UNITED ~TATES COURTS

SOUTHERN DISTRICT OF TEXAS

gs -er. IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

FILED
SEP 14 2004
'

...... Milby,

EQUAL EMPLOYMENT OPPORTUNITY §

COMMISSION,

§

Plaintiff,

§ §

H-04-3584

§

v.

§ CIVIL ACTION NO. _ _ __

§

SLICK WILLIES OF AMERICA, INC.;

§

SLICK WILLIE'S FAMILY POOL HALL, §

INC.; 8471, INC.; 6969 GULF, INC.;

§

1200, INC.; 11852, INC.; 11312, INC.; 3895 INC.;§

SLICK WILLIE'S BAYOU PLACE, INC.;

§

SLICK WILLIE'S HOLLISTER POINTE, INC.;§

12867, INC.; 12138, INC.; and 20801, INC., §

§

Defendants.

§ JURY TRIAL DEMANDED

ORIGINAL COMPLAINT OF THE
UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

TO THE HONORABLE UNITED STATES DISTRICT COURT:

NATURE OF THE ACTION

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

the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of sex, and to

provide appropriate reliefto David B. Perry and other male job-seekers at Defendants' locations in

and around Houston, Texas, each of whom were adversely affected by such practices. As alleged

with greater particularity in paragraphs 7-10, below, Defendants discriminated against males by

failing to recruit and hire them.

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C §§ 451, 1331, 1337, 1343, and 1345. This action is authorized and instituted pursuant to Sections 706(f)(1) and (3) and 707 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e-5(f)(I) and (3) and 2000e-6 ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. 2. The alleged unlawful employment practices were and are now being committed within the jurisdiction ofthe United States District Court for the Southern District ofTexas, Houston Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, as amended, and is expressly authorized to bring this action by Section 706(f)(1) and (3) and 707 of Title VII, 42 U.S.C. §§ 2000e-5(f)(I) and (3) and 2000e-6. 4. At all relevant times, Defendant 20801, Inc., has continuously been a Texas corporation doing business in the State ofTexas and the City ofWebster. All other Defendants have continuously been Texas corporations doing business in the State ofTexas and the City ofHouston. Collectively, Defendants have continuously had at least fifteen (15) employees. Each Defendant may be served with process by serving the registered agent of all Defendants, Ronald A. Monshaugen, 1225 North Loop West, Suite 640, Houston, Texas 77008. 5. At all relevant times, Defendants (collectively "Slick Willie's") have continuously been employers 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).
2

STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, David B. Perry filed a charge with the Commission alleging violations of Title VII by Slick Willie's. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least October 2000, Defendants have engaged in unlawful employment practices at their Houston-area facilities, in violation of Sections 703(a) and 703(k) of Title VII, 42 U.S.C. §§ 2000e-2(a) and (k). Defendants collectively have more than 100 employees. 8. Defendants have discriminated against males as a class in their recruiting and hiring practices. In October 2002, David Perry saw a "Now hiring" sign on the door ofthe Slick Willie's location at Bayou Place in Houston. He inquired about employment, and filled out an application, but was told by the manager on duty that Defendants did not hire males as waitstaff, and that the policy to hire only females as waitstaff"came down from corporate." 9. From January 1,2002, through November 30, 2002, over 250 different people worked as waitstaff at Defendants' locations in the Houston area. All were female. 10. Defendants also discriminated against males in their recruitment and hiring for bartender positions. While males have accounted for a significant majority of the applications for bartender positions, Defendants have staffed most of their bartender positions with women. 11. The effect of the practices complained of in paragraphs 8 - 10, above, has been to deprive David Perry and the other class members of equal employment opportunities and otherwise adversely affect their status as applicants for employment, because of their sex. 12. The unlawful employment practices complained of in paragraphs 8 - 10 were and are intentional.
3

