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USAO Cl VlL. lINn:-
' .

IN THE UNITED STATES DISTRICT' cou~1l ocr 30 p 2: 43
FOR. THE DISTRICT OF MARYLAND . Division
r:; \/
. --.._··. _·--OEPUTY

UNITED STATES OF AMERICA, Plaintiff,-
v. PRINCE GEORGE'S COUNTY, MARYLAND,
Defendant.

Civil Action No.

COMPLAINT AND DEMAND FOR JURY TRIAL

J?lainti.ff, United States of .America, alleges:

1. This action. is brought on behalf of the United States to

enforce the provisions of Title VII of the Civil Rights Act of 1964,

as amended, 42 U.S.C. Section 2000e, §..§.9.. ("Title VII ") .

~ .....

2. This Court has jurisdiction over the action under 42 U.S.C.

Sectiorl2"OOOe-5(f) and 28 U.S.C. Section 1345.

3. -Defendant Prince George's County, Maryland i~; a political
/
subdivision of the State of Maryland created pursuant to Maryland law .

. Defendant Prince George'S'lS:ounty I Maryland is a parsor:, wi thin the
.\
II
meaning of 42 U.S.C. Sectioin 2000e(a), and an employei within the
,/ ;
me~ni\ng of 42 U.S.C. Section 2000e(b).

4. '..' J;)efendant Prince George's County has discriminated against

Sharon Flory, a female formerly employed as a Fire Technician in the

,
'.

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14]009

County's fire Department, because of her sex, in violation of Section

703(a) of Title VII of the Civil Rights Act of 1964, as amended, 42

U.S.C. Section 2000e-2{a), among other ways, by:

a. subjecting Ms. Flory to harassment based on her sex

while she was employed in the Fire Depal:1:me'nt, which

created an intimidating, hostile br offensive work

-;

environment and which adversely affected the terms,

conditions and privileges of Ms. Flory' ~$ employmenti

b. failing or refusing to take appropriate action to

remedy the effects of the discrimination against

Ms. Flory.

5. Defendant Prince George's County also has retaliated against

Sharon Flory because she complained to officials in the County's Fire

Department about what she believed to be discrimination in employment

on the basis 'of sex, in violation of Section 704(a) of Title VII of

the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-

3(a), among other ways, by:

a. imposing an operational suspensidn on Ms. FlorYi

b. transferring Ms. Flory to a less desirable

assignment that resulted in a loss of pay;

c. issuing a "Step II" discipiinary "Letter of

Unsatisfactory Performance" to Ms. Flory; and

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d. failing or refusing to take appropriate action to remedy the effects of the discrimination against Ms. Flory.
6. The Equal Employment Opportunity Commission ("EEOC") receiv~d a timely charge filed by Ms. Flory (Charge No. 120-98-1l46} in which she alleged that the Prince George's County Flre Department discriminated against her in violation of Title VII by subjecting her to a hostile work environment and harassment based on her sex and retaliating against her based on her complaints about 1:::19 hostile environment.
7. Pursuant to Section 706 of Title VIr of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5, the EEOC investigated the charge, found reasonable cause to believe that Ms. clary's . allegat~ons of sex discrimination and retaliation were true, unsuccessfully attempted to achieve through conciliati<::m a voluntary resolution of these matters, and subsequently referred the charge to the Department of Justice.
~ ,"
8. All conditions precedent to the filing of suit have been performed or have occurred.
WHEREFORE, plaintiff United States prays that this Court grant the following relief:
(al Enjoin defendant Prince George's County from failing or refusing to:

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I4J OLl:.

(i) provide sufficient remedial relief to make whole Sharon Flory for the loss she has suffered as a result of the discrimination against her as alleged in this complaint;
(ii) adopt a clear 1 meaningful, and well-p.ublicized written policy prohibiting sexual harassment and retaliation against employees in the County's Fire Df~partment/_ which includes provisions describing responsibilities of all supervisors to report and respond to complaints of sexual harassment and which establishes an effective mechanism for receiving and responding to complaints of sexualharassrnent;
(iii) provide adequate training to employees in the County's Fire Department, and all volunteer fire personnel who work with employees in the County's Firl= Department, wi th regard to sexual harassment and ret.aliation
prohibited by Ti~t...l. e VII.
(iv) modify any existing policies requiring transfers of employees in the County's Fire Department who complain about sexual harassmenti
(v) take appropriate actions to remedy and to prevent acts of sexual harassment and retaliation by volunteer fire personnel who work with employees in the County's Fire

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USAO CIVIL U'.NIT

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Department against employees in the County's Fire Department; (vi) take other appropriate nondiscriminatory measures to overcome the effects of the discrimination. (b) Award compensatory damages to Sharon Flory fClr mental and/or physical injuries incurred as a result of the discrimination against her as alleged i)1- this complaint, pUl=suant to and within the statutory limitations of Section :.02 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981a. The plaintiff prays for such additional relief as justice may' require, together with its costs and disbursements in this action.
JURY DEMAND The United States hereby demands a trial by jury of all issues so triable pursuant to Rule 38 of the Federal Rul~s of Civil Erocedure
,.:

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USAO CIVIL UNIT

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and Section 102 of the Civil Rights Act of 1991, 42 V.B.C. Section
1981a.

JOHN ASHCROF~'~""=-"/

Attorne

al ..

~
-=----L-I-J.~~

By:

i -

RALPH F. BO I JR.

Assistant Attorney Genej:al

Civil Rights Division

U.S. DeI¥r~ent of Justice

\.J.~~.~~
9&~.

-,--

WILLIAM B. FENTON

D.C. Bar Registration No. 414990

JODI B. DANIS (Trial At'torney)

D.C. Bar Registration Nr:J. 453493

Attorneys

U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Employment Litigation Section
Patrick Henry Building, Room 4024

I

Washington, D.C. 20530

(202) 307-5758

(202 ) 514 - 10 05 (fax)

THOMA Unit Scates Att rney Jenn~ er L. Huesman Assistant United States ,Attorney
District of Maryland (410) 209-4800 (410) 962-2310 (fax)

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P.l3

 
 _ _ _FILED

ENTERED

_ _LO~r:m _RECEIVED

IN THE UNITED STATES DISTRICT COURT

OCT 2 j 2003

FOR THE DISTRICT OF MARYLAND Greenbelt Division

AT GREENBELT

CLERK U.S. DlSTRlCT COURT

DISTRICT OF [v'AfWLAND

BY

DEPUTY

)

UNITED STATES OF AMERICA,

)

)

Plaintiff,

)

Civil Action No.

