Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005Page 1 of 6

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIALUTHER ATLANTA DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COM]VIISSION,

Plaintiff,
HOME IMPROVEMENT FINANCIAL SERVICES, INC.,

CIVIL ACTION NO.
1: 05- C It-1 731

JURY TRIAL

DEMANDED -’L~~

~

Defendant.

COMPLAINT This is an action under Title VII of the Civil Rights Act of I964 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of race and retaliation, and to provide appropriate relief to the Charging Party, Mr. Rod Freeman, and other similarly situated black employees, including but not limited to Ms. Lisa Gober, Mr. Motrandy Taylor, and Mr. Don Hunter, who were adversely affected by such practices. As alleged with greater particularity below, the Commission alleges that Mr. Freeman, a black male, and other similarly situated black employees, were on a regular basis racially harassed by the owner of Home Improvement Financial Services, Inc., and after

Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005 Page 2 of 6
complaining directly to Defendant’s owner about the harassment, Mr. Freeman was retaliated against by being discharged by Defendant.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337, 1343 and 1345. This action ~s authorized and instituted pursuant to Section 706(0(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5(f)(1) and (3) ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C § 1981a. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Northern District of Georgia, Atlanta Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(0(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Home Improvement Financial Services, Inc. (the "Employer"), has continuously been a Georgia corporation

Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005 Page 3 of 6
doing business in the State of Georgia and the City of Stone Mountain, and has continuously had at least 15 employees.
5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Mr. Freeman filed a charge with the Commission alleging violations of Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since October 2002, Defendant Employer has engaged in unlawful employment practices at its Stone Mountain, Georgia facilities (among other cities), in violation of Section 703(a)(1) of Title VII, 42 U.S.C. § 2000e-2(a)(1), by racially harassing Mr. Freeman, and other similarly situated black employees, and by discharging Mr. Freeman in retaliation for opposing practices made unlawful by Section 704 (a) of Title VII, 42 U.S.C. § 2000e-3(a). 13. The effects of the practices complained of above has been to deprive Mr Freeman and other similarly situated black employees of equal employment opportunities and otherwise adversely affect their status as employees, because of
3

Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005 Page 4 of 6
their race, and because Mr. Freeman engaged in protected activity. 14. The unlawful employment practices complained of above were
intentional 15 The unlawful employment practices complained of above were done
with malice or with reckless indifference to the federally protected rights of Mr. Freeman and the other members of the protected class.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in racial harassment and retaliation and any other employment practice which discriminates on the basis of race or on the basis of activity protected by Title VII. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for black employees, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Mr. Freeman, and the other similarly situated black employees by providing appropriate backpay with

Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005 Page 5 of 6
prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to reinstatement and/or front pay of Mr. Freeman.
D. Order Defendant Employer to make whole Mr. Freeman by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described above, including job search expenses, in amounts to be determined at trial.
E. Order Defendant Employer to make whole Mr. Freeman, and other similarly situated black employees, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of above, including emotional pain and suffering, inconvenience, loss of enjoyment of life, anxiety, stress, depression and humiliation, in amounts to be determined at trial.
I. Order Defendant Employer to pay Mr. Freeman, and other similarly situated black employees, punitive damages for its malicious and reckless conduct described in paragraphs above, in amounts to be determined at trial.
J. Grant such further relief as the Court deems necessary and proper in the public interest.
K. Award the Commission its costs of this action.

Case 1:05-cv-01731-GET-JFK Document 1 Filed 06/30/2005 Page 6 of 6
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint.
ERIC DREIBAND General Counsel GWENDOLY-N YOUNG REAMS Associate General Counsel
Regional Attorney Ga. Bar Number 617505 A. VICTORIA JOHNSON Trial Attomey Ga. Bar Number 392210 U S. Equal Employment Opportunity Commission - Atlanta District Office 100 Alabama St., SW, Suite 4R30 Atlanta, Georgia 30303 Telephone: (404) 562-6820 (general) Telephone: (404) 562-6812 (direct) Facsimile: (404) 562-6905
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 Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

EQUAL EMPLOYMENT

:

OPPORTUNITY COMMISSION,

:

:

Plaintiff,

:

:

v.

:

:

HOME IMPROVEMENT FINANCIAL :

SERVICES, INC.,

:

:

Defendant.

