I A. LUIS LUCERO, JR., REGIONAL ATTORNEY CLA1RE CORDON, SUPERVISORY TRIAL ATTORNEY
2 KATHRYN OLSON, SENIOR TRIAL ATTORNEY EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
3 909 FIRST AVENUE, SUITE 400 SEATTLE, WASHINGTON 98104
4 TEL: (206) 220-6915

ORIGINAL

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

13

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EQUAL EMPLOYMENT OPPORTUNITY

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15 COMMISSION,

)

)

16

Plaintiff,

)

)

17

v.

)

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18 FIDELITY FINANCIAL SERVICES OF IDAHO, )

INC.

)

19

)

Defendant.

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20 ---------------------------)

~N99 ~ 061
CIVIL ACTION NO. COMPLAINT
JURY TRIAL DEMAND

21

NATURE OF THE ACTION

22

This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil

23 Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation and

24 to provide appropriate relief to Stacie Schiffer. The Equal Employment Opportunity Commission

25 alleges that defendant subjected Ms. Schiffer to hostile work environment sexual harassment,

26 retaliation and constructive discharge. Plaintiff seeks monetary and injunctive relief: including

27 pecuniary and nonpecuniary compensatory danlages and punitive damages.

COMPLAINT - PAGE I

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office

Federal Office Building

909 First Avenue, Suite 400

Seattle, Washington 98104-1061

Telephone {206) 220-6883

Fax (206) 220-6911

TDD (206) 220-6882

/.

1 of the Civil Rights Act of 1964, as amended, 42 U.S.C. sections 2000e-S(f)(l) and (3) ("Title VII"),

2 and Section 102 of the Civil Rights Act of 1991, 42 U.S.c. §1981a.

3

2.

The employment practices alleged to be unlawful were committed within the

4 jurisdiction of the United States District Court for the District ofIdaho.

S

PARTIES

6

,1 ,,

Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the

7 agency of the United States of America charged with the administration, interpretation and

8 enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) of

9 Title VII, 42 U.S.c. §2000e-S(f)(l).

10

4. At all relevant times, defendant Fidelity Financial Services, Inc. ("Fidelity") has been

II a corporation continuously doing business in the State of Idaho and has continuously had at least IS

12 employees.

13

S. At all relevant times, defendant Fidelity has continuously been an employer engaged

14 in an industry affecting commerce within the meaning of Sections 701 (b), (g) and (h) of Title VII, 42

IS U.S.c. §§2000e-(b), (g) and (h).

16

STATEMENT OF CLAIMS

17

6. More than thirty days prior to the institution of this lawsuit, Stacie Schiffer filed a

18 charge with the Commission alleging violations of Title VII by defendant Fidelity. All conditions

19 precedent to the institution of this lawsuit have been fulfilled.

20

7.

Beginning on or before April 1998, defendant Fidelity engaged in unlawful

21 employment practices at its Idaho facilities in violation of §§ 703(a) and 704(a) of Title VII, 42

22 U.S.c. §§ 2000e-2(a) and -3(a). Defendant Fidelity affected the terms and conditions of Ms.

23 Schiffer's employment by subjecting her to ongoing harassment based on sex, retaliation and

24 constructive discharge.

25

8.

The effect of the practices complained of in paragraph 7 above has been to deprive

26 Ms. Schiffer of equal employment opportunities and otherwise adversely affect her status as an

27 employee because of her sex.

COMPLAINT, PAGE 2

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office Building 909 First Avenue, Suite 400
Seattle, Washington 98104-1061 Telephone (206) 220-6883 Fax (206) 220-6911 TDD (206) 220-6882

I

9.

The unlawful employment practices complained of in paragraph 7 above were

2 intentional.

3

10. The unlawful employment practices complained of in paragraph 7 above were done

4 with malice or with reckless indifference to the federally protected rights of Ms. Schiffer.

5

PRAYER FOR RELIEF

6

Wherefore, the Commission respectfully requests that this Court:

7

A. Grant a permanent injunction enjoining defendant, its officers, successors, agents,

8 assigns, and all persons in active concert or participation with it, from engaging in any

9 employment practices which discriminate on the bases of sex and retaliation.

10

B. Order defendant to institute and carry out policies, practices, and programs which

II provide equal employment opportunities for all employees, and which eradicate the effects of its past

12 and present unlawful employment practices.

13

C. Order defendant to make whole Ms. Schiffer by providing appropriate back pay with

14 prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to

IS eradicate the effects of its unlawful employment practices.

16

D. Order defendant to make whole Ms. Schiffer by providing compensation for past and

17 future pecuniary losses resulting from the unlawful employment practices described in paragraph 7

18 above, including past and future out-of-pocket expenses, in amounts to be determined at trial.

19

E. Order defendant to make whole Ms. Schiffer by providing compensation for past and

20 future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7

21 above, including without limitation emotional pain, suffering, and loss of enjoyment oflife, in

22 amounts to be determined at trial.

23

F. Order defendant to pay Ms. Schiffer punitive damages for its malicious and reckless

24 conduct described in paragraph 7 above, in amounts to be determined at trial.

25

G. Grant such further relief as the Court deems necessary and proper in the public

26 interest.

27

H. Award the Commission its costs of this action.

COMPLAINT - PAGE 3

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office Building 909 First Avenue, Suite 400
Seattle, Washington 98104-1061 Telephone (206) 220-6883 Fax (206) 220-6911 TDD (206) 220-6882

1

JURY TRIAL DEMAND

2

The Commission requests a jury trial on all questions offact raised by its complaint.

3 4

M DATED this

""\1 day

of ~ ~cC(i'v\ \\ r

t'

,1999.

C. GREGORY STEWART General Counsel

GWENDOL YN YOUNG REAMS Associate General Counsel

15 16 17 18 19 20 21 22 23 24 25 26 27
COMPLAINT, PAGE 4

ITY

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION

Office of the General Counsel

1801 "L" Street, N.W.

Washington, D.C. 20507

Attorneys for Plaintiff

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office BUilding 909 First Avenue, SUite 400
Seattle, Washington 98104-1061 Telephone (206) 220-6883 Fax (206) 220-6911 TDO (206) 220-6882

 
 A. LUIS LUCERO, JR., REGIONAL ATTORNEY

CLAIRE CORDON, SUPERVISORY TRIAL ATTORNEY

2 KATHRYN OLSON, SENIOR TRIAL ATTORNEY

r" :'.'~' 2 \ [I

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION '..

3 909 FIRST AVENUE, SUITE 400 SEATTLE, WASHINGTON 98104
4 TEL: (206) 220-6915

Y.~
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5

6

7

8

9

10

11

12

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

13

14

EQUAL EMPLOYMENT OPPORTUNITY

)

15 COMMISSION,

)

)

16

Plaintiff,)

)

17

v.

)

)

18 FIDELITY FINANCIAL SERVICES OF IDAHO, )

INC., FIDELITY FINANCIAL SERVICES, INC., )

19 and NORWEST FINANCIAL, INC.

)

)

20

Defendants.)

CIVIL ACTION NO. i ~ cr q.to ~~ 10
FIRST AMENDED COMPLAINT
JURY TRIAL DEMAND

21 --------------------------)
NATURE OF THE ACTION 22
This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil
23
Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation and 24
to provide appropriate relief to Stacie Schiffer. The Equal Employment Opportunity Commission 25
alleges that Defendants subjected Ms. Schiffer to hostile work environment sexual harassment, 26
retaliation and constructive discharge. Plaintiff seeks monetary and injunctive relief, including 27

FIRST AMENDED COMPLAINT· PAGE I

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
Federal Office BUilding
909 First Avenue. Suite 400 Seattie, Washington 98104-1061
Telephone (206) 220-6883
J1,. Fax (206) 220-6911,
TDO (206) 220-6882

pecuniary and nonpecuniary compensatory damages and punitive damages.

2

JURISDICTION AND VENUE

3

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§451, 1331, 1337, 1343

4 and 1345. This action is authorized and instituted pursuant to sections 706(f)(1) and (3) of Title VII

5 of the Civil Rights Act of 1964, as amended, 42 U.S.c. sections 2000e-5(f)(I) and (3) ("Title VII"),

6 and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. §1981a.

7

2. The employment practices alleged to be unlawful were committed within the

8 jurisdiction of the United States District Court for the District ofIdaho.

9

PARTIES

10

3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the

II agency of the United States of America charged with the administration, interpretation and

12 enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) of

13 Title VII, 42 U.S.C. §2000e-S(f)(l).

14

4.