)

DKC-02-3563

v.

)

)

PRINCE GEORGE'S COUNTY, MARYLAND, )

CONSENT DECREE; ORDER

)

)

Defendant.

)

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

CONSENT DECREE

This action was brought by the United States against Prince George's County, Maryland

("County" or "Defendant") to enforce the provisions of Title VII of the Civil Rights Act of 1964,

42 U.S.C. §2000e, et seq., as amended ("Title VII"). In its Complaint, the United States alleges

that the County has discriminated against Sharon Flory, an individual formerly employed as a

fire technician in the County's Fire Department because of her sex, female, in violation of 42

U.S.C. Section 2000e-2(a), and has retaliated against her in violation of 42 U.S.C. Section

2000e-3(a).

The parties, desiring to appropriately settle this action, agree to the jurisdiction of this

Court over them and the subject matter of this action, and hereby waive the entry offmdings of

fact and conclusions oflaw. The parties, desiring to avoid protracted and unnecessary litigation,

also accept this Consent Decree ("Decree") as final on the issues resolved in this Decree. This

Decree, being entered with the consent of the parties, shall not constitute an admission,

adjudication or finding on the merits of this action, and the County denies that any unlawful

discrimination has occurred. In resolution of this action, the parties hereby AGREE and the Court expressly
APPROVES, ENTERS and ORDERS the following: I. DEFINITIONS AND PARTIES 1. The parties to this Decree are the United States, by the Department of Justice ("United States") and Prince George's County, Maryland. 2. Prince George's County, Maryland, its Fire Department, and its current, former and future agents, employees, officials, designees and successors in interests are referred to hereinafter as "the County." 3. The terms "supervisor" and "administrator" include all employees of the County who manage, supervise, or have authority to affect the hiring, firing, discipline, assignments or pay rates of employees in the Fire Department, and all persons who establish policies or procedures for the Fire Department. The term "supervisor" also includes all members of the Fire Department who hold ranks above the level of Volunteer Firefighter and to whom the County has delegated actual or effective supervisory authority over employees in the Fire Department. 4. Sharon Flory is referred to hereinafter as "Ms. Flory." S. "Member" or "Members" refer to all persons who are members of volunteer fire companies that operate within the County, or who are otherwise authorized through'the County to provide firefighting, fire apparatus or emergency vehicle driving or maintenance, emergency medical, or other similar services to County residents on a volunteer basis. 6. The Equal Employment Opportunity Commission is referred to hereinafter as "EEOC." 7. Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e, et seq., is
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referred to hereinafter as "Title VII." 8. "Sexual harassment" is any act that would be prohibited under Title VII's prohibitions against gender discrimination such as unwelcome sexual advances, requests for sexual favors, verbal, physical or other conduct of a sexual nature, or acts of animosity or hostility based on sex (whether or not sexual in nature), any of which creates or tends to create a hostile work environment based on sex for an employee ofthe County's Fire Department. "Sexual harassment" also includes prohibited conduct directed at a member in the County's Fire Department to the extent that it contributes to or creates a hostile work environment based on sex for an employee ofthe County's Fire Department. 9. "Retaliation" is any act that would be prohibited under Title VII's prohibitions against retaliation such as taking an adverse employment action (including disciplining an employee, operationally suspending an employee, transferring an employee involuntarily from shift work to day work, or decreasing the amount ofovertime work available to an employee) because the employee has opposed any practice he or she reasonably believes violates Title VII, or has made a formal or informal complaint or charge, testified, assisted, or participated in any manner in a formal or informal investigation, proceeding or hearing relating to a practice alleged to violate Title VII. 10. "Day" or "days" refers to calendar and not business days. 11. "Date of entry of this Decree" refers to the date that the Court orders entry of the Decree.
II. PURPOSES OF TillS DECREE 12. The purposes of this Decree are to ensure that:
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a. employees in the County's Fire Department are not subjected to sexual harassment in violation of Title VII;
b. employees in the County's Fire Department are not subjected to retaliation in violation of Title VII;
c. all complaints of sexual harassment or retaliation made by Fire Department employees are investigated fairly and promptly, whether the complaints involve conduct by employees or members, and that the County takes appropriate remedial action when the County, through its responsible deciding official(s), determines that the complaints are well-founded;
d. the County adopts and maintains a clear, meaningful and well-publicized policy prohibiting sexual harassment and retaliation in its Fire Department (in compliance with this requirement, the County has agreed to ~~opt the amendment
~
to its policy attached to this Decree as Appendix C); e. the County maintains an EEO Officer for the Fire Department who shall oversee
the receipt and investigation of complaints of sexual harassment and retaliation, and has neither a dual role as legal counsel for the County or its Fire Department regarding claims of employment discrimination or retaliation, nor any other conflict of interest. f. the County provides adequate training to employees and members in its Fire Department, and to all County supervisors, administrators or officials responsible for making determinations regarding complaints of sexual harassment or retaliation, with regard to workplace sexual harassment and retaliation prohibited
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by Title VII, as provided for below; and

g. the County offers to Ms. Flory appropriate individual relief.

TIl. SPECIFIC RELIEF

Without admitting the allegations of the United States, and in settlement of the United

States' claims for relief for Sharon Flory, as well as settlement of the claims ofMs. Flory ifshe

accepts the relief provided her by this Decree, the County agrees to do the following:

13. The County shall offer Ms. Flory a monetary award of $90,000, inclusive of attorney's

fees.