13. The unlawful employment practices complained of in paragraphs 8 - 10, above, were and are done with malice or with reckless indifference to the federally protected rights of David Perry and other male job-seekers.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns and all persons in active concert or participation with them, from engaging in discriminatory hiring and recruitment practices, and any other employment practice which discriminates on the basis of sex. B. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns, and all persons in active concert or participation with them, from engaging in any unlawful retaliation against individuals who oppose employment practices reasonably believed to be unlawful under Title VII, or against individuals who assist, encourage, and/or support others who oppose employment practices reasonably believed to be unlawful under Title VII. C. Order Defendants to institute and carry out policies, practices and programs which provide equal employment opportunity for males, and which eradicate the effects of their past and present unlawful employment practices against males. D. Order Defendants to make whole David Perry and other class members by providing appropriate backpay with prejudgment interest, in amounts to be proved at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to rightful-place instatement to aggrieved males, or in the alternative to provide front pay. E. Order Defendants to make whole David Perry and other class members by providing
4

compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 8-10, above, including job search expenses, in amounts to be detennined at trial.
F. Order Defendants to make whole David Perry and other class members by providing compensation for past and future nonpecuniary losses resulting from the unlawful employment practices described in paragraphs 8-10, above, including emotional pain, inconvenience, and humiliation, in amounts to be detennined at trial.
G. Order Defendants to pay David Perry and other class members punitive damages for their malicious and reckless conduct described in paragraphs 8 - 10, above, in amounts to be detennined at trial.
H. Grant such further relief as the Court deems necessary and proper in the public interest.
1. Award the Commission its costs of this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted,
Eric s. Dreiband
General Counsel James L. Lee Deputy General Counsel Gwendolyn Young Reams Associate General Counsel
5
------

Equal Employment Opportunity Commission 1801 L Street, N.W.
------ Washington, D.C. 20507
---J~ Gcr-
Timothy M. Bow Senior Trial Atto ey Attorney-in-Charge Texas Bar No. 00793371 Southern Dist. of Texas No. 20023 Equal Employment Opportunity Commission 1919 Smith Street, 7th Floor Houston, Texas 77002 (713) 209-3395 (713) 209-3402 [facsimile]
OF COUNSEL: Jim Sacher Regional Attorney Rose Adewale-Mendes Supervisory Trial Attorney Equal Employment Opportunity Commission 1919 Smith Street, 7th Floor Houston, Texas 77002
6
-------

JS 44

(Rev. 07/89)

CIVIL COVER SHEET

The JS 44 civil cover sheet and the infonnation contained herein neither replace nor supplement the filing and selVlce of pleadings or other papers as required by law, except as provided by local rules of coun. This fonn,

6r;~:: ~~~~~dicial Conference of the United Sllltes in September 1974, is required for the use of the Clerk of Coun for the purpose of initiBatinsthe civil doocket Sheet. (SEE INSTRUCT10NS 0sNTII4REEVERSE

)("r&X. I(a) PLAINTIFFS
EQUAL EMPLOYMENT

OPPORTUNITY

COMMISSIONt\t~

\"

~ (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF

~ ~

DEFENDANTS

4 -

-

SLICK WILLIES OF AMERICA, INC. ET AL

35

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _ _ __

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLy)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE

CT OF LAND INVOLVED

(C) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE Nu~MTHERN DISTRICT ~SS (IF KNOWN)

Tim Bowne, Trial Attorney

FILED A. Martin Wickliff, Jr.

EEOC-Houston District Office 1919 Smith Street, 7th Floor

SEP 14.20 ~

Epstein Becker Green Wickliff & Hall

.....

ljOOO Louisiana, Ste. 5400

Houston, Texas 77002

~ .

Houston, Texas 77002

(713) 209-3395

II. BASIS OF JURISDICTION (pLACE AN xIN ONE BOX ONLy)

[x] I u.s. Government
PlaintilT
II 2 U.S. Government
Defendant

[J 3 Federal Question (U.S. Government Nota Pany)
II 4 Diversity
(Indicate Citizenship of Parties in Item 11\)

III. CITIZENSHIP OF PRINCIPAL PARTIES (pLACE AN xIN ONE BOX

(For DIversity Cases Only)

FOR PLAINTIFF AND ONE BOX FOR OEFENDANI)

PTF DEI'

PTF DEI'

Citizen ofThis State [ ] I [] I Incorporated or Principal Place [ ] 4 [] 4

of Business In This State

Citizen of Another State []2 []2 Incorporated and Principal Place [ ] 5 [] 5

of Business in Another State

Citizen or Subject ofa [ ] 3 [] 3 Foreign Nation

[]6 []6

Forei n Country

IV. C AUSE 0 FACTION (CITIl nm u.s. CIVIL STA1VI1l UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATIlMENT OF CAUSE 00 NO ICITIl JURISDICTIONAL STA1VI1lS UNLESS DIVERSITY.)
SlIck Willies of America, [nco et al engaged in unlawful employment practices in violation of Section 706(f)(J) and (3) and 707 ofTitie VII, 42 U.S.C.§§ 2000e-5 (f)(J) and 3 and 2000e-6. The practice include unlawful employment discrimination on the basiS of sex and not providing appropriate relief to David Perry and other male job-seekers at Defendants' locations In and around Houston, Texas, each of whom were adversely affected by such practices.