At all relevant times, Defendants Fidelity Financial Services, Inc. and. Fidelity

IS Financial Services ofIdaho, Inc.("fidelity") and Norwest Financial, Inc. ("Norwest") have been

16 corporations continuously doing business in the State of Idaho, and have continuously had at least 15

17 employees.

18

S. At all relevant times, Defendants Fidelity and Norwest have each continuously been

19 an employer engaged in an industry affecting commerce within the meaning of Sections 701 (b), (g)

20 and (h) ofTitle VII, 42 U.S.C. §§2000e-(b), (g) and (h).

21

STATEMENT OF CLAIMS

22

6. More than thirty days prior to the institution of this lawsuit, Stacie Schiffer filed a

23 charge with the Commission alleging violations of Title VII by Defendant Fidelity Financial

24 Services ofldaho, Inc. and Norwest, Inc. Defendants Fidelity Financial Services, Inc. and Norwest

2S Financial, Inc. were on notice of the charge. All conditions precedent to the institution of this

26 lawsuit have been tulfilled.

27

7. Beginning on or before April 1998, Defendants Fidelity and Norwest engaged in

FIRST AMENDED COMPLAINT - PAGE 2

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
Federal Office BUilding 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone (206) 220.-t:i883
Fax (206) 220-6911 TDD (206) 220-6882

unlawful employment practices at its Idaho facilities in violation of §§ 703(a) and 704(a) of Title

2 VII, 42 U.S.c. §§ 2000e-2(a) and -3(a). Defendants Fidelity and Norwest affected the terms and

3 conditions of Ms. Schiffer's employment by subjecting her to ongoing harassment based on sex,

4 retaliation and constructive discharge.

5

8. The effect of the practices complained of in paragraph 7 above has been to deprive

6 Ms. Schifler of equal employment opportunities and otherwise adversely affect her status as an

7 employee because of her sex.

8

9. The unlawful employment practices complained of in paragraph 7 above were

9 intentional.

10

10. The unlawful employment practices complained of in paragraph 7 above were done

11 with malice or with reckless indifference to the federally protected rights of Ms. Schiffer.

12

PRAYER FOR RELIEF

13

Wherefore, the Commission respectfully requests that this Court:

14

A. Grant a permanent injunction enjoining Defendants, its officers, successors, agents,

15 assigns, and all persons in active concert or participation with it, from engaging in any

16 employment practices which discriminate on the bases of sex and retaliation.

17

B. Order Defendants to institute and carry out policies, practices, and programs which

18 provide equal employment opportunities for all employees, and which eradicate the effects of its past

19 and present unlawful employment practices.

20

c. Order Defendants to make whole Ms. Schiffer by providing appropriate back pay

21 with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary

22 to eradicate the effects of its unlawful employment practices.

23

D. Order Defendants to make whole Ms. Schiffer by providing compensation for past

24 and future pecuniary losses resulting from the unlawful employment practices described in paragraph

25 7 above, including past and tuture out-ot:pocket expenses, in amounts to be determined at trial.

26

E. Order Defendants to make whole Ms. Schiffer by providing compensation for past

27 and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7

FIRST AMENDED COMPLAINT - PAGE 3

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
Federal Office BUilding 909 First Avenue, SUite 400 Seattie, Washington 98104-1061 Telephone (206) 220-6883
Fax (206) 220-.6911 TOO (206) 220-6882

I above, including without limitation emotional pain, suffering, and loss of enjoyment of life, in

2 amounts to be determined at trial.

3

F. Order Defendants to pay Ms. Schiffer punitive damages for its malicious and reckless

4 conduct described in paragraph 7 above, in amounts to be determined at trial.

5

G. Grant such further relief as the Court deems necessary and proper in the public

6 interest.

7

H. Award the Commission its costs ofthis action.

8

JURY TRIAL DEMAND

9

The Commission requests a jury trial on all questions of fact raised by its complaint.

10

II

DATED this ~~c?" day of \\,,\0,,'"t \.

,2000.

12 A. LUIS LUCERO, JR. Regional Attorney
13 CLAIRE CORDON
14 Supervisory Trial Attorney

C. GREGORY STEWART General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel

15 KATHRYN OLSON Senior Trial Attorney
16

I 7 BY:-I---,4-''-'-''-----''----'7-''--L----'''''---'-'""'--''-''--'---

18 EQUAL MPLOYMENT OPPORTUNITY

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION

COMMISSION

19 Seattle District Office

Office of the General Counsel

909 First Avenue, Suite 400

1801 "L" Street, N.W.

20 Seattle, Washington 98104

Washington, D.C. 20507

Telephone (206) 220-6915

21

Attorneys for Plaintiff

22

23

24

25

26

27

rlRST AMENDED COMPLAINT - PAGE 4

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
Federal Office BUilding 909 First Avenue, SUite 400 Seattle, Washington 98104-1061
Telephone (206) 220-6883 Fax (206) 220-6911 TOO (206) 220-6882

 
 A. LUIS LUCERO, JR. KATHRYN OLSON ZULEMA HINOJOS-FALL EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 909 FIRST AVENUE, SUITE 400 SEATTLE, WASHINGTON 98104 TEL: (206) 220-6889 FAX: (206) 220-6911

i W:.;1 F{ll-"~; , ':"; rH!(~ ( n:
Ii' ZUOl
C/:/GINAL

uNITED STATES COURT' IN THE UNITED STATES DISTRICT COURT DISlRlCT OF IDAHO '"

FOR THE DISTRICT OF IDAHO

EQUAL EMPLOYMENT OPPORTUNITY)

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

FIDELITY FINANCIAL SERVICES OF )

IDAHO, INC., FIDELITY FINANCIAL )

SERVICES, INC., and NORWEST

)

FINANCIAL, INC.,

)

)

Defendants.

)

------------------------)

SETTLEMENT AGREEMENT
AND (PROPOSED) ORDER
APPROVING SETTLEMENT AGREEMENT

I. INTRODUCTION

I. This Settlement Agreement has been voluntarily entered into by

the parties engaged in this litigation, and is submitted to the Court for approval. This

Settlement Agreement fully and finally resolves this civil action: Equal Employment

Opportunity Commission v. Fidelity Financial Services ofIdaho, Inc., Fidelity Financial

Services, Inc., and Norwest Financial. Inc., (collectively referred to as "Fidelity"), Civil

Action No. CIV99-061O-S-BLW.

2. This action originated with two discrimination charges Stacie

SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 1

Schiffer filed with the Idaho Human Rights Commission and Equal Employment Opportunity Commission in which she alleged she was discriminated against on the bases of sex, constructive discharge, and retaliation, in violation of Title VII of the Civil Rights Act of 1964, as amended ('Title VII"), 42 U.S.C. § 2000e et seq. Copies of the charges are attached to this Settlement Agreement as Exhibit 1.
3. During the investigation of these charges, Fidelity denied all of the allegations.
4. On December 7, 1999, the EEOC sent Fidelity a Letter of Determination with a finding ofreasonable cause that Fidelity violated Title VII. A copy of the Letter of Determination is attached to this consent decree as Exhibit 2.
5. The Commission filed this lawsuit on December 29, 1999, in the United States District Court for the District ofIdaho. The EEOC's original Complaint and First Amended Complaint allege sexual harassment, constructive discharge, and retaliation. Fidelity denies the allegations on, inter alia, the same bases that it denied the allegations in the underlying charge.
6. The EEOC, Fidelity and Stacie Schiffer ("Plaintiff-Intervenor") want to conclude all claims arising out of the above charge without expending further resources in contested litigation.
II. NONADMISSION OF LIABILITY AND NONDETERMINATION BY THE COURT
7. This Settlement Agreement is not an admission of wrongdoing or liability. It is not an adjudication or finding on the merits of the case. This Settlement Agreement is a compromise of disputed claims, the validity of which Fidelity expressly denies, entered into for the purpose of terminating this litigation.
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 2