14. The County shall provide Ms. Flory with a retirement badge and certificate.

15. The County will not provide negative employment references for Ms. Flory to any future

prospective employer that inquires about her past employment in the Fire Department, nor will it

refer in any way to Ms. Flory's filing of complaints or charges of sexual harassment or

retaliation or this lawsuit when communicating with prospective employers seeking a reference

for

Ms. Flory. In order to ensure that Ms. Flory does not receive negative employment

references, the County will:

a. expunge from Ms. Flory's personnel files the Letter of Unsatisfactory Conduct

and the notice of operational suspension issued to Ms. Flory in 1998, as well as

any references to her alleged unsatisfactory conduct and her operational

suspension. The County also shall remove from Ms. Flory's personnel files any

and all documents that refer to any internal complaints of sexual harassment or

retaliation made by Ms. Flory during her employment with the County, the charge

of discrimination filed by Ms. Flory with the EEOC (charge No. 120-98-1146),

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the United States' investigation of Ms. Flory's charge of discrimination, and this lawsuit; and b. instruct all of Ms. Flory's former supervisors who are incumbent County employees that they may not give out employment references for Ms. Flory, but will direct the inquiring entity or person to the Office of the Fire Chief. If a reference is requested by a prospective employer, the County will confirm the length of Ms. Flory's employment, the positions she held during her employment in the Fire Department, her past salary history, and the fact that she received overall ratings that placed her between the "exceeds satisfactory" and "outstanding" categories on her performance evaluations. 16. The County shall notify Ms. Flory of the relief being afforded her under the terms of this Consent Decree within seven (7) days of its entry by mailing to her, by certified mail, return receipt requested, a copy of the letter set forth in Appendix A and enclosing a copy of this Decree and a copy ofthe Release in the form set forth in Appendix B. The letter identified as Appendix A will advise Ms. Flory that in order to accept the relief offered her, she must return the executed Appendix B Release to the County within thirty (30) days of her receipt of the Appendix A letter, unless she can demonstrate good cause, to be determined by the United States, for her failure to do so. 17. In order to accept the specific relief to be offered by the County under this Decree, Ms. Flory must execute a Release in the manner attached as Appendix B. 18. The County will pay to Ms. Flory the monetary award specified in paragraph 13, supra, within fifteen (15) days of its receipt of the executed Appendix B Release. The County will
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issue to Ms. Flory, if she accepts the monetary award, an appropriate IRS fonn that reflects the monetary amount. IV. GENERAL INJUNCTIVE RELIEF 19. The County, its employees, supervisors, agents and all individuals in active concert or participation with it, are enjoined from:
a. subjecting any employee in the Fire Department to sexual harassment; b. creating, facilitating, or tolerating sexual harassment or a hostile work
environment based on sex in the Fire Department; c. failing or refusing to use all reasonable and lawful available means to control the
activities of members to prevent them from engaging in sexual harassment of employees in the Fire Department; and d. retaliating against or in any respect adversely affecting any employee in the Fire Department because that individual has engaged in practices protected under 42 U.S.C. 2000e-3(a) (including cooperating with the United. States' investigation of EEOC charge No. 120-98-1146, as amended, or this lawsuit). V. REVISION AND ADOPTION OF FIRE DEPARTMENT HARASSMENT POLICIES AND PROCEDURES 20. Within sixty (60) days after the date of the entry of this Decree, the County shall revise Prince George's County Fire Department General Order No. 1-6, dated February 22,1999 (or any other version ofthat Order that is effective at the time this Decree is entered by the Court), with the approval of counsel for the United States, not to be unreasonably withheld. As indicated in paragraph 12(d), the County has agreed to incorporate and adopt Appendix C as a policy of the County. lfthe County and the United States are unable to agree upon other
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mutually acceptable and appropriate revisions to General Order No. 1-6 within this sixty (60) day period, the dispute shall be submitted to the Court for resolution under paragraph 47, infra. 21. Within seventy-five (75) days of the entry of this Decree, the County and Fire Department shall take all necessary actions to adopt the Revised General Order No. 1-6 as a policy of the County. Within this time period, the County and Fire Department also shall take all necessary actions to adopt Revised General Order No. 1-6 asa Volunteer Services Directive titled "Equal Employment Opportunity" and as a policy of the County applicable to members. 22. Within ninety (90) days ofthe entry ofthis Decree, the County shall issue and distribute to all current Fire Department employees and members Revised General Order No. 1-6 and the Equal Employment Opportunity Volunteer Services Directive. 23. Within sixty (60) days of the entry of this Decree, the County and Fire Department shall take all necessary actions to amend other policies, rules and regulations applicable to employees and members in the Fire Department so that they are consistent with the provisions and requirements ofRevised General Order 1-6 and the Equal Employment Opportunity Volunteer Services Directive. The policies, rules and regulations to be amended include, but are not . limited to: the Prince George's County Fire Department Career Services Directives and the Prince George's County Fire Department Volunteer Services Directives. The amended policies, rules and regulations shall, when appropriate, cross-reference Revised General Order 1-6 and the Equal Employment Opportunity Volunteer Services Directive. All amended policies and rules shall be submitted to the United States for approval. If the County and the United States are unable to agree upon mutually acceptable and appropriate revisions, the dispute shall be submitted to the Court for resolution under paragraph 47, infra.
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24. Within seventy-five (75) days of the entry of the Decree, the County and Fire Department shall take all necessary steps to adopt any policies, rules and regulations amended pursuant to . this Decree as policies ofthe County. Within ninety (90) days of the entry of this Decree, the County shall distribute any amended policies, rules and regulations to all employees and members in its Fire Department. 25. For all future employees and members, the County shall issue and distribute Revised General Order No. 1-6 to employees and members, and the Equal Employment Opportunity Volunteer Services Directive to members, within fifteen (15) days of an employee's hire or member's authorization to begin providing volunteer services. The County shall require all current and future employees and members to sign and date an acknowledgment of receipt of the . Order or Directive when the employee or member obtains a copy of the Order or Directive. 26. The County shall post Revised General Order 1-6 and the Equal Employment Opportunity Volunteer Services Directive in prominent, conspicuous, centrally-located places commonly used for posting notices (e.g., bulletin boards) in each fire station located within the County, in all County Fire Department buildings and facilities and in the County's administrative offices for the Fire Department. The County shall designate one supervisory employee at each fire station who is responsible for ensuring, at least on a monthly basis, that these documents
in remain posted and have not been defaced or altered any fashion.
VI. TRAINING 27. Within one hundred eighty (180) days ofthe entry of the Decree by the Court, the County shall provide mandatory basic training regarding sexual harassment and retaliation for all nonsupervisory Fire Department employees assigned to, and all members who belong to, Companies
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18,21,28 and 42, and combined basic and supervisory training for all County supervisors,· administrators and officials (including members ofthe Fire Commission) responsible for making determinations regarding complaints of sexual harassment and retaliation from Fire Department employees. This training shall be conducted by the United States Department of Justice or its designee. The County shall take any and all reasonable action to ensure attendance by members and employees at the training sessions described below. The Department of Justice reserves the right to require the County to provide additional training of employees at, and members of, other stations, to be presented by the Department of Justice, should it be determined that such training is warranted by the circumstances at particular stations or failure to comply with the provisions ofthis Decree. 28. The basic training class for non-supervisory employees and members of Companies 18,21, 28 and 42 shall be offered on different days and times of day, at one central location in the County, or, at the discretion of the United States, shall be conducted at those fire stations. If any training session held at a station is interrupted due to a fire emergency, the make-up session shall be held at a centrallocation in the County. 29. All supervisory employees, members who hold ranks above the rank of volunteer firefighter, members of the Prince George's County Fire Commission, and all County supervisors, administrators and officials responsible for making determinations regarding complaints of sexual harassment and retaliation from employees in the Fire Department, will be required to attend a combined basic and supervisory training class. The combined basic and supervisory training class shall be offered on different days and at different times of day, at a Department of Justice facility in Washington, D.C.
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30. The County will include a unit on sexual harassment as part of its regular, ongoing inservice training of firefighters and members. 31. All Fire Department employees and members will be asked to sign and date an acknowledgment of attendance for any and all training instituted by the United States or the County concerning sexual harassment and retaliation. VII. EVALUATION OF EMPLOYEES AND MEMBERS 32. Within thirty (30) days of the entry of the Decree, the County shall amend the job descriptions of all employees who have supervisory or managerial authority over employees in the Fire Department to include a duty to know and enforce the law wi.th respect to sexual harassment and retaliation. Also within that 30 day period, the County shall adopt, as a criterion for evaluating the performance of all of its employees who have supervisory or managerial authoritY over other employees in the Fire Department, a factor that takes into account that individual's awareness ofEEO requirements and procedures and his or her commitment to enforcing the County's sexual harassment and retaliation policies. For Fire Department employees, this evaluative criterion shall be incorporated in Past Performance Appraisals ("PPAs") or any other type of written performance evaluations adopted by the County during the period this Decree remains in effect. VIII. PROCEDURES FOR ACCEPTANCE AND INVESTIGATION OF COMPLAINTS