V NATURE OF SUIT (PLACE AN xlN ONE BOX ONLY)

CONTRACT

TORTS

[] 11 0 In'uno"", [] 120 Manne [] 130 M,II" Aot
(] 140 Negotiable Instrwnenl
(] ~n9a::~;J=~t &
[] lSI M"",,,~A"
nsl~~:~:~~~:~~)
[] ~~~:'~=Ii~CMrpa)1llenllJf
(] 160 StockholrJc..n' SUits
[] 190 Qth"Con"''' [] 195 CO
REAL PROPERTY
[] 210 1.and Condemnution
[] 220 Fnrcel",,,,,,
[] 230 Rent Lase & EJcctment
[l240 Tort> In Land
[] 245 Tort Product Llablhty
[] 290 All 00" Ronl Ptnperty

PERSONAL INJURY [] 310 A"P1anc [] 31 S Airplum: rroducll.lllblhty
[] 320 AsSDuJl, Libel & Slander [] 330 Fedl.."fD1 Employen' Liability
[] 340 Manne
[] 345 Manne Product Liability [] 350 Motor Vehicle [] 355 Motor Vchlcle Product
Liability
[] 360 Other Personal InJury
CIVIL RIGHTS [] 441 VOllng
[X] 442 Employmont
[] 443 lIowmglAcoommOOallons
[] 444 Wdf.rc [] 440 Othcr C'VlI R,sh"

PERSONAL INJURY
[] 36~':::.:;:!:-
[] 36t~:::1 InJury--Product
[] 36~~:~;a:;nal Injury
PERSONAL PROPERTY [] 370 00" F",ud [] 37t TNth on l.endtng [] 380 Othcr Penonal Ptnperty Damog. [] ~~~II~;pcrty Dumage Product
PRISONER PETITIONS
[] 510 Motions to VaCAte:' Sentence Habeas Corpus
[] 530 0 ,n=1 [] 535 Daoth P""'ty [] 540 Mondam", & Othcr [] 550 0t00

FORFEITURE/PENALTY
[] 610 Asn,ultwc [] 620 Othe< Food & Drus
[] ~~i'':;~'':8~=Of
[] 630 L'quod..w. [] 640 R R& Tnock
[] 650 AIrline Regs [] 660 OccupatIOnal Safety/Haith
[] 690 LABOR
[] 710 Fair Labor Standards Act
[] 720 l..borlMgml R.I.h....
[] 7iB.~'::::tt Reportmg
[] 740 Railway Labor Act
[] 790 Othcr Labor Lot'gation [] 79 ~,~mpi Rot I"" Secunty

BANKRUPTCY [] 422 Ap"..12. usc 158 [] 423 W,thdmw.l28 usc 157
PROPERTY RIGHTS
[] 820 COl'Y"shto [] 830 P,tent [] 840 T",dcm"k
SOCIAL SECURITY
[] 861 ilIA (1395fl) [] 862 m"kLung (923) [] 863 DIWClDIWW (405(g» [] 864 SSID Totl. XVI [] 865 RSI (405(g»
FEDERAL TAX SUITS
[] &7.!~~~CJ (U.S. Plamllff Of
[] 871 IRS-llurd Party 26 USC 7609

OTHER STATUTES
[] 400 s.... Roappo"n..menl [] 410 Anht","
[] 430 Banka and Bankme
[] 450 c"""","""cc R.tW... [] 460 Ooportallon [] 4Z!';:t= Influon=! and Comopt
[] 810 Sci,,,,,,,, Scm""
[] ~~urilleaIComrnOthtU:sI
[] 87~2~":c"';'4~~hallong. [] 891 Asn,u"unol A,,,
[] 892 EconomIC Stabilization Act [] 893 Envl.Rmmental Matten
[] 894 Enorgy AII"",hon Aot
[] 895 Freedom of Information Act
[] ?PJerAr::II::,~=tlon
[] 950 ConstltutlOTlIIIhty ofSlatc Starutn [] 890 Other Statulol)' Action!