III. SETTLEMENT SCOPE 8. This Settlement Agreement is the final and complete resolution of all Title VII allegations of unlawful employment practices contained in: (I) Stacie Schiffer's discrimination charge; (2) the EEOC's administrative determination; and (3) the Complaint and First Amended Complaint and Complaint-in-Intervention filed or to be filed herein, including all claims by the parties for attorney fees and costs. 9. This Settlement Agreement, including the exhibits hereto, constitute the complete understanding between the EEOC and Fidelity with respect to matters herein. 10. This Settlement Agreement in no way affects EEOC's right to process, in accordance with standard Commission procedures, charges filed by individuals against Fidelity alleging violations of Title VII. Charges include those pending as of the effective date of the Agreement and filed in the future. Processing includes the administrative investigation and conciliation and commencement of civil actions on the basis of such charges.
IV. MONETARY RELIEF II. In settlement of the EEOC's claims in this lawsuit, Fidelity agrees to pay Schiffer the total gross sum of $52,500.00. The payment will be mailed to Schiffer within two (2) business days ofreceipt of the signed release agreement (which is also entitled "Settlement Agreement") attached to this Settlement Agreement as Exhibit 3 and incorporated herein by this reference, or seven (7) days of the entry of the Order Approving Settlement Agreement, whichever is later.
V. NONMONETARY CONSIDERATION A. General Provisions 12. Wells Fargo Financial Acceptance Idaho, Inc., which was formerly
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 3

known as Fidelity Financial Services ofIdaho, Inc., which was fonneriy known as Fidelity Financial Services, Inc., an Idaho corporation, reaffinns its commitment to comply with Title VII to the extent, if any, required by law. To further this commitment, Wells Fargo Financial Acceptance Idaho, Inc. shall monitor the affinnative obligations of this Settlement Agreement. The tenns of this Settlement Agreement apply to all applicants and employees of Wells Fargo Financial Acceptance Idaho, Inc.
13. Wells Fargo Financial Acceptance Idaho, Inc. will not retaliate against any applicant or employee for opposing a practice deemed unlawful by Title VII or for making a charge, testifying, assisting, or participating in any investigation, proceeding, or hearing associated with this action.
B. Establishment of Policy and Procedures to Prevent Discrimination
14. After Stacie Schiffer filed her first charge of discrimination, Fidelity Financial Services ofIdaho, Inc., which is now known as Wells Fargo Financial Acceptance Idaho, Inc., reviewed its policies against discriminatory employment practices based on sex and retaliation to make reasonably certain that its internal policies comply with Title VII. Said policies were improved and strengthened. Said policies contain an internal grievance and complaint resolution procedure as outlined below. This grievance and complaint resolution policy has been distributed to any and all present employees, both management and nonmanagement, of Wells Fargo Financial Acceptance Idaho, Inc. and is attached hereto as Exhibit 4. Wells Fargo Financial Acceptance Idaho, Inc. will continue to distribute a copy of its grievance and complaint resolution policy to any and all its employees, including all temporary and pennanent employees, beginning 45 days after entry ofthis Settlement Agreement and continuing for the duration of the Agreement.
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 4

C. Internal Grievance Procedure 15. Wells Fargo Financial Acceptance Idaho, Inc. will maintain for the duration of this Settlement Agreement an internal grievance procedure for applicants or employees who believe they have been discriminated against. These procedures have also been set forth in the written policy discussed in paragraph 14 above. Consistent with the terms of the grievance procedure: a. An employee relations or human resources employee or department ("the department") will investigate complaints of discrimination or harassment made to the department by employees of Wells Fargo Financial Acceptance Idaho, Inc. or applicants for employment with Wells Fargo Financial Acceptance Idaho, Inc .. b. The department will document the steps taken in the investigation of each complaint, as well as any corrective action taken as a result of the investigation and, if no action is taken, the reasons for not taking corrective action. c. The department shall inform the complainant of the outcome of the investigation. d. Within thirty (30) days after the end of the year following the date of entry of this decree, Wells Fargo Financial Acceptance Idaho, Inc. will mail to EEOC a copy of each complaint of discrimination or harassment along with a summary of the resolution of each complaint or a statement that no complaints have been made. D. Title VII Training and Awareness Program 16. Wells Fargo Financial Acceptance Idaho, Inc. is a subsidiary of Norwest Financial, Inc., which has developed and presented to its and its subsidiaries' human resources manager and staff, managers, and employees a one and one-half hour Title VII training session, which was reviewed by the EEOC. The cost of training has
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 5

been borne by Norwest Financial, Inc. 17. Norwest Financial, Inc. has provided the EEOC with the training
materials for said Title VII training session, including but not limited to: the videotape entitled "Sexual Harassment: Is It or Isn't It?" by American Media Incorporated; the booklet "Sexual Harassment Desk Reference Guide" by American Media Incorporated; the documents entitled "Sexual Harassment: Is It or Isn't It? Management Guide," "Sexual Harassment: Is It or Isn't It? Participant Guide," "Sexual Harassment for Management Training Outline," "How Much Do I Know about Sexual Harassment? A True or False Quiz for Employees"; the pamphlet entitled "Trainer's Guide Harassment"; and the written Program Objectives and Program Timeline for the training program.
18. For the duration of this Settlement Agreement, Wells Fargo Financial Acceptance Idaho, Inc. will continue to conduct training at the orientation program for all new hires, and training shall be conducted at least annually thereafter during the duration of this Settlement Agreement.
19. Wells Fargo Financial Acceptance Idaho, Inc. will retain a record of future training programs (i.e., dates held and persons attended) during the duration of this Settlement Agreement, and Wells Fargo Financial Acceptance Idaho, Inc. will provide copies ofthe records and any new training materials to the EEOC within 30 days after any such training.
E. Reporting 20. Wells Fargo Financial Acceptance Idaho, Inc. shall submit a final report to EEOC 30 days before the Settlement Agreement expires containing a statement that it has complied with all the terms of this Settlement Agreement. F. Posting 21. Wells Fargo Financial Acceptance Idaho, Inc. will post a notice,
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 6

attached as Exhibit 5 to this Settlement Agreement on a centrally located bulletin board at any and all of its business locations in Idaho, which notice shall remain so posted for the duration of the Settlement Agreement.
VI. ENFORCEMENT 22. If the EEOC concludes that Wells Fargo Financial Acceptance Idaho, Inc. has breached this Settlement Agreement, it may bring an action in the United States District Court for the District of Idaho to enforce this Settlement Agreement. Before bringing an action for breach of the agreement, the EEOC shall first give Wells Fargo Financial Acceptance Idaho, Inc. 20 days' notice of the EEOC's conclusion that Wells Fargo Financial Acceptance Idaho, Inc. has breached this Settlement Agreement. The EEOC and Wells Fargo Financial Acceptance Idaho, Inc. shall use that 20-day period for good faith efforts to resolve the matter. In the event the EEOC and Wells Fargo Financial Acceptance Idaho, Inc. cannot resolve their differences, they agree to mediate the issue in good faith at Wells Fargo Financial Acceptance Idaho, Inc.'s expense using an outside mediator, prior to bringing any action for breach of the Settlement Agreement.
VII. RETENTION OF JURISDICTION 23. The United States District Court for the District ofIdaho shall retain jurisdiction over this matter for the duration of this Settlement Agreement.
VIII. DURATION AND TERMINATION 24. This Settlement Agreement shall be in effect for one year plus ninety (90) days, commencing with the date this Agreement is filed. If the EEOC petitions the Court for breach of agreement, and the Court finds Wells Fargo Financial Acceptance Idaho, Inc. to be in violation of the terms ofthis Settlement Agreement, the Court may extend this Agree~ent. Unless earlier terminated by the Court for good cause shown by Wells Fargo Financial Acceptance Idaho, Inc., this Settlement Agreement shall
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 7

expire without further action by the parties at midnight on the date one year plus ninety

days after the date this Settlement Agreement is filed.

IX. CONCLUSION

25. The provisions ofthis Settlement Agreement are not binding on the

parties until the authorized representatives of each party sign the Settlement Agreement

and the Court executes and files the Order Approving Settlement Agreement.

DATED this z,( day of~eeeHleer, ~QQQ.
- - Jee""""'!- Lotl/.