OF HARASSMENT OR RETALIATION 33. Within thirty (30) days after the entry ofthis Decree, the County shall inform all employees in the Fire Department, in writing, ofthe name and contact information of the current designated Fire Department Equal Employment Opportunity Officer (" Fire Department EEO Officer"), as well as the name and contact of an alternative County employee ("Alternative EEO
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Officer"), not in the Fire Department, who is authorized to receive and investigate complaints of sexual harassment and retaliation by employees in the Fire Department (collectively, the "EEO Officers"). Within ten (10) days of the date upon which the County or the Fire Department designates a Fire Department EEO Officer and Alternative EEO Officer, the County shall provide the United States with written notice of the name, title and qualifications of those individuals, and of any other person to whom the Fire Department EEO Officer (or Alternate BEO Officer) anticipates delegating responsibility for the receipt and/or investigation of complaints of sexual harassment under circumstances that would make such a delegation necessary and appropriate. With respect to any person to whom the Fire Department EEO Officer (or Alternate EEO Officer) delegates authority to receive and investigate a complaint, the County also shall provide to the United States a summary of the designee's relevant background and training to receive and investigate complaints of sexual harassment and retaliation prior to any receipt or investigation of a complaint by that designee. 34. The Fire Department EEO Officer and Alternative EEO Officer shall be designated as individuals capable ofreceiving complaints of sexual harassment and retaliation from employees in the County's Fire Department, as set forth in Revised General Order 1-6 and the Equal Employment Opportunity Volunteer Services Directive. These EEO Officers shall investigate all complaints of sexual harassment and retaliation received by them directly from employees, or referred to them by County supervisors, officials or volunteers, as set forth in Revised General Order 1-6 and the Equal Employment Opportunity Volunteer Services Directive, and shall recommend appropriate action pursuant to those policies, including discipline where appropriate. As provided for in paragraph 12(e) of this Decree, the Fire Department and Alternative EEO
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Officers shall maintain neutral roles and must remain free of conflicts of interest. 35. The County will issue quarterly reports to the United States regarding any complaint of sexual harassment or retaliation of a Fire Department employee during the effective period of this Decree. In the report, the County will provide copies of the complaint, advise of the date of receipt and mtture of the complaints, and the findings and outcome ofthe investigation and any actions taken as a result of such findings. Absent extenuating circumstances, which must be explained in the report, all investigations of complaints of sexual harassment or retaliation of a Fire Department employee will be completed within fourteen (14) days ofthe receipt of the complaint. 36. At least one of the EEO Officers shall be present at each basic and supervisory training session presented by the United States or its designee. At least one of the EEO Officers also shall be present at the presentation of the unit on sexual harassment and retaliation during the inservice training required pursuant to paragraph 30, and shall distribute the names and phone numbers ofboth EEO Officers, in writing, to employees and members in the Fire Department during each of those training sessions. IX. TREATMENT OF COMPLAINANTS AND EMPLOYEES OR MEMBERS
ACCUSED OF SEXUAL HARASSMENT OR RETALIATION 37. The County and/or EEO Officers shall accept and investigate complaints of sexual harassment by employees that involve allegations of sexual harassment directed at members, to the extent that the sexual harassment of members may create or contribute to a hostile environment based on sex for the complaining employee. 38. In the interim period between the entry ofthe Decree by the Court and the County's adoption of revised or amended policies and regulations pursuant to part V, the County shall
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implement the procedures set forth in Appendix C upon receipt of a complaint of sexual harassment or retaliation. 39. Without superseding any provisions in Section IX herein, or Appendix C, regarding transfers of complainants andlor members, the County generally reserves the right to engage in transfers of Fire Department personnel required by demonstrated operational needs. However, a complaint of sexual harassment andlor retaliation shall not constitute, de facto, an operational need that would justify transfer of a complainant. 40. None ofthe provisions of Section IX, or·any other provision of the Decree, shall be construed as requiring the County to take actions inconsistent with public safety, except that the fact of a complaint of sexual harassment or retaliation shall not, in and of itself, be deemed by the County to constitute a threat to public safety or the safety of employees ofthe PGFD. X. TERMS CONCERNING PORNOGRAPHY IN FIRE STATIONS 41. The County will use all reasonable and lawful available means to ensure that there will be no displays or presentation of pornographic material, including videos, ~elevision, computergenerated displays and pictures, in those areas of all fire stations where employees would, in the normal course oftheir employment or tours of duty, spend time. Those areas ofthe fire stations include, but are not necessarily limited to, dayroom and kitchen areas.
XI. PUBLICITY 42. Within thirty (30) days ofthe entry ofthis Decree by the Court, the County shall modify the internet website of the Fire Department to include information and links regarding Revised General Order 1-6. The Fire Department home page shall include an item titled "Employment
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Discrimination Claims," and shall be linked to the web sites of state, local and federal agencies authorized to receive complaints of sexual harassment and retaliation under Title VII. 43. The information required to be posted on the Fire Department's"internet website shall remain posted throughout the duration of this Decree. XI. COMPLIANCE MONITORING 44. For a period of two (2) years from the effective date of this Decree, the United States may request, at its discretion, an annual report containing a description of any sexual harassment and retaliation complaints received from employees or members within the Fire Department, and copies of attendance sheets and any course materials used in connection with the annual training. 45. The County shall retain during the term ofthis Decree all documents, in paper or electronic form, (including electronic mail), that come into its possession relating to complaints of sexual harassment or retaliation from an employee or former employee in the Fire Department made against the County, the Fire Department or any employee or member in the Fire Department and documents relating to the training sessions provided for under this Decree. 46. -The United States may review compliance with this Decree at any time. The County shall provide copies of documents relevant to the County's compliance with this Decree upon the request ofthe United States, including but not limited to the documents described in paragraph 45, supra, and the United States shall pay the reasonable costs of making such copies. lfthe United States believes that this Decree or any portion of it has been violated, it will raise its concerns with the County pursuant to the dispute resolution procedure set forth in paragraph 47, infra.
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XII. DISPUTE RESOLUTION 47. The parties shall attempt to resolve informally any dispute that arises under this Decree. If the parties are unable to resolve the dispute expeditiously, either party may move the Court for a resolution of the issue, provided that written notice has been provided to the other party. XIII. MODIFICATION OF THE DECREE 48. With respect to the various time frames for completion of activities set forth in this Decree, those time frames may be modified upon mutual written consent of the parties. The parties may jointly agree to other modifications ofthis Decree with the approval of the Court. XIV. JURISDICTION OF THE COURT 49. The Court shall maintain jurisdiction over this case throughout the duration of this Decree for purposes of resolving disputes between the parties with respect to the terms or implementation of the Decree. 50. Failure by the United States to enforce this entire Decree or any provision thereof shall not be construed as a waiver of its right to do so with regard to other provisions of this Decree. XV. TERMINATION DATE 51. The termination date of the Decree is two (2) years after the effective date of the Decree, or the date on which the County provides any report requested by the United States pursuant to paragraph 44, supra, whichever is later. The termination date of the Decree may be extended for good cause shown. XVI. GENERAL PROVISIONS 52. The parties shall bear their own costs, expenses and attorney's fees in this action, including the costs of compliance or monitoring, except that the parties shall retain the right to
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seek costs for any matter which, in the future, may arise from this Decree and require resolution by this Court. 53. All documents required to be delivered under this Decree to the United States shall be sent to the following address:
Chief, Employment Litigation Section, United States Department of Justice, Civil Rights Division 950 Pennsylvania Avenue N.W. Employment Litigation Section, PHB Room 4040 Washington, D.C. 20530 '
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For Prince George's County:
/s/ By: County Attorney Prince George's County, Maryland (signed copy of document bearing signature of County Attorney is being ..maintained in office of Anat Ehrlich)
/s/ By: Chief Administrative Officer Prince George's County, Maryland (signed copy of document bearing signature of ChiefAdministrative Officer is being maintained in office of Anat Ehrlich)
/s/ Chief, Prince George's County FirelEMS Department (signed copy ofdocument bearing signature of Chief of the FirelEMS Department is being maintained in office of Anat Ehrlich)