VI. ORIGIN
[X] I Original
Proceeding

(PLACE AN x IN ONE BOX ONLy)

[] 2 Removed from

[] 3 Remanded from

State Court

Appellate Court

Transferred from

[] 4 Reinstated or

[] 5 anolher district

Reopened

(specify)

Appeal to District

[] 6 Multidlstrict

[] 7 Judge from

Litigation

Magistrate Judgment

VII. REQUESTED IN

CHECK IFTHIS IS A CLASS ACTION

COMPLAINT:

[) UNDER F.R.C.P. 23

DEMAND $

Check YES only if demanded in complaint:

JURy DEMAND:

[Xl YES

[) NO

VIII. RELATED CASE S IF ANY (Seoi"'tructi....)

10 Cf DAm

11L.j

q

SIONAlURI! OF ATTORNBY OF RI!CORD

JUDGE

DOCKET NUMBER

UNITED STATES DISTRICT COURT

 
 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

SouUthnaitmedDSitsatrteicst CofouTretaxas
ENTERt:O
SEP 2 0 2004

EQUAL EMPLOYMENT OPPORTUNITY

§

COMMISSION,

§

Plaintiff

§

§

VS.

§

§

SLICK WILLIES OF AMERICA INC.;

§

SLICK WILLIES FAMILY POOL HALL INC.; §

8471 INC.; 6969 GULF INC.; 1200 INC,;

§

11852 INC.; 11312 INC.; 3895 INC.;

§

SLICK WILLIES BAYOU PLACE INC.;

§

SLICK WILLIES HOLLISTER POINT INC.;

§

12867 INC.; 12138 INC.; AND 20801, INC.,

§

Defendants

§

B-04-3584
CIVIL ACTION H-04-_ __

CONSENT DECREE

Plaintiff, the United States Equal Employment Opportunity Commission ("Commission"

or "EEOC"), and Defendant, Slick Willies Of Americas USA, Ltd., (collectively known as "Slick

Willies," "Slick Willies of America, or Defendant") agree to entry of this Consent Decree.

I.

Background and History of Proceedings

A. Charging Party, Robert Perry ("Perry"), filed a Charge of Discrimination with the Commission on October 23, 2002, alleging Defendant violated Title VII of the Civil Rights Act

of 1964, 42 U.S.C. 2000e et seq. ("Title VIlli); Charge No. 330 2003 00210.

B. On ,Sept. 14,2004, the Commission filed this action alleging that Defendant

discriminated against Perry and other men because of their gender in violation of Section 703(a)

of Title VII by failing to recruit and hire them because oftheir gender, male. C. Slick Willies denied all of the allegations of discrimination lodged by the EEOC.

D. The parties have resolved all issues raised in this litigation and wish to avoid

protracted and expensive litigation. Accordingly, the parties have agreed to settle this lawsuit.

