Regional Attorney

U.S. Equal Employment Opportunity Commission

Miami District Office

One Biscayne Tower, Suite 2700

2 South Biscayne Boulevard

Miami, Florida 33131

AGREED TO: FOR THE DEFENDANTS
by:

Date:

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Case 6:99-cv-01181-JA Document 18 Filed 08/14/2000 Page 11 of 11

NOTICE TO ALL EMPLOYEES
This notice is being posted pursuant to an agreement reached
in Civil Action NO.99-1181-Civ-orl-~ in the Middle District of
Florida. Medical Center Radiology Group of Drs. Curry, Harding, George & Eliscu, P.A., will not discriminate against employees in violation of Title VII of the Civil Rights Act of 1964 ("Title VII"). Title VII protects individuals from discrimination in all aspects of their employment, including hiring, because of their race, religion, color, national origin, or sex.
Medical Center Radiology Group of Drs. Curry, Harding, George & Eliscu, P.A., assures its employees that it supports Title VII and will not take any action against an individual because he/she has exercised his/her rights under the law to oppose discriminatory acts or to file charges with the EEOC.
This notice shall remain posted for three years from the date signed. Employees or applicants for employment who have questions about their rights under Title VII or any other federal antidiscrimination law may telephone the Miami District Office of the Equal Employment Opportunity Commission at 1-800-669-4000, (305) 530-6000 or (305)530-6007.

Signed this

day of _____________ , 2000.

PRESIDENT/CEO, Medical Center Radiology Group

 
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CLOSED, FRC, KRS
U.S. District Court Middle District of Florida (Orlando) CIVIL DOCKET FOR CASE #: 6:99-cv-01181-JA

EEOC v. Medical Center Group Assigned to: Judge John Antoon II Demand: $0 Cause: 28:451 Employment Discrimination Plaintiff Equal Employment Opportunity Commission
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Date Filed: 09/16/1999 Date Terminated: 07/31/2000 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by C. Gregory Stewart Equal Employment Opportunity Commission Miami District Office One Biscayne Tower 2 S. Biscayne Blvd., Suite 2700 Miami, FL 33131 305/530-6010 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Delner Franklin-Thomas Equal Employment Opportunity Commission Suite 2700 2 S Biscayne Blvd Miami, FL 33131 305/530-6001 Email: delner.franklin-thomas@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gilbert Carrillo Law Office of Gilbert Carrillo P.A 2651 SW 109 Avenue Davie, FL 33328-1003 954/258-4565 Fax: 305/530-6121 Email: g2651carrillo@aol.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gwendolyn Y. Reams Equal Employment Opportunity Commission Miami District Office
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V.
Defendant
Medical Center Radiology Group of Drs. Curry, Harding, George & Eliscu, P.A.

One Biscayne Tower 2 S. Biscayne Blvd., Suite 2700 Miami, FL 33131 305/530-6010 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Kenneth Lawrence Gillespie Equal Employment Opportunity Commission Miami District Office One Biscayne Tower 2 S. Biscayne Blvd., Suite 2700 Miami, FL 33131 305/530-6010 Email: kenneth.gillespie@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Alan M. Gerlach, Jr. Adventist Health System 111 N Orlando Ave Winter Park, FL 32789 407/975-1410 Fax: 407/975-1414 Email: agerlach@ahss.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jack R. Elliott Law Office of Jack R. Elliott 903 S. Riverside Dr. Indialantic, FL 32903 321/768-8795 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/16/1999 09/16/1999

#

Docket Text

1 COMPLAINT and demand for jury trial filed - injunctive relief sought. Action filed to correct unlawful employment practices. (spr) (Entered: 09/16/1999)
MAGISTRATE JUDGE CASE ASSIGNMENT Magistrate assigned: Karla R. Spaulding (spr) (Entered: 09/16/1999)

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09/16/1999
09/16/1999 09/17/1999 09/27/1999 10/28/1999 11/29/1999 12/27/1999 01/24/2000
01/24/2000
01/27/2000
02/02/2000 02/04/2000 04/26/2000 04/26/2000
04/27/2000 06/05/2000 07/31/2000

2 ORDER directing counsel to review and certify compliance with Local Rule 1.04(c) within 10 days ( Signed by Judge Patricia C. Fawsett ) ctc (spr) (Entered: 09/16/1999)
SUMMONS(ES) issued for Medical Center Group. (spr) (Entered: 09/16/1999)
3 NOTICE of designation under Local Rule 3.05 - TRACK 2. (ctc) (spr) (Entered: 09/17/1999)
4 CERTIFICATE OF COMPLIANCE by EEOC with [2-1] order - no related cases (spr) (Entered: 09/27/1999)
5 NOTICE of compliance with Local Rule 3.05 by EEOC (spr) (Entered: 10/28/1999)
6 ANSWER and defenses to Complaint by defendant Medical Center Group (jrm) (Entered: 11/29/1999)
7 CASE MANAGEMENT REPORT. (spr) (Entered: 12/28/1999)
8 ORDER that each party shall file a signed, written response to Question 1(b) of the case management report within 10 days from the date of this Order. ( Signed by Judge Patricia C. Fawsett ) ctc (spr) (Entered: 01/24/2000)
9 CASE MANAGEMENT AND SCHEDULING ORDER setting Joining of parties, amending of pleadings on 5/30/00; Deadline for filing of motions 10/16/00; Discovery cutoff 9/1/00; Pretrial statement due on or before 12/18/00; Jury trial set for the trial term commencing on 3/1/01 before Judge Patricia C. Fawsett ( signed by Judge Patricia C. Fawsett ) ctc (spr) (Entered: 01/24/2000)
10 NOTICE Scheduling Final Pretrial Conference: Set final pretrial conference for 10:00 a.m. on 2/2/01 before Magistrate Judge Karla R. Spaulding ctc (spr) (Entered: 01/27/2000)
11 RESPONSE by EEOC to Question 1(b) of case management report pursuant to [8-1] order (spr) (Entered: 02/02/2000)
12 COMPLIANCE by Medical Center Group with [8-1] order concerning Question 1(b) of case management report (spr) (Entered: 02/07/2000)
13 MOTION by Medical Center Group with memorandum in support for leave to file motion under seal (spr) (Entered: 04/27/2000)
14 ORDER denying as unnecessary [13-1] defendant's motion for leave to file motion under seal; and order of recusal . The Clerk is directed to reassign the case under the blind assignment system. ( Signed by Judge Patricia C. Fawsett ) ctc (spr) (Entered: 04/27/2000)
15 NOTICE OF CASE REASSIGNMENT to the Unassigned Docket. New case number is 6:99-cv-1181-Orl-99A ctc (spr) (Entered: 04/27/2000)
16 NOTICE OF CASE REASSIGNMENT to the Honorable Judge John Antoon II . ctc (spr) (Entered: 06/05/2000)
17 ORDER dismissing this cause subject to the right of any party to reopen the action within 60 days upon good cause shown. All pending motions are denied as

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07/31/2000 08/14/2000

moot. ( Signed by Judge John Antoon II ) ctc MFR Number (lak) (Entered: 07/31/2000)
CASE CLOSED. (lak) (Entered: 07/31/2000)
18 CONSENT DECREE by EEOC, Medical Center Group (sph) (Entered: 08/14/2000)

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