For the United States Department of Justice:
R. ALEXANDER ACOSTA Assistant Attorney General Civil Rights Division
By: WILLIAM B. FENTON JODI B. DANIS ANAT EHRLICH Attorneys Employment Litigation Section Civil Rights Division U.S. Department ofJustice

Dated: _ __

Dated: _ _ __

IT IS SO ORDERED

Dated: ()tdl~ U>D3

~~C4t~
DEBORAH CHASANOW
United States District Judge

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APPENDIX A

VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED

Sharon Flory 403 East Oregon Road Lititz, PA 17543

Re: United States of America v. Prince George's County, Maryland Civil Action No. DKC-02-3563 CD. Md.)

Dear Ms. Flory:

The United States and Prince George's County, Maryland (" the County") have entered

into a Consent Decree settling the case of United States v. Prince George's County, Md, CV No.

DKC-02-3563 (D. Md.). A copy of the Consent Decree, which was approved and entered by the

Court on

, is enclosed.

Pursuant to the Consent Decree, the County is offering to:

1. pay you a monetary amount of $90,000, inclusive of attorney's fees, in compensation of

your claims of discrimination. You should be aware that all or a portion of the monetary

amount may be subject to federal, state andlor local income tax, for which you would be

responsible;

.

2. provide you with a retirement badge and certificate;

3. provide you with neutral employment references that confrrrn the length of your employment with the County, the positions that you held, your salary history, and the fact that you received overall ratings of "exceeds satisfactory" and "outstanding" on your performance evaluations; and

4. . remove from your personnel files any and all documents relating to the Letter of Unsatisfactory Conduct and the notice of operational suspension issued to you in 1998, as well as any and all documents that refer to any internal complaints of sexual harassment or retaliation made by you during your employment with the County, EEOC charge number 120-98-1146, as amended, the United States' investigation ofyour allegations of discrimination and this lawsuit.