Neither Defendant's consent to the entry of this Consent Decree nor any of the tenns set forth in it shall constitute or be construed as an admission of any Title VII violation. The parties agree that this Consent Decree is being entered for the sole purpose of compromising disputed claims without the necessity for protracted litigation. This Consent Decree resolves all issues raised in the complaint of the EEOC through the date of this Consent Decree, and the parties accept this Consent Decree as final and binding among themselves as to the issues resolved herein. This Consent Decree shall not constitute an admission, an adjudication or a finding on the merits of the case.
E. The Commission and Slick Willies Of Americas stipulate to the jurisdiction of the court and the satisfaction of all administrative prerequisites. No party shall contest the jurisdiction of this court to enforce this Consent Decree.
F. The parties further waive hearing and entry of findings of fact and conclusions of law on all issues.
IT IS ORDERED that: 1. This Consent Decree is entered in full and complete settlement of any and all claims made by
Y the Commission arising out of or asserted in Civil Action H-04-ii& and the above-referenced
Charge on behalf of Mr. Perry and a class of male applicants for wait staff and bartender jobs in 2002 at Slick Willies' Houston-area facilities. 2. The Company's employment practice will be maintained and conducted in a manner which do not violate Title VII of the Civil Rights Act of 1964, as amended. 3. The attached Notice (Exhibit A) will be posted in a conspicuous area frequented by all employees at defendant's Houston locations for a period of two (2) years commencing within thirty (30) calendar days following the date of this Consent Decree. Defendant agrees to take reasonable steps to assure that the Notice will remain in place for the entire period of time.
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4. Slick Willies will provide an independent experienced training person or group who shall provide a program on employment discrimination, including the law relating to Title VII, to all management level employees and any other staff involved in recruitment and/or hiring of staff, whether characterized as employees, independent contractors or otherwise. The names of all attendees will be provided to the Commission, and attendees will be told that discipline will be administered to store managers who are found to violate this consent decree and who do not adhere to the defendant's training principles; and attendees will be advised that notices are being posted as a reminder about the company's obligations under Title VII and that the notices will remain posted for two (2) years. The training shall be completed no later than January 31, 2005, or within six(6) months from the date the Consent Decree is entered, whichever date is later. The person who shall administer the training will be either attomey(s) or person(s) possessing at least five years of experience in labor and employment law. Written acknowledgment of receipt of the training shall be obtained by Defendant from all individuals attending the training and retained among the employment records of Defendant. 5. Within one (1) week after the entry of this Decree, Defendant shall establish a restricted escrow bank account at Southern National Bank for the sole purpose of disbursement of settlement funds. Charging Party will be paid back pay, minus interim earnings, as other class members, within one (1) week after defendant receives the Commission's calculation of Charging Party's back pay. Within two weeks after the Commission identifies the class members, pursuant to paragraph 7 of the Consent Decree, Defendant shall fund that escrow account by placing therein the entire settlement fund of $49,000, minus what has already been paid to Charging Party. Any interest accrued from that account shall be paid to the class. 6. The Commission will develop a list of persons to whom settlement checks will be made payable. If up to $5,000 remains undistributed, that money shall revert to the company to be used to defray the cost of training, pursuant to paragraph 4. Any balance over $5,000 after
3

--- -"--"---------
disbursal to class members and Charging Party will be donated to charity regarding placement of persons in employment and to be mutually selected by the parties. 7. The Commission shall have until 120 days from the entry of this Decree to identify all class members and notify defendant of their identification. The list of the known class members will include their names and home addresses. Defendant shaH begin preparing checks to the identified class members within 30 days after receiving notice from the Commission. The checks shall be delivered to the Commission for distribution to the class members by the Commission. The checks shall be delivered to: Legal Unit, EEOC, 7th Floor, Houston, Texas 77002. Edmond Mab, co-owner of defendant, with the assistance of his counsel in the litigation; will file annual reports for two (2) years regarding defendant's efforts to assure affirmative recruitment and hiring of qualified male applicants. The defendant will retain its website that shows it is an equal employment opportunity employer. 8. Defendant shall not retaliate against any class member who receives a distribution of settlement monies. 9. Hiring goals: The Company agrees that it will not discriminate against male applicants, and will continue its policy of affirmatively recruiting male applicants for its establishments. 10. Each party to this Consent Decree shall bear their own costs and attorney's fees. 11. Defendant agrees that it is subject to the jurisdiction of the Houston federal court if the Commission believes Defendant has violated the terms ofthis Consent Decree. 12. This Consent Decree shall be binding on Defendant and all of Defendant' subsequent successors-in-interest, and Defendant will notify all such subsequent successors-in-interest of the existence and terms of this Consent Decree. As used herein, successors-in- interest shall mean a company or other entity which succeeds to the corporate entity ofDefendant. 13. Nothing in this Consent Decree shall be construed to preclude the Commission from filing a separate action in the future on behalf of anyone other than Mr. Perry and the class of male
4

---"'------------------ --------- -----

applicants as designated within under Title VII, or any other statute which the Commission

enforces, for any alleged pending or subsequent violations by Defendant not resolved by this

Decree.

14. Each signatory certifies that he or she is authorized to execute this document on behalf ofthe

party or parties whom they represent.

t Signed this I day of September 200c:::~uston. Texas.

¥ , ~;

,F/g(}()¥

AGREED AND CONSENTED TO:
ATTORNEY FOR DEFENDANT SLICK WILLIES

ATTORNEY FOR PLAINTIFF EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Epstein Becker Green Wickliff & Hall, P.C. Attorney -in- Charge TBN: 21419900 1000 Louisiana, Ste. 5400 Houston, TX 77002 (713) 750-3100 fax (713) 750-3101

es Sacher ( A orneY-in-Charge ~ OC, Houston District Office
919 Smith, 7th Floor Houston, TX 77002 (713) 209-3398 fax (713) 209 3402 BN: Texas: Southern District of Texas No.