A. LUIS LUCERO, JR. Regional Attorney

C. GREGORY STEWART General Counsel Designate

KATHRYN OLSON Acting Supervisory Trial Attorney

GWENDOLYN YOUNG REAMS Associate General Counsel

ZULEMA HINOJOS-FALL Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office 909 First Avenue, Suite 400 Seattle, Washington 98104 Tel: (206) 220-6869 Fax: (206) 220-6911

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Office of the General Counsel 1801 "L" Street, N.W. Washington, D.C. 20507

Gerald T. Husch

John C. Lynn

C. Clayton Gill

LYNN, SCOTT & HACKNEY, PLLC

MOFFATT, THOMAS, BARRETT,

500 W Bannock

ROCK & FIELDS, CHARTERED

Boise, Idaho 83702

101 S. Capitol Boulevard, lOth Floor

Tel: (208) 342-7600

P.O. Box 829

Fa\ (208) 342-655/

Boise, Idaho 83701

n/ \/ Tel: (2

-2000

Fa BY

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-2.-01

SETTLEMENT AGREEMENT AND (PROPOSEdj ORDER - 8

ORDER APPROVING SETTLEMENT AGREEMENT The Court, having considered the foregoing stipulated agreement of the parties, HEREBY ORDERS THAT the foregoing Settlement Agreement be, and the same hereby is, approved as the final decree of this Court in full settlement of this action. This lawsuit is hereby dismissed with prejudice and without costs or attorneys' fees to any party. The Court retains jurisdiction of this matter for purposes of enforcing the Settlement Agreement approved herein. DATED this _ _ day of _ _ _ _ _ _,2000.
The Honorable B. Lynn Winmill Chief District Judge
SETTLEMENT AGREEMENT AND (PROPOSED) ORDER - 9

CHARCo"'" ~ DISCRIMINATION

GENCY

0'.1 ~ Th1s form is affected by the Prlva~. Act 01 1974; See Privacy Act Statement b",
completlnQ this form.

FEPA
EEOC

CHARGE NUYSER
c - (nei g'- OJ Cj
I3Y((:'95?G Cl..X7

Idaho Human Rights Commission
Slate or local Agency, ifany

and EEOC

NAME

(~cBte co"::' ,

Hr t.:

.•,.,Mt.sb.•

Mrs.)

Ms. Stac:t M. Schiffer

STREET ADDRESS

CITY, STATE AND ZIP CODE

HOME TELEPHONE (Include Area Code)
I (208) 344-0510 DATE OF BIRTH

2UO Canal Street #204 Boise ID 83105

04/21177

NAMED IS THE EMPLOYER, LABOR ORGANIZATION, EMPLOYMENT AGENCY APPRENTICESHIP COMMITTEE,

STATE OR LOCAL GOVERNMENT AGENCY WHO DISCRIMINATED AGAINST ME (Ir more than one list belo~.)

NAME
Fidelity Financial Services

7 \ NUMBER OF EMPLOYEES, MEMBERS
201 - ')00 EmDlovees

\ TE~~~~N~ II;c~;~;r~'4

de )

STREET ADDRESS

CITY, STATE AND ZIP CODE

I COUNTY

2645 North Cole Road Boise ID 83704
NAME

001
TELEPHONE NUMBER (Include Are8 Code)

Norwest Inc.
STREET ADDRESS

G 16. S _

Jl't ITY , STATE AND ZIP CODE

3101 West 69th Street ~dina Minnesota 55435

CAUSE OF DISCRIMINATION BASED ON (Check appropriate box{es))

DRACE

o COLOR

00 SEX

o RELIGION

D NATIONAL ORIGIN

00 RETALIATION

OAGE

D D DISABILITY

OTHER (Specify)

I COUNTY

DATE DISCRIMINATION TOOK PLACE

EARLIEST

LATEST

04/25/98

07117198

[K] CONTINUING ACTION

THE PARTICULARS ARE (If additional space is needed, attach extra sheet(s)):

***See Attached***

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- ~ I want this charge filed w1th both the EEOC and the State 0 ~R.Y (When necessary for State and Local ReqUirem~~~

local Agency, if any. I will advise the agencies if I change my

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address or telephone number and cooperate fully with them in the I swear or af1'IrID, that I have read the above char~m1d that

process1ng of my charge in accordance wit~r. procedures.

1t is true to the best Of my KnOWledge, in~9f.al1on and bellef.

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EX-HIBIT .. - I I EEOc FOR" 5,(Rev.06{92)

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(Day, mG , and year)

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COMPLAINANT: Stacy Schiffer vs. Fidelity Financial Services PAGE TWO THE PARTICULARS ARE:

I. COMPLAINANT'S STATEMENT OF HARM: I was continuously sexually harassed and retaliated against for complaining of the
harassment.

II. RESPONDENT'S REASON FOR ADVERSE ACTION: Ms. Joan Bums, manager for Respondent, has not provided me a reason for the sexual
harassment, nor for the retaliation. Mr. George Mullinix, district manager for Respondent, has not provided me with a reason for not investigating my complaints.

III. COMPLAINANT'S STATEMENT OF DISCRIMINATION: I believe that I have been discriminated against based on my sex, female, and retaliated
against for complaining about sexual harassment. I offer the following statements in support of these beliefs:

A. I was employed as a customer service representative for Respondent on April 20, 1998. I have an excellent work history despite the uncomfortable work environment.

B. On approximately April 27, 1998, I began feeling extremely uncomfortable at work. Ms. Bums delivered a mini-seminar on how to cheat on men and get away with it. Shortly after this, Ms. Bums went on to describe the beauty ofa woman's body and her sexual fantasies involving another man and woman. She spoke of what she had seen on the internet in reference to sexually explicit material and invited both Ms. Price, co-worker, and myself to go home with her some evening to play with it. I was shocked by her topics, and was even more uncomfortable when she began touching me. While at my desk working, Ms. Bums would stand over me so closely that she would brush her body against me. I pulled away every time she came too near. Ms. Bums asked me what was wrong with me, referring to the slight adjustments I would have to make to prevent her from brushing her body against me. I told her that I was uncomfortable with her getting so close to me. She responded sarcastically, "Get a life!" She did not respect my request to stop touching me.

C. I complained to Mr. Mullinix, district manager for Respondent, about Ms. Bums behavior on June 26, 1998. He flew in from the corporate office and observed Ms. Bums actions. He agreed that Ms. Bums was getting much closer in proximity to me than was necessary. He also affirmed that he had seen me try to avoid her touch by moving away when she touched me. He said he would take care of the problem.

D. Ms. Bums continued her sexual harassment both physically and verbally. She

noticed my bra strap had slipped out of my sleeveless dress. She adjusted it rather than simply

telling me that the strap was exposed. Ms. Bums has found many excuses to touch me, such

as, grabbing my leg and lifting it to observe my tattoo, which is on my ankle. She has tried to

rub my thigh with her hand, claiming she was interested in the material of my slacks. She

went as far as lifting the back of my shirt and pulling the tag out from the back of my slacks to

check the material. I told her that I resented her handling me.

000033

E. Ms. Bums has asked me if! had "gotten laid last night" when I've come into work. She had me sit in her chair on one particular day. She said, "Now I can share my crabs with you." She has made comments concerning her vibrator, complaining that she has worn the batteries out so often that she's considering a model that plugged in. She described the phallic purpose of this implement.

F. Ms. Bums has asked me about my body and my use of birth control. These topics are personal to me and I saw no need to respond to her interests. On another occasion, I was bending over Ms. Price's desk assisting her on the computer when Ms. Bums approached me from behind. She reached slightly down the back of my slacks and grabbed the top of my underwear. I was startled and stood upright. She allowed my underwear to snap back and said, "Ah, blue today."

G. I complained once again to Mr. Mullinix about Ms. Bums on July 15, 1998. He assured me that the behavior would cease. The sexual harassment has decreased, but not ended. I feel that since complaining to Mr. Mullinix, Ms. Bums has begun retaliating against me. My work is suddenly being heavily scrutinized. Processes that I had been trained to do previously now are no longer satisfactory to Ms. Bums. She's called me liar on several occasions when discussing areas of concern. At one point, my co-worker, Ms. Misty Price, came to my defense by stating that I was correct in the manner in which I processed. Ms. Bums did not apologize, but rather found other areas to chastise, which were never pointed out to me in my training.

H. More recently, Ms. Misty Price, my co-worker who is going to be married soon, was trying to measure me for my bridesmaid dress. Ms. Bums came up and took the tape away from Ms. Price and told us that she would measure. Rather than approaching me from the back to measure my bust, she stood in front of me and extended the tape only from one breast to the other, applying pressure to my breasts as she rested the tape measure there. She did not attempt to do the measurement correctly but she appeared pleased at the opportunity to touch me again. I again backed away and we ended the measurement session while in her presence.

I. Since speaking with Mr. Mullinix about the problem I was experiencing with Ms.

Bums, Ms. Bums has refused to proceed with my training. She has told Ms. Price that she

refused to do my evaluation. She also told Ms. Price that she didn't expect me to remain with

Respondent much longer anyway. She also told her that I would be stupid not to quit. Ms.