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In order to accept the County's offer, you must execute the enclosed Release and return it, within thirty (30) days of your receipt ofthis letter, to the County's counsel at:

Robert Mellin, Esq. Associate County Counsel Prince George's County Office of Law County Administration Building, Room 5121 Upper Marlboro, MD 20772

The County will pay the entire monetary amount offered to you within fifteen (15) days

of its receipt of your executed release.

'

If you decline the relief offered by the County, the County will nevertheless have satisfied its obligation to the United States pursuant to the Consent Decree, and the United States will not seek additional relief on your behalf.

Ifyou have any questions concerning the Consent Decree or the University's offer to you, you may contact one of the following attorneys at the U.s. Department ofJustice:

Jodi B. Danis Anat Ehrlich Senior Trial Attorneys Employment Litigation Section Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C. 20530 (202) 307-5768

Sincerely,

Enclosures

Robert Mellin, Esq.

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APPENDIXB

RELEASE OF ALL CLAIMS

For and in consideration of the acceptance of all or any part of the relief offered to me by

Prince George's County, Maryland (the "County"), pursuant to the provisions of the Consent

Decree entered by the Honorable

, United States District Judge, on

in

United States v. Prince George's County, Md, CV No. DKC-02-3563 (D. Md.), I, Sharon Flory,

forever release and discharge the County, and all current, former and future agents, employees,

officials, designees, predecessors and successors in interest from all legal and equitable claims,

arising out of the Complaint filed in the above-captioned civil action and EEOC charge number

120-98-1146, as amended, accrued prior to the date of this release. I further agree that I will not

institute a civil action or seek to intervene against the County in any pending civil action alleging

employment discrimination on the basis of EEOC charge number 120-98-1146, as amended, or

any other EEOC charges filed against the County before the date ofthis release, or the

Complaint in CV No. DKC-02-3563 (D. Md.), or any ofthe facts alleged in EEOC charge

number 120-98-1146 or any other EEOC charge, as amended, or Complaint filed before the date

of this release against the County and/or any of its agents, employees, officials, designees, and

predecessors and successors in interest.

I understand that the relief to be given to me, including the payment to me of any

monetary amount" does not constitute an admission by the County of the validity of any claim

raised by me or on my behalf.

'

This release constitutes the entire agreement between the County and myself, without exception or exclusion.

I acknowledge that a copy of the Consent Decree in this action has been made available to me for my review.

I HAVE READ THIS RELEASE AND UNDERSTAND THE CONTENTS THEREOF,
AND I EXECUTE THIS RELEASE OF MY OWN FREE ACT AND DEED.

Signed this _ _ _ day of _ _ _ _"_ _.

SHARON FLORY

Social Security No. _ _ _ _ __

Subscribed and sworn to before me this

______ dayof

, __

Notary Public

My Commission expires:,_ _ _ __

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APPENDIXC
.INSERT FOR REVISED GENERAL ORDER NO. 1-6 AND EQUAL EMPLOYMENT OPPORTUNITY VOLUNTEER SERVICES DIRECTIVE
The following policies and procedures shall apply to complaints of sexual harassment and/or retaliation ofPGFD employees by either other employees or members. These policies and procedures shall apply to complaints of harassment or retaliation between members only to the extent that the harassment is alleged to create or contribute to a hostile environment based on sex or retaliation for employees. To the extent that a complaint of harassment or retaliation between members is not alleged to create or contribute to a hostile environment based on sex or retaliation for an employee, other policies regarding inappropriate conduct by members nevertheless may apply.
I. Definitions
1. "Sexual harassment" includes, but is not limited to: unwelcome sexual advances, requests for sexual favors, verbal, physical or other conduct of a sexual nature, or acts of animosity or hostility based on sex (whether or not sexual in nature), any of which creates or tends to create a hostile work environment based on sex for an employee ofthe County's Fire Department. "Sexual harassment" also includes, but is not limited to, such conduct directed at a member in the County's Fire Department to the extent that it contributes to or creates a hostile work environment based on sex for an employee of the County's Fire Department.
2. "Retaliation" includes, but is not limited to: taking any adverse employment action (including disciplining an employee, operationally suspending an employee, transferring an employee involuntarily from shift work to day work, or decreasing the amount of overtime work available to an employee) because the employee has opposed any practice he or she reasonably believes violates Title VII, or has made a fonnal or informal complaint or charge, testified, assisted, or participated in any manner in a formal or infonnal investigation, proceeding or hearing relating to a practice alleged to violate Title VII.
3. As used herein, the terms "less serious" or "minor" incident (or allegation thereof) of sexual harassment or retaliation include, but are not limited to:
a) an isolated joke, comment or remark, whether verbal, written, drawn or disseminated electronically, that is of a sexual nature or is offensive or disparaging on the basis of gender;
b) an isolated incident involving a display of sexually explicit materials; and c) an isolated negative or derogatory comment based on an individual's past
complaint of sexual harassment or discrimination.
The County shall have discretion to determine whether an incident (or allegation thereof) is less
serious or minor based on a reasonable complainant standard and the parameters established by relevant case law.