:

:

CIVIL ACTION NO. 1:05-CV-1731-GET
JURY TRIAL DEMANDED

AMENDED COMPLAINT

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

of the Civil Rights Act of 1991 to correct unlawful employment practices on the

basis of race and retaliation, and to provide appropriate relief to the Charging

Party, Mr. Rod Freeman, and other similarly situated black employees, who were

adversely affected by such practices. As alleged with greater particularity below,

the Commission alleges that Mr. Freeman, a black male, and other similarly

situated black employees, were on a regular basis racially harassed by the owner of

Home Improvement Financial Services, Inc., and after complaining directly to

Defendant’s owner about the harassment, Mr. Freeman was retaliated against by

being discharged by Defendant.

1

Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 2 of 6
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 toSection 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5(f)(1) and (3) ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a . 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Northern District of Georgia, Atlanta Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Home Improvement Financial Services, Inc. (the "Employer"), has continuously been a Georgia corporation doing business in the State of Georgia and the City of Stone Mountain, and has continuously had at least 15 employees.
2

Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 3 of 6
5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Mr. Freeman filed a charge with the Commission alleging violations of Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since October 2002, Defendant Employer has engaged in unlawful employment practices at its Stone Mountain, Georgia facilities (among other cities), in violation of Section 703(a)(1) of Title VII, 42 U.S.C. § 2000e-2(a)(1), by racially harassing Mr. Freeman, and other similarly situated black employees, and by discharging Mr. Freeman in retaliation for opposing practices made unlawful by Section 704 (a) of Title VII, 42 U.S.C. § 2000e-3(a). 8. The effects of the practices complained of above has been to deprive Mr. Freeman and other similarly situated black employees of equal employment opportunities and otherwise adversely affect their status as employees, because of their race, and because Mr. Freeman engaged in protected activity.
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Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 4 of 6
9. The unlawful employment practices complained of above were intentional.
10. The unlawful employment practices complained of above were done with malice or with reckless indifference to the federally protected rights of Mr. Freeman and the other members of the protected class.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in racial harassment and retaliation and any other employment practice which discriminates on the basis of race or on the basis of activity protected by Title VII. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for black employees, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Mr. Freeman, and the other similarly situated black employees by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative
4

Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 5 of 6
relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to reinstatement and/or front pay of Mr. Freeman.
D. Order Defendant Employer to make whole Mr. Freeman by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described above, including job search expenses, in amounts to be determined at trial.
E. Order Defendant Employer to make whole Mr. Freeman, and other similarly situated black employees, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of above, including emotional pain and suffering, inconvenience, loss of enjoyment of life, anxiety, stress, depression and humiliation, in amounts to be determined at trial.
F. Order Defendant Employer to pay Mr. Freeman, and other similarly situated black employees, punitive damages for its malicious and reckless conduct described in paragraphs above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
H. Award the Commission its costs of this action.
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Case 1:05-cv-01731-GET-JFK Document 3 Filed 08/11/2005 Page 6 of 6
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint.
ERIC DREIBAND General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
____/S/________________ A.VICTORIA JOHNSON Trial Attorney Ga. Bar Number 392210
S. ROBERT ROYAL Regional Attorney Ga. Bar Number 617505 U. S. Equal Employment Opportunity Commission - Atlanta District Office 100 Alabama St., SW, Suite 4R30 Atlanta, Georgia 30303 Telephone: (404) 562-6820 (general) Telephone: (404) 562-6812 (direct) Facsimile: (404) 562-6905
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 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

HOME IMPROVEMENT

)

FINANCIAL SERVICES, INC.,

)

)

Defendant.

)

CIVIL ACTION FILE NO. 1:05-CV-1731-JFK

CONSENT DECREE This action was instituted on June 30, 2005, by the Equal Em ployment Opportunity Commission (hereinafter the “Com mission” or “EEOC”) against Home Improvement Financial Services, Inc., (hereinafter the “Defendant” or “Company”) pursuant to Title VII of the Civil Rights Act of 1991. On August 11, 2005, the EEOC filed an Am ended Complaint. In both its original Com plaint and the Amended Complaint, the EEOC a lleged that Defenda nt harassed black employees because of their race, and discharged the Charging Party, Rod Freem an (hereinafter “Mr. Freeman”), because he complained about the racial harassm ent. In both its original complaint and the Amended Complaint, the EEOC sought make whole relief including, but not limited to, back pay, damages, prejudgment interest, as well as injunctive and other affirmative relief.