Bums has left piles of trash under my desk on several occasions, claiming that she had

forgotten that there was no longer a trash can there. I had reminded her of this prior to her

throwing her paper under my desk. Since complaining, Ms. Bums has demeaned me with her

sarcasm and talking down to me. She calls me "kid" or "kiddo" instead of my name, and has

made working conditions extremely tense.

000034

J. Respondent employs over 15 employees.

I believe the practices of the above-named Respondent are in violation of: (x)Title 67, Chapter 59 of the Idaho Code () Title 44, Chapter 17 of the Idaho Code (x)Titie VII of the Civil Rights Act of 1964, as amended ( ) Age Discrimination in Employment Act of 1967 (ADEA) ( ) Americans with Disabilities Act
000035

IP ,m CHAt. )F DISCRIMINATION

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CHAACE MUMIE"
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19l1hc Human HUht II Ccmm1u11l1l
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and EEOC

NAlit (~Nt. IIZ-••• . . . . /Ir3.)

HUE TELEP.O.E{lM._ ...... Cob)

S aCle Schiffer

STReeT ADDRISS ryA-'" ~.

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I (208) 344-0510 OATE Of BIRT" n~/?1/77

NAilED IS THE EUPLOYER, LABOR ORGANIZATION, EUPLOYUENT AGENCY APPRENTICESHIP COUUITTEE,

•.0'. jlUUtft •• . J STATE OR LOCA.L GOVERNMENT AGENCY WHO OISCRIIiINATED AGAINST UE (Ir _ ........ u .. ..._.)

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~ TE.LEP"DIJlIE (ZllcJIIfie ~. Code)

I Fidelity Financial Services

201 to 500 Employee (208) 322-2841

STREET AIIDREII

CITY, STATE AID ZIP CODE

COUNTY

"wE' 2645 North Cole Road. Boise 10 83704

001
trELEPHONE MU.IER (J"•• _ AN. couJ

Norwest, Inc.
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DATE. Dlsca!MlNATIDM TDO~ PLACE

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04;25/98 07 /17/98 ~XcO.TI.UIND ACTION

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CHARGE OF DISCRIMINATION February 23, 1999 PAGE 2

l. COMPLAINANT'S STATEMENT OF HARM: I was continuously sexually harassed, retaliated against for complaining ofthe harassment, and constructively discharged.

II. RESPONDENT'S REASON FOR ADVERSE ACUON: Ms. Joan Burns, Manager for Respondent, has not provided me II reason for the sexual harassment, nor for the retaliation. Mr. George Mullinix, District Manager for Respondent, has not provided me with a reason for not investigating my complaints.
m. COMPLAINANT'SSTATEMENTOFDISCRIMINATlON: I believe that I have been
discriminated against based on my sex, female, and retaliated against for complaining about sexual harassment. I offer the following statements in support of these beliefs:

A I was employed as a customer service representative for Respondent on April 20, 1998. I have an excenent work history despite the uncomfortable work environment.

B. On approximately April 27, 1998, I began feeling extremely uncomfortable at work.. Ms. Burns delivered a mini-seminar on how to cheat on men and get away with it. Shortly after this, Ms. Burns went on to describe the beauty ofII woman's body and her sexual fantasies involving another man and woman. She spoke of what she had seen on the Internet in reference to sexually explicit material, and invited both Ms. Price, a co-worker, and myse1fto go home with her some evening to play with it. 1 was shocked by her topics, and was even more uncomfortable when she began touching me. While at my desk working, Ms. Bums would stand over me so closely that she would brush her body against me. I pulled away every time she came too near. Ms. Bums asked me what was wrong with me, referring to the slight adjustments I would have to make to prevent her from brushing her body against me. I told her that I was uncomfortable with her getting so close to me. She responded sarcastically, "Get a life!" She did not respect my request to stop touching me.

C. I complained to Mr. Mullinix, District Manager for Respondent, about Ms. Bums' behavior on June 26, 1998. He flew in from the corporate office and observed Ms. Burns' actions. He agreed that Ms. Burns was getting much closer in proximity to me than was necessary. He also confirmed that he had seen me try to avoid her touch by moving away when she touched me. He said he would take care of the problem.

D. Ms. Bums continued her sexual harassment both physically and verbally. She noticed my bra strap had slipped out ofmy v-neck sweater. She adjusted it rather than simply telling me that the strap was exposed. Ms. Bums has found many excuses to touch me, such as, grabbing my leg and lifting it to observe my tattoo, which is on my ankle.

2

000214

CHARGE OF DISCIUMINATION February 23, 1999 PAGE 3
She has tried to rub my thigh with her hand, claiming she was interested in the material of my slacks. She went as far as lifting the back ofmy shirt and pulling the tag out from the back ofmy slacks to check the material. I told her that I resented her handling me.
E. Ms. Bums has asked me if I had "gotten laid last oight" when I've come into work. She had me sit in her chair on one particular day. She said, "Now I can share my crabs with you". She had made comments concerning her vibrator, complaining that she has worn the batteries out so often that she's considering a model that plugged in. She described the phallic purpose orthis instrument.
F. Ms. Burns has asked me about my body and my use ofbirth control. These topics arc personal to me and I saw no need to respond to her interests. On another occasion, 1 was bending over Ms. Price's desk. assisting her on the computer when Ms. Burns approached me from behind. She reached slightly down the back of my slacks and
grabbed the top ormy underwear. I was startled and stood upright. She allowed my
underwear to snap back and said, "Ah, blue today".
G. I complained once again to Mr. Mullinix about Ms. Burns on July 15, 1998. He
assured me that the behavior would cease. The sexual harassment has decreased, but not ended. I feel that since complaining to Mr. Mullinix, Ms. Bums has begun
retaliating against me. Myworlc is suddenly being heavily scrutinized. Processes that I had been trained to do previously now are no longer satisfactory to Ms. Burns. She's called me a liar on several occasions when discussing areas ofconcern. At one point, my co-worker, Ms. Misty Price, came to my defense by stating that I was correct in the manner in which I processed. Ms. Burns did not apologize, but rather found other areas to chastise, which were never pointed out to me in my training.
H. More recently, Ms. Price, who is going to be manied soon, was trying to measure me
for my bridesmaid dress. Ms. Burns came up and took the tape away from Ms. Price and told us that she would measure. Rather than approaching me from the back to measure my bust, she stood in front ofme and extended the tape around me and held the tape to my breast from one breast to the other, applying pressure as she rested the tape measure there. She did not attempt to do the measurement correctly but she appeared pleased at the opportunity to touch me again I again backed away and we ended the measurement session while in her presence.
I. Since speaking with Mr. Mullinix about the problem I was experiencing with Ms. Burns, Ms. Burns has refused to proceed with my training. She hilS told Ms. Price that she refused to do my evaluation. She also told Ms. Price that she didn't expect
3
00021~i

1....11'11'1 -:.JL...UII 6. HHI...-f'..I"t:.l H I I .
CHARGE OF DlSCRlMINATION February 23, 1999
PAGE 4
me to remain with Respondent much longer anyway, She also told Ms. Price that I would be stupid not to quit. Ms, Bums has left piles of trash under my desk on several occasions. claiming that she had forgotten that there was no longer a trash can there. I bad reminded her of tbis prior to ber throwing the paper under my desk. Since complaining, Ms. Bums bas demeaned me with ber sarcasm and talking down to me. She calls me "kid" or "kiddo" instead of my name, and has made working conditions extremely tense.
J. That Fidelity's failure to address the above mentioned retaliation coupled with Ms. Burns' continuous retaliation created intolerable woricing conditions. These matters were previously raised and addressed in Complainant's previous Charge of Discrimination Nos. E-0798-029; 3BC 980 287. Therefore, I was forced to resign on July 17, 1998 which constituted a constructive discharge.
K. Respondent employs over I S employees.
Tbelieve the practices of the above named Respondent are in violation of: Title 67, Chapter S9 of the Idaho Code and Title VII ofthe Civil Rights Act of 1964> as amended.