4. As used herein, the terms "more serious" or "major" incident (or allegation thereof) of sexual harassment or retaliation include, but are not limited to:
a) repeated jokes, comments or remarks, whether verbal, written, drawn, or disseminated electronically, that are of a sexual nature or are offensive or disparaging on the basis of gender;
b) repeated displays of sexually explicit materials; c) unwelcome physical conduct of a sexual nature, including physical assaults or
threats of physical assaults; d) requests for sexual favors and other verbal or physical conduct of a sexual nature
when a) submission to such conduct is made explicitly or implicitly a term or condition of an individual's employment or (b) submission to or rejection of such conduct by an individual is used as the basis for an employment decision affecting the individual; e) repeated incidents of negative or derogatory comment based on an individual's past complaint of sexual harassment or discrimination; and f) any denial of a tangible job benefit, or any act or omission with respect to the complainant that puts or could put the safety of the complainant or others at risk, based on his or her past complaints of sexual harassment or discriminatiori.
The County shall have discretion to determine whether an incident (or allegation thereof) is more serious or major based on a reasonable complainant standard and the parameters established by relevant case law.
II. Procedures Pendinll the Outcome of a Complaint Investillation
An employee who makes an informal or formal complaint of either sexual harassment or retaliation will not be transferred to another fire station because of that complaint unless the employee voluntarily requests a transfer. The County will first explain to the complainant the steps that it is willing and able to take pursuant to parts A and B below. If the complainant nevertheless insists upon a transfer to another station as a means of resolving the complaint, the County shall transfer the complainant to the same type of work, i.e., shift work or day work, that the complainant has at the time of the complaint, at the closest station practicable under the circumstances, unless no such assignment is available.
A. Complaints ofAlleged Harassment or Retaliation byA Career Employee
If the complaint of an employee relates to alleged physical contact, or involves conduct of a serious nature (including retaliatory harassment), and the alleged harasser is an employee, the complainant and the alleged harasser shall be separated through their assignment to different shifts within the same fire station pending the resolution of the complaint. The complainant may only be transferred to the same type of work or shift, i.e., day work or shift work, that he or she had at the time ofthe complaint. To the maximum extent possible, the alleged harasser also should be maintained in the same type of work that he or she had at the time of the complaint. If,
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after an investigation is conducted, an employee is determined to have engaged in sexual harassment or retaliation, in addition to any other appropriate disciplinary measures imposed, that employee will be maintained on a separate shift or transferred if it is determined that permanent separation of the employee and victim is necessary.
B. Complaints ofAlleged Harassment or Retaliation by a Volunteer Member
If the complainant is an employee but the person alleged to have engaged in sexual harassment or retaliation is a member, the following steps shall apply to members accused of sexual harassment and/or retaliation in the Fire Department during the investigation of a complaint:
1. If the complaint against a member concerns physical contact or harassment of a serious nature (including retaliatory harassment), the County shall limit the member accused of harassment to providing volunteer services only during hours other than the scheduled working hours or shift of the complainant pending the investigation and resolution ofthe complaint. The alleged harasser shall not be
permitted to be present at the fire station during the scheduled working hours or
shift of the complainant unless the complaint has been investigated and resolved against the complainant. .
2. While an investigation of a complaint described in subparagraph (1) is pending against a member, if that member can demonstrate to the County that the fire station to which he or she belongs as a member is his or her sole residence, and that exclusion from the station during the scheduled working hours or shift of the complainant thus would present and undue hardship, the County temporarily may effectuate a separation of the member and the complainant until the resolution of the complaint by changing the shift, working hours or station assignment ofthe complainant, as long as the change does not result in any loss of payor overtime work opportunities for the complainant.
3. If a member whose service and presence at the fire station is limited pursuant to subparagraph (1) refuses to absent himselfi'herselffrom the station during the complainant's scheduled shift or hours, or if it is determined that the member was present at the station during the scheduled hours ofthe complainant, the Fire Chief shall request in writing that the Volunteer Chief of that station immediately enforce the ban of the alleged harasser from'the premises during the complainant's scheduled hours.
4. If, following a request to the Volunteer Fire Chief under subparagraph (3), the member nevertheless remains present at the station during the scheduled shift of the complainant, the Fire Chiefshall operationally suspend both the alleged harasser and the Volunteer Chief for a thirty-day period.
5. If the alleged harasser violates the terms ofhislher operational suspension, or if
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the alleged harasser is found to be present at the station during the thirty-day period of occupational suspension, the County shall impose a permanent operational suspension on himlher and will suspend dispersal of any discretionary funds allocated by the County to the volunteer fire company of which the alleged harasser is a member for a six-month period. If the Volunteer Chief violates the terms of an operational suspension imposed under subparagraph (4), that Volunteer Chief shall remain on operational suspension for an additional six (6) months, and the County shall suspend dispersal of any discretionary funds allocated by the County to the volunteer fire company of which the Volunteer Chief is a member for a six-month period.
If, after all of the previous steps outlined in paragraphs 1-5, supra, have been undertaken, the member nevertheless remains present at the station during the scheduled shift of the complainant, the County must consider the removal of all career employees from the station as a first option.
If removal of all career employees from the station cannot be achieved due to a goodfaith determination that such removal would create a substantial risk to public safety, then the County will offer the complainant the option of either remaining in the station at issue or, if helshe does not prefer this option, the County shall offer himlher a minimum ofthree (3) alternative choices of stations to which helshe may transfer. Each ofthe alternative transfers offered to the complainant shall be to the same type of work, i.e., shift work or day work, that the complainant has at the time of the complaint, and shall be to the closest station practicable under the circumstances.
Without superseding any provisions herein regarding transfers of complainants and/or members, the County generally reserves the right to engage in transfers of Fire Department personnel required by demonstrated operational needs. However, a complaint of sexual harassment and/or retaliation shall not constitute, de facto, an operational need that would justify transfer of a complainant.
ID. Disciplinary Action Upon the Determination of a Violation
Where the County has determined that a member has engaged in sexual harassment or retaliation after having conducted an investigation, the County shall take the following steps:
1) imposition of appropriate disciplinary measures (including operational suspension ofthe member), of the type and duration commensurate with the disciplinary actions that would be imposed on an employee under similar circumstances;
2) if the member does not comply with the operational suspension or other disciplinary measures, the County shall follow the steps delineated in paragraphs II. B(1-5) supra; and
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3) if permanent separation ofthe complainant and the member is deemed necessary by the County or is requested by the complainant, the County also shall provide the options delineated in part II. B, to the complainant
If there are more than three (3) violations of Revised General Order 1-6 or the Equal Employment Opportunity Volunteer Services Director by one or more members of the same volunteer company or station during a one-year period, the County shall operationally suspend the Volunteer Chief(s) of that volunteer company from his or her position as Volunteer Chief for at least a one-year period and shall suspend the dispersal of discretionary funds to that volunteer company or station for a six-month period.
As part ofthe disciplinary measures imposed by the County on employees who are determined to have engaged in violations of Revised General Order 1-6, the Equal Employment Opportunity Volunteer Services Directive, or other applicable sexual harassment and retaliation policies or procedures, after such a determination of a violation is made, those employees shall not be eligible for promotion to a higher rank for a six-month period if a minor violation has occurred and a one-year period if a more serious violation has occurred, and shall not be eligible to receive any type of performance award for the one-year period (including annual leave awards or incentive awards described in Career Services Directives Number 2 and 21).
Without superseding any provisions in parts II. A or B herein regarding transfers of complainants and/or members, the County generally reserves the right to engage in transfers of Fire Department personnel required by demonstrated operational needs. However, a complaint of sexual harassment andlor retaliation shall not constitute, de facto, an operational need that would justify transfer of a complainant. ,
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 U.S. District Court District of Maryland (Greenbelt) CIVIL DOCKET FOR CASE #: 8:02-cv-03563-DKC