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On August 29, 2005, Defendant filed its Answer to the EEOC’s Am ended Complaint denying that it had engaged in any illegal conduct in any m anner against its black em ployees or had discha rged Mr. Freeman in retaliation for his alleged complaints of racial harassment. It further denied that it owed any damages or other relief to the EEOC, Rod Freeman, or any other individuals.
The EEOC and Defendant desire to avoid the additional expenses, delay, and uncertainty which would result from the continuance of this litigation and further desire to form ulate a plan to be em bodied in an agreem ent which is hereinafter referred to as the “Consent Decree”.
Now, therefore, the parties to this action agree as follows: I. JURISDICTION AND VENUE
Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337, 1343 and 1345. This actio n is authorized pursuant to Section 706(f)(1) and (3) (“Title VII”) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C . § 1981a. The employment practices alleged to be unlawful in the original Com plaint and the Am ended Complaint filed herein occurred within the jurisdiction of the Northern District of Georgia.
II. DISCLAIMER OF VIOLATION This Consent Decree, being entered with the consent of the Commission and Defendant, shall not constitute an adjudication or finding on the merits of this case
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and shall not be construed as an admission of liability by Defendant or as a waiver by the Commission of any contentions of discrimination.
III. TITLE VII OBLIGATIONS Defendant and its subsidiaries, offi cers, agents, servants, employees, successors in interest an d all persons acting or claiming to act on their behalf and interest will continue their po licy and practice of not engaging in em ployment practices that are in violation of T itle VII, including racial harassm ent and retaliatory discharge.
IV. NON-RETALIATION PROVISION Defendant shall not ret aliate against any person because that person is a beneficiary of the Consent Decree, or has provided inform ation, assistance, or participated in any other manner in any i nvestigation or proceeding relating to this lawsuit, the underlying charge of discrimination, or the Consent Decree.
V. REFERENCES Defendant agrees that if it receives inquiries from persons or prospective employers seeking a reference or other employment related information regarding Mr. Freeman, it shall provide no m ore than a neutral reference, citing the dates of his employment and the position(s) that he held with Defendant. Further, Defendant will m ake no m ention to persons or prospective em ployers seeking a reference of the fact that Mr. Freeman f iled a charge of discrim ination, that the
3