4

0002H;

TOTRL P.05

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Seattle District Office

h·d..:r;l! (Hlicc nuildillt'

DEC -7 1999

(j()\) hL.,1 AVL'J]l1I":, 'illile 4()() '1e'lUk. \V:\ 9XIO-l-1(1(,1 (2()6) nO-!JX,II..l
r I Y (206) 22(l-6XX2
L\X (20b) 220-h91I

Stacie Schiffer 2170 Canal Street #204 Boise, ID 83705
Fidelity Financial Services 206 Eight Street Des Moines, IA 50309

Charge NO.38C990164 Charginq Party
Respondent

DETERMINATION

Under the authority vested in me by the Commission, I issue the following determination as to the merits of the subject charge filed under Title VII of the civil Rights Act of 1964, as amended (Title VII) .
All requirements for coverage have been met. Charging Party alleged that she was discriminated against in violation of Title VII in that she was sexually harassed, retaliated against for complaining of the harassment and constructively discharged on July 17, 1998 due to the hostile environment, because of her gender, female.
During the investigation, all relevant, available witnesses were interviewed, and all relevant documents were reviewed. I have considered all the evidence disclosed during the investigation and have determined that there is reasonable cause to believe thal there is a violatioll of Title VII with regard to Charging Farly's allegation of sexual harassment, hostile work environment dnd cctaliatiol1.
l;pon finding lhaL l here i co reason to bel ieve that a vi 0 La t ion has occurred, the Commission aLtempts to eliminate the ulleged lJnJawful practices by illfc)rmal methods of (~onciliatiorl. Tllere£C)r(~ tlle Commission now irlViLeG the parties La join witll it in ceachiIl9 a jusL Y'esolution of Lhis ]l;aLter. The Commission wil_l ~Ilso co~sidcr compcnsdlory ~rld purlitive c]amages lllldcr tl1c
C i '1 i i P -j q :-1 t oS Ac t () f 1091.

OOOZ~)(;

If the Respondent declines to discuss settlement or when, for any other reason, a settlement acceptable to the office Director is not obtained, the Director will inform the parties ane! advise them of the court enforcement alternatives available to aggrieved pcrSOI1S and lhe Commission. A Commission representative will COlltact each party in tIle near future to begin concili,ation.
On Behalf of the Commission:

DEC - 11999

JE~~TTE M. LEINO District Director

cc ,John Lynn Lynn Scott & Hackney, 500 W. Bannock Boise, 10 83702

P.L.L.C.

11[,,10 -16 -LUIJU I,.IIUI\ 1 1/:U1 Illurr.illlnUIIA)

r.UUJ/UUO

SETTLEMENT AGREEMENT
This Senlement Agreement (hereinafter "Agreement") is made and entered into on the date of the last signature bdow, by and among: (a) Stacie Glover, fonnerly known as Stacie Schiffer, and Eric Glover, wife and husbWld (hereinafter "Glovers"); and (b) Wells Fargo Financial Acceptance Idaho, Inc., fonnerly known as Fidelity Financial Services ofIdaho, Inc., fonnerly known as Fidelity FinWlcial Services, Inc., an Idaho corporation; Wells Fargo Finaocial Acceptance, Inc., formerly known as Fidelity Acceptance Corp.; Fidelity Acceptance Holding, 1m;.; Wells FargoFirumcial, Inc., formerly known as Norwest Financial, Inc.; Wells Fargo Financial Servkes, Inc., fonnerly known as Norwest Financial Services, Inc.; aod Wells Fargo & Company, fonnerly known as Norwest Corporation (a/l of which are hereinafter "Wells Fargo").
WHEREAS, between on or about April 20, 1998, aod on or about June 27, 1998. Stacie Schiffer was employed by Fidelity Financiul Services. Inc., an Idaho corporation. On or about June 28, 1998, Fidelity Financial Services, Inc. changed its name to Fidelity Financial
Services ofIdaho, Inc., aod from June 28, 1998, through July 30, 1998, Stacie Schiffer was
employed by Fidelity Financial Services ofIdaho, Inc.
WHEREAS, between on or about July 28, 199B, and on or about February 19, 1999, Stacie Schiffer filed with both the Idaho Human Rjghls Commission and the Equal Employment Opportunity Commission ("EEOC") charges of discrimination numbered E-079B029, 38C 980287, E-0299-321 and 38C 990164, nil of which charges of discrimination are incorporated herein by this reference, in which she nlleged that "Fidelity Financial Services" and "Norwl!st, Inc." had discriminated against her on the basis of sex and retaliated against her, in violation of the Idaho Human Rights Act, Idaho Code Sections 67-5901 et seq., and Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Sections 2000e et seq.
WHEREAS, on or about October 20, 1999, Stacie Schiff'er filed, as Case No. CV OC 9905638D, ill the District Court of the Fourth Judicial District of the State ofIdaho, in and for the County of Ada, 0. Complaint and Demand for Jury Trial captioned "STACIE SCHIFFER, Plaintiff, vs. FIDELITY FINANCIAL SERVICES OF IDAHO, fIDELITY SERVICES, INC. Wld NORWEST FINANCIAL, INC., Defendants," which Complaint and Demand for Jury Trial is incorporated herein by this reference.
WHEREAS, on or about December 29,1999. the EEOC filed as Case No. CIV99-06\ O-S-BLW in the United States District Court for the District ofIdaho. a Complaint Jury Trial Demaod, captioned "EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, vs. FIDELITY FINANCIAL SERVICES OF IDAHO, INC., Defendant," which Complnint - Jury Trial Demand is incorporated herein by this reference.
WHEREAS, on or about March 3D, 2000, the EEOC filed in Case No. CIV99-061 O-S-BLW in the United States District Court for the District of Idaho, a First Amended Complaint - Jury Triul DemWld. captioned "EQUAL EMPLOYMENT
EXHIBIT 3 TO SETTLEMENT AGREEMENT AND (PROPOSED) ORDER APPROVING SETTLEMENT AGREEMENT - 1

UI,L 10 LUUU\IU1! 1I UJ ,II Urr MI I III U.Ill\)

\ r ,H ; LUO J0 J JJ 0i

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OPPORTUNITY COMMISSION, Plaintiff, vs. FIDELITY FINANCIAL SERVICES OF IDAHO, INC., FIDELITY FINANCIAL SERVICES, INC., and NORWEST FINANCIAL, INC., Defendants," which First Amended Complaint - Jury llial Demand is incorporated herein by this reference.
WHEREAS, on or about June 12,2000, the United States District Court for the District of Idaho filed its Order Granting Motion to Intervene by Stacie SChiffer, thereby allowing Stacie Schiffer to assert claims against the defendants in Civil No. 99-0610-S-BLW, which case was then recaptioned as "EQUAL EMPLOYM£NT OPPORTUNITY COMMiSSION, and STACIE SCmFFER, Plnintiffs, vs. FIDELITY FINANCIAL SERVICES OF IDAHO, INC., FIDELITY FINANCIAL SERVICES,INC., and NORWEST FINANCIAL, INC., Defendants," in the United States District Court for the District ofIdaho.
WHEREAS, the Glovers and Wells Fargo thereafter agreed to settle all of the Glovers' claims against Wells Fargo (including but not limited to the Glovers' cinims arising out of the occurrences and transactions underlying the above-referem::ed charges of discrimination, complaints and lawsuits).
NOW, THEREFORE, in consideration of and in exchange for their mutual promises set forth herein, the Glovers and Wells Fargo hereby agree as follows:
1. PAYMENT OF SETTLEMENT PROCEEDS TO GLOVERS. Within the time set forth in paragraph II of the Settlement Agreement and (Proposed) Order Approving Settlement Agreement, which this Agreement is attached to and made a part of, Wens Fargo shall pay and deliver to the Glovers and their counsel the slUD of Fifty-two Thousand Five Hundred and Noll 00 Dollars ($52,500.00).
2. RELEASE. The Glovers fully compromise and settle, and completely and forever release and discharge Wells Fargo from, any and all claims, os defined herein, whether or not such claims arise out of the any of the transactions or occurrences underlying the above-referenced charges of discrimination. complaints and lawsuits.
3. GLOVERS' FURTHER ACKNOWLEDGMENTS AND RF:PRESENTATIONS.
(a) The Glovers represent that they are husband and wife. Stacie Schiffer represents that prior to her marringe to Eric Glover she was at all time a single, unmarried woman.
(b) The Glovers Wlderstand that this Agreement contnins a complete and total release of all of their claims against Wells Fargo.
(c) The Glovers acknowledge that they will not be able to recover any further monetary amounts from Wells Fargo for any claim, even ifsuch claim is not known to
EXHIBIT 3 TO SETTLEMENT AGREEMENT AND (PROPOSED) ORDER APPROVING SETTLEMENT AGREEMENT - 2