USA v. Prince George's Assigned to: Judge Deborah K. Chasanow Demand: $0 Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 10/30/2002 Date Terminated: 10/23/2003 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff United States

represented by Anat Ehrlich US Department of Justice 601 D St NW Washington, DC 20530 12025142000 Fax: 12025141005 Email: anat.ehrlich@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jennifer Lilore Huesman 10 S Woodland Dr Fair Haven, NJ 07704 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jodi Beth Danis United States Department of Justice 950 Pennsylvania Ave NW Room 4024 Washington, DC 20530 12025143831 Fax: 12025141005 Email: jodi.danis@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Thomas M DiBiagio Beveridge and Diamond PC 1350 I St NW Washington, DC 20005 12027896000 Fax: 12027896190

Email: tdibiagio@bdlaw.com

V. Defendant Prince George's County, Maryland

represented by Robert James Mellin, II Office of Law for Prince Georges County 14741 Governor Oden Bowie Dr Ste 5121 Upper Marlboro, MD 20772 13019525225 Fax: 13019523071 Email: rjmellin@co.pg.md.us LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 10/30/2002 10/30/2002 10/30/2002
11/21/2002 01/13/2003 01/16/2003 01/23/2003 02/05/2003 02/05/2003

#

Docket Text

1 COMPLAINT filed; (raf, Deputy Clerk) (Entered: 11/01/2002)

1 DEMAND for jury trial by USA (raf, Deputy Clerk) (Entered: 11/01/2002)

2 NOTICE OF LAWSUIT AND REQUEST FOR WAIVER of service of SUMMONS as to Prince George's (ljs, Deputy Clerk) (Entered: 11/04/2002)

3 NOTICE of attorney appearance for United States by Jodi B Danis (c/s) (rank, Deputy Clerk) (Entered: 11/25/2002)

4 ANSWER to Complaint by Prince George's (Attorney Robert James Mellin II), (c/s) (rank, Deputy Clerk) (Entered: 01/14/2003)

5 SCHEDULING ORDER ( signed by Judge Deborah K. Chasanow ) dated 1/15/03 (c/i 1/16/03) (rank, Deputy Clerk) (Entered: 01/16/2003)

**Renotice document [5-1] Scheduling order (mib, Deputy Clerk) (Entered: 01/23/2003)

6 MOTION by United States for Anat Ehrlich to Appear Pro Hac Vice (rank, Deputy Clerk) (Entered: 02/10/2003)

6 ORDER granting [6-1] motion for Anat Ehrlich to Appear Pro Hac Vice ( signed by the Clerk ) dated 2/5/03 (c/i 2/10/03) (rank, Deputy

06/24/2003 07/11/2003 07/11/2003
08/14/2003 09/11/2003 10/15/2003 10/22/2003 10/22/2003 10/22/2003 10/23/2003 10/23/2003
11/03/2003 04/07/2004

Clerk) (Entered: 02/10/2003)
7 Request for Status Report. Status Report due by 7/11/2003. (mlm, Chambers) (Entered: 06/24/2003)
8 STATUS REPORT by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 07/11/2003)
9 Paperless ORDER APPROVING 8 Status Report filed by United States, Prince George's County, Maryland, and ORDER STAYING CASE. Counsel are directed to submit status reports on the 15th day of each month. Signed by Judge Deborah K. Chasanow on 7/11/03. (Chasanow, Deborah) (Entered: 07/11/2003)
10 STATUS REPORT by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 08/14/2003)
11 STATUS REPORT by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 09/11/2003)
12 STATUS REPORT by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 10/15/2003)
13 SETTLEMENT AGREEMENT with Order Entering Agreement by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 10/22/2003)
14 STIPULATION for Retention of Court's Jurisdiction over Settlement Agreement by Prince George's County, Maryland, United States. (Ehrlich, Anat) (Entered: 10/22/2003)
15 Correspondence re: Recently Filed Settlement Agreement and Stipulation for Retention of Court's Jurisdiction over Settlement Agreement (Ehrlich, Anat) (Entered: 10/22/2003)
16 CONSENT DECREE and ORDER. Signed by Judge Deborah K. Chasanow on 10/23/03. and Appendix A and B(ranks, Deputy Clerk) (Entered: 10/23/2003)
17 ORDER "ADMINISTRATIVELY CLOSING' this case, as therein set forth and "DIRECTING" counsel to submit a status report no later than 11/1/05. Signed by Judge Deborah K. Chasanow on 10/23/03. (rank, Deputy Clerk) Modified on 10/24/2003 (lad3, Deputy Clerk). (Entered: 10/23/2003)
18 STATUS REPORT by United States. (Ehrlich, Anat) (Entered: 11/03/2003)
19 Joint MOTION for Extension of Time To Complete Training by Prince George's County, Maryland, United States. Responses due by

04/07/2004 04/07/2004 10/21/2005 10/24/2005

4/26/2004 (Ehrlich, Anat) (Entered: 04/07/2004)
20 MOTION for Extension of Time (Proposed Order Granting Motion for Extension of Time to Complete Training by Prince George's County, Maryland, United States. Responses due by 4/26/2004 (Ehrlich, Anat) (Entered: 04/07/2004)
21 PAPERLESS ORDER granting 19 Motion for Extension of Time, granting 20 Motion for Extension of Time (Order). Signed by Judge Deborah K. Chasanow on 4/7/04. (Chasanow, Deborah) (Entered: 04/07/2004)
22 Joint MOTION for Extension of Time of Consent Decree by Prince George's County, Maryland, United States. Responses due by 11/7/2005 (Attachments: # 1 Consent Decree# 2Proposed Order (Danis, Jodi) (rank, Deputy Clerk). (Entered: 10/21/2005)
23 PAPERLESS ORDER "GRANTING" 22 Joint Motion for Extension of Consent Decree. Consent Decree expiration extended to January 23, 2006. Signed by Judge Deborah K. Chasanow on 10/24/05. (Chasanow, Deborah) (Entered: 10/24/2005)