instant lawsuit was filed, or that Mr. Freeman participated in the charge process, or was a claimant in the instant lawsuit.
VI. DISCIPLINARY POLICY ON RACIAL HARASSMENT AND RETALIATION
Defendant agrees to continue to m aintain a racial harassm ent policy and procedure applicable to all employees, particularly those who perform in a managerial, supervisory or lead capacity, and to require all em ployees, including management and lead employees to sign a stipulation acknowledging that each has read and understands the racial harassment policy and procedure.
Defendant agrees to continue to issue a document to all employees , including management officials, that clarifies how com plaints regarding racial harassment should be m ade to Defendant, including the identity and/or job title of the official(s) to whose attention the com plaint should be brought in the supervisory chain of com mand. Employees shall continue to be advised that such complaints will be prom ptly investigated and effectively resolved by Defendant. Defendant further agrees to advise em ployees that they will not be retaliated against for complaining about racial harassment. [See EEOC Compliance Manual, Section 615, Para 3116, (“EEOC Enforcement Guidance: V icarious Employer Liability for Unlawful Harassment by Supervisors”) for guidance in this regard.]
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Defendant agrees to continue its disciplinary policy with penalties up to and including discharge for e mployees who are found t o have engaged in racial harassment or retaliation in violation of Defendant’s policy. Defendant further agrees that employees who commit acts of racial harassment shall be admonished in writing and disciplined in accordance with the policy.
The above referenced racial hara ssment policy and procedure shall be revised and re-institut ed within ninety (90) days of the entry of this Consent Decree. On or before that date, Defenda nt shall certify the im plementation of said revised policy and procedure to EEOC’s Regional Attorney in the EEOC Atlanta District Office whose address is 100 Alabama Street, Suite 4R30, Atlanta, Georgia 30303.
VII. CHARGING PARTY’S INDIVIDUAL RELIEF The Defendant, in settlement of all cl aims brought in this lawsuit, shall provide Mr. Freeman a total of $5,000.00 (“Five Thousand dollars and zero cents”) within two weeks of the entry of this Consent Decree by th e Court. This payment by Defendant to Mr. Freeman is m ade to avoid the additional expenses, delay, and uncertainty which would result from the continuation of this li tigation. A copy of the above-referenced check will be m ailed within five working days of issuance to
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the EEOC’s Attorney, S. Robert Royal, in the Atlanta District Office, whose address is 100 Alabama Street, Suite 4R30, Atlanta Georgia 30303.
VIII. COMPLIANCE OFFICIAL The Defendant has desi gnated John R. Crenshaw, Esq., 300 Galleria Parkway, N.W., Suite 1000, Atlanta, Georgia 30339 as the Defendant’s Compliance Official who shall be assisti ng the Defendant in com plying with the Consent Decree. The Com pliance Official is to be responsible for coordinating and overseeing the Defendant’s compliance w ith the specific terms of the Consent Decree.
IX. PROCEDURE FOR ENFORCING COMPLIANCE The Commission will attempt to re solve any dispute regarding the enforcement of this Consent Decree by consultation with Defendant before seeking enforcement through the judicial process. The Com mission will notify, by first class mail and facsi mile, [Defendant’s Compliance Official or other designee; mailing address] if it has any reason to be lieve that any action or omission by the Defendant is in violation of the Consent Decree. The Defendant shall h ave thirty (30) days after the receipt of such notification to cure any such alleged de ficiency, and to notify the Com mission, by
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written report addressed to the Regional A ttorney of the EEOC’s Atlanta District Office, of the m easures taken to cure the alleged deficiencies. If upon receipt of the Defendant’s report, the Commission concludes that the deficiency has not been satisfactorily cured by the Defendant, th e Commission shall seek to resolve the alleged deficiency through good faith negotia tions. If the alleged deficiency is not resolved within thirty (30) days after the initiation of further good faith negotiations, including a conference with th e Magistrate Judge if necessary, then the Commission may seek enforcement of this Consent Decree through the judicial process.
Notwithstanding any of the foregoing, nothing in this agreem ent shall be deemed to prohibit any m atter which occurred during the term of this Consent Decree, and which constitutes a dispute as contemplated by this Section VIII, from being fully and completely processed in the manner described in this Section VIII, even though the dispute is not resolved within thirty (30) days of the termination of this Consent Decree.
X. TERMS OF DECREE - PERIOD OF JURISDICTION This Consent Decree shall continue to be effective and binding upon the parties to this action for a period o f twelve (12) calendar m onths immediately
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following the entry of the Consent Decree, provided that all rem edial benefits required hereby have been received o r offered prior to its expiration and certification are subm itted at least thirty (30) d ays prior to the expiration date of the Consent Decree. If the remedial benef its are not received or offered as agreed in the Consent Decree, the Consent D ecree will be autom atically extended un til these provisions are completed.
Upon the Court’s execution a nd entry of this Consent Decree, this case shall be dismissed w ith prejudice. However, this Court shall retain jurisdiction over this action for the p urposes of clarifying and enforcing this Consent Decree, and for any other appropria te or equitable purposes, for twelve (12) calendar months from the date of entry of this C onsent Decree, unless the Court acts, or the Commission has, prior to the expiration of said twelve (12) month period, moved to enforce compliance with the Consent Decree. If this Court acts, or the Commission has m oved to enforce com pliance with this Consent Decree within this period, this Court shall retain jurisd iction of this action until all issues relating to all such motions which are made during the twelve (12) month period have been resolved.
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XI. OTHER ACTIONS The Commission shall not commence or prosecute against the Defendant any action or other proceeding based upon claims, demands, causes of action, obligations, damages or liabilities which aro se out of Charging Party’s claim that he, and other sim ilarly situated black employees, were racially harassed by Defendant, or that he was discharged for engaging in protected activity in violation of Title VII, as embodied in EEOC Charge Number 110-2004-32739, which was filed with, and investigated by, the EEOC’s Atlanta District Office. This Con sent Decree in no way affects the Commission’s right to process any pending or future charges that m ay be filed against th e Defendant in accordance with standard Commission procedures, and to com mence civil actions pursuant to pursuant to Section 706(f)(1) and (3) (“Title VII” ) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. Nothing herein shall preclude the Commission from bringing an action to enforce the provisions of this Consent Decree.
XII. COSTS AND ATTORNEYS’ FEES Each party shall bear its own costs and attorneys’ fees for this act ion. The parties hereto and the undersigned attorneys of record for the parties hereby
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consent to the entry of the foregoing Consent Decree.
BY CONSENT:
For Plaintiff: /s/ Gerald Kiel Gerald Kiel Georgia Bar No. 417300 Acting Regional Attorney S. Robert Royal Georgia Bar No. 61750 Attorney for Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION ATLANTA DISTRICT OFFICE - LEGAL UNIT 100 Alabama Street, SW Suite 4R30 Atlanta, Georgia 30303 (404) 562-6818 For Defendant: /s/ John R. Crenshaw John R. Crenshaw, Esq. 300 Galleria Parkway, N.W. Suite 1000 Atlanta, Georgia 30339-5917
APPROVED, DONE, and SIGNED this 31st day of March, 2006.
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 CM/ECF LIVE v3 - U.S. District Court - Docket Report