II Lei 0 LUUU\.11 U1\ J I I . U~ IIiU r r .,11 IIlU.II.'~

I.UUJ/UUO

them and even if knowledge of the unknown claim would cause them not to enter into this Agreement.
(d) The Glovers shaJl not be entitled to any further employment, or consideration for employment, with Wells Fargo or any company affiliated with Wells Fargo.
(e) The Glovers shall be responsible for payment of all taxes with respect to the payment of the Settlement Proceeds specified in Section I ofthi" Agreement and agree to defend. indemnify and hold harmless Wells Fargo from and against any claim of Iiahility for taxes or any kind, interest andlor penalties as may be asserted against Wells Fargo by any third party, including but not necessarily limited to the United States of America, Internal Revenue Service, Social Security Administration, the State ofldaho or the Idaho State Tax Conunission as a result of its payment of the Settlement Proceeds specified in Section 1 of this Agreement.
4. MISCELLANEOUS PROVISIONS.
(n) Definition of "CIllim(s)." The term "claim(s)," as used in this Agreement, means any and all claims-whether past, present or future, known or unknown, legal or equitable, contingent or established-of evel)' kind, nante and nature, including but not necessarily limited to all costs. bills, expenses, damages, demWlds, promises, contraCts, court costs, attorney's fees, liens, subrogation interests, controversies, actions, causes of action, choses in action and judgments, and further including but not limited to any and all: (i) charges of discrimination and causes ohetion under the Idaho Human Rights Act, Title VO of the Civil Rights Act of 1964, as runended, the Civil Rights Act of 1991, the Frunily WId Medical Leave Act, the Americans with Disabilities A"t, the Fair Labor Standards Act, the Employee Retirement Income Security Act, the Idaho Wage Claim Statute, any and all wnendments to such statutes; (ii) claims of wrongful termination or constructive dis"hnrge from employment; (iii) claims of breach of any express or implied employment contract or agreement; (iv) claims for buck pay, front payor reinstatement; (v) claims fur punitive, exemplBl)' or double or treble damages; (vi) wage claims. claims of breach of the implied covenWlt orgood faith and fair dealing and claims ofquunlum meruil; (vii) drums and causes of action that were or "ould buve been asserted in the above-referenced lawsuits; and (viii) claims under any other federal or state discrimination, human rights. employment, unemployment compensation, employment security, wnrker's compensation, occupational disease, or wage and hour law or statute,
(b) NODadmission or Liability, This Agreement is entered into as a
settlement of disputed claims and to avoid the expense and inconvenience oflitigation, and this
Agre~ment is not an admission of any wrongdoing, liability or fault by Wells Fargo or of any drnnages to the Glovers.
(c) Inlcgrntion and Modification. The terms of this Agreement are contractual and not mere recitals. No promise, inducement or agreement, except those stated in this Agreement, has been made to any party 10 induce said party 10 make or sign this Agreement.
EXHIBIT 3 TO SETILEMENT AGREEMENT AND (PROPOSED) ORDER APPROVING SETtLEMENT AGREEMENT - J

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This Agreement constitutes the final and entire expression of the parties and supersedes all prior statements, promises, representations, agreements and understandings, either oral or written, with respect [0 the matters Sc[ forth herein. No agent of any party or any other person may orally or by conduct modify, delete, vary, or contradict the terms or conditions of this Agreement or this paragraph. This Agreement may be modified only by a written agreement signed by all punies.
t
(d) Titles and Captions. All section and paragraph titles and captions contained in this Agreement are for convenience only and shall not be deemed part of the context nor nffect the construction or interpretation ofthis Agreement.
(e) Severability. The invalidity or unenforceability of any provision herein. or portion thereof, shall in no way affect the enforceability of any remaining provision of this Agreement. which remaining provisions shall remain in full force and effect lIS if this Agreement had been executed with the invalid portion thereof eliminated.
(f) Pnrties in Interest. This Agreement shall be binding upon and inure to the benefit of each of the parties to this Agreement and any and all of hislher/its spouses, family members, predecessors, successors, representatives, attorneys, IlSsigns, agents, employees, members, servants, estates, insurers, reinsurers, underwriters, heirs, executors, administrators, holding companies. subsidiaries and/or related entities. and any und all other persons and entities actiog for, by or through said party or on hislher/its behalf.
(g) Governing Law. This Agreement shall be interpreted and construed in accordance with the laws of the state ofldnho.
(h) Attnrney's Fees. In any lawsuit brought to enforce or interpret the provisions of this Agreement. the prevailing party shall be entitled to reasonable attorney's fees und court costs in addition to any other relief that may be awarded.
(i) Waiver. The waiver by any party of a breach or violation of any provision of this Agreement shall not opemte or be construed to be a waiver of any other or subsequent breach or violation of this Agreement.
OJ Further Actions. The parties agree to execute and deliver to each
other any pleadings, agreements, or other documents and to take any other action reasonably necessary to effectuate the intent of this Agreement.
The undersigned aCknowledge thnt they have fully read the tenns of this Agreement and fully understand nnd voluntarily nccept the terms of this Agreement.
GLOVERS
~dlj.~~~i) Sta e Glover (
EXHIBIT 3 TO SETTLEMENT AGREEMENT AND (pROPOSED) ORDER APPROVING SETfLEMENT AGREEMENT· 4

j i ' UJ ,II VI'l' ,j 1 I 1II V;II:I,

\1:1A!£1l0JOJJJO~

/_J APPROVED AS TO FORl\.:I"
AND CONTENT: .
LYNN')fC TT & HA~
By \, i
JolmLynn - Ofthe Finn Attorneys for Glovers
V

STATE OF IDAHO

)

) 5S.

County of Ada

)

~ay ~ On this /.j

of

,2000, before me, personally appeared STACIE

GLOVER, known or identified to me (or proved to me on the oath of

),

to be the person whose name is subscribed to the within instrument, and acknowledged to me

that she executed the same.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official seal the day and year in this certificate first above written.

STATE OF IDAHO

)

) 55.

County of Ada

)

~ ~ On this

day of

,2000, before me, personally appeared ERIC

GLOVER, known or identified to me (or proved to me on the oath of

),

to be the person whose n!lIIle is subscribed to the within instrument, and acknowledged to me

that he executed the same.

EXHIBIT 3 TO SETILEMENT AGREEMENT AND (PROPOSED) nun"" A .....,OVING ~FTTI .FMJ.:NT AGREEMENT _ S

IICL - 16 ~UUU \illV\ I l/,UJ JijVrr~I' lnuillij

\i,iA;LIIOJO))JOY

I, UUO; uuo

fN WITNESS WHEREOF. Iluwe hereunto set my hand and affixed my official s~al the day WId year in this certificate first above written.

d:1 NOTARY PUBLlCtrr Idaho

Residing at

f --(

My Commission Expires

"", Lt'

F_XHIRIT 3 TO SETTLEMENT ACREEMENT AND (pROPOSED) ORDER APPROVING SETtLEMENT AGREEMENT - 6

1 j! ·1 11)[ 1 I 1 I I I I II I, IlL,

I I II \., IiI ),"', ),-h) ",

12/12/20DO 10;58 FAX 515 S!51 i601

II"ELLS HRGO FI:\.'..'iCI.>.L

Sexual Harassment
wells Fargo Financl~1 seeks to provide each team member with an equal opportunitY to reach hiS or her full potential. Harassment bas~d upon sex, I1Ice, color, age, religion. disability, national origin, ancestry, pregnancy. marital status, miliUlry seNice or any other legally proteCted characteristic or condirion Is inconsistent with this goa\. unprofe55ianal, illegal. and will not be tolerated.
Sexual harassm~nt includes unwelcome sexual adl/anc~s, requests for sexual favors, and other conduct of a sexual nature when (1) acceptance of the conduct is required as a part of a person's employment. (2) an employment decision regarding the harassed person is based upon their acceptance or refus~1 oftne conduct, or (3) the conduct is int•.nded [0 or actually does unreasonably interfere with a team member's job performance at create an in'imidatlng, ho5tile. Ot offens;ve working environment. Examples include: unwelcome advances or propositions and conduct of a sexual nature that creates a threatening or offensive working envlronrT.ent. slJth as sexual innuendoes, comments, jokes or insults; the posting or distribution of sexually suggestive or derogatory pictures or drawings; the making of suggestive or obscene noises or gestures; or unnecessary touching.
Harassment based upon any other legally protected charaCteristiC or condition includes conduct intended to or that actually does unreasonably interfere with a team member's job performance; or creates an intimidoting. hostile, or offensive working environment. Examples include: name-calling.
slurs~ demE:aning remarks, stereotyping. or jokes, and thE distribution of
demeaning draWings or cartoons_

EXHIBIT

PO!idll1- 1'" (Revise!:! 0"00)
/J.