HO:46377vl

5

NOTICE REGARDING
EQUAL EMPLOYMENT OPPORTUNITY LAWS
Federal law requires that there be no discrimination against any employee or applicant for employment because of the employee's 'race, color, religion, sex, national origin, age or disability with respect to compensation, terms, conditions, or privileges of employment. Visit the Equal Employment Opportunity Commission at WWW.EEOC.GOV for more information.
Slick Willies supports the enforcement of all laws prohibiting discrimination; and it does not and will not interfere with anyone who exercises hislher rights under Title VII of the Civil Rights Act of 1964, as amended, Age Discrimination in Employment Act of 1967, as amended, Equal Pay Act of 1963, as amended, Americans with Disabilities Act of 1990, or who files a charge, testifies, provides assistance or information, or participates in any manner in an investigation, proceeding or hearing relating to charges filed with the Commission.
Specifically, Slick Willies does not and will not tolerate the denial of employment or promotion of an individual because of the individual's race, color, religion, sex, national origin, age or disability. SLICK WILLIES does not and will not engage in any employment practices which have the effect of discriminating against its employees because of race, color, religion, sex, national origin, age or disability. In the event you feel you have been discriminated against, you have duty to report this to Slick Willies' corporate office, 6222 Richmond, Suite 500-A, Houston, Texas 77057, telephone number 713-978-7390. SLICK WILLIES encourages all employees to visit WWW.EEOC.GOV for more information regarding employment rights.
Signed this _ _ _ day of _ _ _ _ _ _ _ _ 2004.

Signature of Respondent

Title

EXHIBIT" A"

 
 DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

https://ecf.txsd.uscourts.gov/cgi-bin/DktRpt.pl?319332580399643-L_3...

U.S. District Court SOUTHERN DISTRICT OF TEXAS (Houston) CIVIL DOCKET FOR CASE #: 4:04-cv-03584

CLOSED

Equal Employment v. Slick Willies of America Inc et al Assigned to: Judge Nancy F. Atlas Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 09/15/2004 Date Terminated: 09/18/2004 Jury Demand: Defendant Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Timothy M Bowne EEOC 1919 Smith 7th Fl Houston, TX 77002 713-209-3395 Fax: 713-209-3402 fax Email: timothy.bowne@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Slick Willies of America Inc
Defendant Slick Willie's Family Pool Hall Inc
Defendant 8471 Inc.

represented by A Martin Wickliff, Jr Epstein Becker et al 1000 Louisiana Ste 5400 Houston, TX 77002-5013 713-750-3110 Fax: 713-750-3101 Email: mwickliff@ebglaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address)

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DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

https://ecf.txsd.uscourts.gov/cgi-bin/DktRpt.pl?319332580399643-L_3...

Defendant 6969 Gulf, Inc.
Defendant 1200, Inc.
Defendant 11852, Inc.
Defendant 11312, Inc.
Defendant 3895 Inc.
Defendant Slick WIllie's Bayou Place, Inc.
Defendant Slick Willie's Hollister Pointe, Inc.
Defendant 12867, Inc.

LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY

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DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

https://ecf.txsd.uscourts.gov/cgi-bin/DktRpt.pl?319332580399643-L_3...

Defendant 12138, Inc.
Defendant 20801, Inc.

ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by A Martin Wickliff, Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/14/2004 09/14/2004
09/14/2004 09/14/2004 09/18/2004

#

Docket Text

1 COMPLAINT against Slick Willies of America Inc et al (Filing fee $ 150) filed by Opportunity Commission Equal Employment.(hlerma, ) (Entered: 09/15/2004)
2 ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 1/14/2005 01:00 PM in Courtroom 9F before Judge Nancy F. Atlas. Parties notified.(hlerma, ) (Entered: 09/15/2004)
3 ANSWER to Complaint with Jury Demand by Slick Willies of America Inc et al, filed.(hlerma, ) (Entered: 09/15/2004)
4 PROPOSED Consent Decree ORDER , filed.(hlerma, ) (Entered: 09/15/2004)
5 CONSENT DECREE.( Signed by Judge Nancy F. Atlas ) Parties notified.(amaly, ) (Entered: 09/20/2004)

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