111.1 N',.C12Y 12/12 'uo 1!):2c, II)
1~/1211000 10: ~9 F.U 51~ 557 7602

"IAII IHUMAS

fAX:2l1I:J32'

WELLS }-",\j{loU r l~."L'\".I."'j....

Any team member who believes that he/she or anoth~r team member has been subjected to h~rassment by another team member or any other person within the workplace must Immediately repon: the alleged conduct to either:
Pete DeLanoi! Director of Human Resou"es Wells Fargo Fin=ncial. Inc. 206 Eighth Street Des MoinES. lOWe 50309 515557-7200 petedelanolt@financial.welisfargo.com
or
Jame, E. Goodson Senior Vice President Wells Fargo Finandal. Inc. 206 Eighth Street Des Moines. IOwa 50309 515557-7332 jimgoodson@financial.wellsfargo.com
Every report will be promptly investigated. and information received will be treated as eonfidential. ex~ept as necessal)/ to investigate the report. Any retaliation against a team member who reported suspeaed harassment is illegal. will not be tolerated. and should be reported immediately. Any team memberfound to have engaged in harassing conduct will be subjeC{to disciplinary action. including but not limited to. counseling or training. a reprimand, transfer. demotion. suspenSion With or without pay. and termination of employment.

NOTICE TO ALL EMPLOYEES
This notice is being posted pursuant to an agreement between Wells Fargo Financial Acceptance Idaho, Inc. (formerly known as Fidelity Financial Services, Inc., which was formerly known as Fidelity Financial Services, Inc.) and the Equal Employment Opportunity Commission, entered as the result of a settlement of a lawsuit pending in the United States District Court for the District Idaho, Civil No. CIV99-0610-S-BLW.
Title VII of the Civil Rights Act of 1964, as amended, the Age Discrimination in Employment Act of 1967, the Equal Pay Act of 1963, and the Americans with Disabilities Act of 1990 are enforced by the EEOC and require the following:
That there be no discrimination against any employee or applicant for employment because of the employee's race, sex, color, religion, national origin, age (over age 40), or disability with respect to hiring, firing, compensation, or other terms, conditions or privileges of employment. Sexual harassment is a form of sex discrimination, and is also prohibited under Title VII.
It is an unlawful employment practice for an employer to retaliate against any employees or applicants for employment because they have opposed a practice or because they have made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under these statutes.
Wells Fargo Financial Acceptance Idaho, Inc. has posted this notice because the company supports and will comply with these federal laws in all respects and will not take any retaliatory action against employees because they have exercised their rights under the law. Wells Fargo Financial Acceptance Idaho, Inc. also has an anti-sexual harassment training program and distributes to all employees and managers the Company's policy prohibiting sexual harassment.
DATED _ _ _ _ _ _ _ _ _ _ __
BY_________________________
S:\legal\CASES\Fidel ity\notice2-Dec 18. wpd

 
 District of Idaho Live CM/ECF - Docket Report

https://ecf.idd.uscourts.gov/cgi-bin/DktRpt.pl?835507093611811-L_35...

JURY, MTNDDL, RFDISC, TERMED
U.S. District Court District of Idaho (LIVE Database)Version 3.0.4 (Boise) CIVIL DOCKET FOR CASE #: 1:99-cv-00610-BLW

EEOC v. Fidelity Financial, et al Assigned to: Honorable B. Lynn Winmill Demand: $0 Cause: 42:2000 Job Discrimination (Employment)

Date Filed: 12/29/1999 Date Terminated: 01/17/2001 Jury Demand: Defendant Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by A Luis Lucero, Jr US EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office 909 First Ave #400 Seattle, WA 98104-1061 (206) 220-6883 Fax: 1-206-220-6911 Email: luis.lucero@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Claire Cordon US EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office 909 First Ave #400 Seattle, WA 98104-1061 (206) 220-6883 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kathryn Olson EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 909 First Ave #400 Seattle, WA 98104-1061 (206) 220-6895 Fax: (206) 220-6911 Email: kathryn.olson@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.

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District of Idaho Live CM/ECF - Docket Report
Defendant Fidelity Financial Services of Idaho, Inc.
Defendant Fidelity Financial Services, Inc
Defendant Norwest Financial, Inc
Intervenor Plaintiff Stacie Schiffer

https://ecf.idd.uscourts.gov/cgi-bin/DktRpt.pl?835507093611811-L_35...
represented by C Clayton Gill MOFFATT THOMAS BARRETT ROCK & FIELDS PO Box 829 Boise, ID 83701 (208) 345-2000 Fax: 1-208-385-5384 Email: ccg@moffatt.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gerald T Husch MOFFATT THOMAS BARRETT ROCK & FIELDS PO Box 829 Boise, ID 83701 (208) 345-2000 Fax: (208) 345-2000 Email: gth@moffatt.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by C Clayton Gill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gerald T Husch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by C Clayton Gill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gerald T Husch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by John Charles Lynn LYNN SCOTT & HACKNEY 500 W Bannock

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District of Idaho Live CM/ECF - Docket Report

https://ecf.idd.uscourts.gov/cgi-bin/DktRpt.pl?835507093611811-L_35...

Boise, ID 83702 (208) 342-7600 Fax: 1-208-342-6553 Email: johnlynn@spro.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 12/29/1999 03/31/2000 04/07/2000 04/07/2000 04/07/2000 04/17/2000 04/17/2000 04/17/2000 04/18/2000 04/18/2000 05/12/2000 06/02/2000 06/12/2000 06/12/2000
01/17/2001

#

Docket Text

1 COMPLAINT (Summons(es) issued) (jml)
2 FIRST AMENDED COMPLAINT [1-1] by pla; jury demand; adding Fidelity Fin Svc Inc, Norwest Financial (wm) (Entered: 04/03/2000)
3 MOTION by Stacie Schiffer to intervene (wm) Modified on 04/10/2000 (Entered: 04/10/2000)
4 MEMORANDUM by intervenor-pla Stacie Schiffer in support of motion to intervene [3-1] (wm) (Entered: 04/10/2000)
5 AFFIDAVIT of John C. Lynn in support of motion to intervene [3-1] (wm) (Entered: 04/10/2000)
6 RETURN OF SERVICE/PROCESS executed upon def Fidelity Financial on 3/31/00 (wm) (Entered: 04/18/2000)
7 RETURN OF SERVICE/PROCESS executed upon def Fidelity Fin Svc Inc on 3/31/00 (wm) (Entered: 04/18/2000)
8 RETURN OF SERVICE/PROCESS executed upon def Norwest Financial on 3/31/00 (wm) (Entered: 04/18/2000)
9 ANSWER by defs; jury demand (wm) (Entered: 04/19/2000)
10 RESPONSE by defs to motion to intervene [3-1] (wm) (Entered: 04/19/2000)
11 NOTICE OF STATUS CONFERENCE ; Telephonic Status Conference set for 9:00 6/8/00 before BLW in Boise (wm)
12 STIPULATED SCHEDULING CONFERENCE FORM - LITIGATION PLAN (wm) (Entered: 06/05/2000)
13 ORDER by Honorable B. Lynn Winmill granting motion to intervene by Stacie Schiffer [3-1] (cc: all counsel) (wm) (Entered: 06/14/2000)
14 SCHEDULING ORDER by Honorable B. Lynn Winmill ; Telephonic Status Conference held 6/8/00 ; Discovery ddl set for 3/9/01 ; Disp Motion ddl set 2/9/01 ; Pretrial Conference set for 6/26/01 at 8:30 ; Jury Trial set for 7/9/01 at 1:30 Matters of discovery referred to Magistrate Mikel H. Williams (cc: all counsel) (wm) Modified on 07/18/2000 (Entered: 06/14/2000)
15 ORDER APPROVING SETTLEMENT AGREEMENT by Honorable B. Lynn Winmill dismissing case (cc: all counsel) (wm) (Entered: 01/18/2001)

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https://ecf.idd.uscourts.gov/cgi-bin/DktRpt.pl?835507093611811-L_35...

01/17/2001

16 SETTLEMENT AGREEMENT (wm) (Entered: 01/18/2001)

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