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4months, CLOSED, TitleVII
U.S. District Court Northern District of Georgia (Atlanta) CIVIL DOCKET FOR CASE #: 1:05-cv-01731-JFK

U.S. Equal Employment Opportunity Commission v. Home Improvement Financial Services, Inc. Assigned to: Judge Janet F. King Cause: 42:2000 Job Discrimination (Race)

Date Filed: 06/30/2005 Date Terminated: 03/31/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
U.S. Equal Employment Opportunity Commission

represented by Amy Victoria Johnson Equal Employment Opportunity Commission-ATL Atlanta District Office-Legal Unit 100 Alabama Street, S.W. 4R30 Atlanta Federal Center Atlanta, GA 30303-8704 404-562-6818 Email: vicki.johnson@eeoc.gov TERMINATED: 09/22/2005 LEAD ATTORNEY

S. Robert Royal Equal Employment Opportunity Commission Atlanta District Office-Legal Unit 100 Alabama Street, S.W. 4R30 Atlanta Federal Center Atlanta, GA 30303-8704 404-562-6820 Email: stan.royal@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Defendant Home Improvement Financial Services, Inc.

represented by John R. Crenshaw Wasson Sours & Harris 300 Galleria Parkway, N.W. Suite 1000 Atlanta, GA 30339-5917 770-956-1700 Email: jcrenshaw@wshpc.net LEAD ATTORNEY

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ATTORNEY TO BE NOTICED

Date Filed 06/30/2005 08/01/2005 08/11/2005
08/11/2005 08/11/2005 08/12/2005 08/12/2005 08/29/2005
08/30/2005 09/22/2005 09/22/2005 10/12/2005 10/12/2005 10/14/2005

#

Docket Text

1 COMPLAINT filed. Consent form to proceed before U.S. Magistrate and pretrial instructions given to attorney , filed by U.S. Equal Employment Opportunity Commission. (Entered: 07/01/2005)
2 NOTICE of Attorney's Lien filed by Thompson, Rollins, Schwartz and Borowski (Kosten, Lawrence) Modified on 8/5/2005 to correct text to accurately reflect e-filed pleading. (epm). (Entered: 08/01/2005)
3 AMENDED COMPLAINT against Home Improvement Financial Services, Inc., filed by U.S. Equal Employment Opportunity Commission.(Johnson, Amy) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 08/11/2005)
4 MOTION to Amend Complaint with Brief In Support by U.S. Equal Employment Opportunity Commission. (Attachments: # 1)(Johnson, Amy) (Entered: 08/11/2005)
5 CERTIFICATE OF SERVICE filed by U.S. Equal Employment Opportunity Commission (Johnson, Amy) (Entered: 08/11/2005)
Submission of 4 MOTION to Amend Complaint, submitted to Magistrate Judge Janet F. King. (jlm) (Entered: 08/12/2005)
6 ORDER DENYING AS MOOT pla's 4 Motion to File an Amended Complaint. Signed by Judge Janet F. King on 8/12/05. (jlm) (Entered: 08/12/2005)
7 ANSWER to Amended Complaint by Home Improvement Financial Services, Inc.. Discovery ends on 1/26/2006.(Crenshaw, John) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 08/29/2005)
8 Guidelines for Discovery and Motion Practice Signed by Judge Janet F. King on 8/30/05. (lwc) (Entered: 08/30/2005)
9 NOTICE by U.S. Equal Employment Opportunity Commission of Withdrawal of Counsel by Plaintiff (Duckett, Lakisha) (Entered: 09/22/2005)
10 CERTIFICATE OF SERVICE filed by U.S. Equal Employment Opportunity Commission of Notice of Withdrawal of Counsel for Plaintiff (Duckett, Lakisha) (Entered: 09/22/2005)
11 CERTIFICATE OF SERVICE for discovery by Home Improvement Financial Services, Inc.. (Attachments: # 1 # 2)(Crenshaw, John) (Entered: 10/12/2005)
12 ORDER DIRECTING dft to file a Certificate of Interested Persons and both parties to file a Joint Preliminary Statement within 30 days of the date of this order. Signed by Judge Janet F. King on 10/12/05. (jlm) (Entered: 10/13/2005)
13 Initial Disclosures by U.S. Equal Employment Opportunity Commission.(Royal, S.) (Entered: 10/14/2005)

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10/18/2005 10/19/2005
10/27/2005 11/02/2005 11/02/2005 12/14/2005 01/05/2006 01/05/2006 01/23/2006 01/24/2006
02/07/2006 02/08/2006
02/21/2006 03/09/2006 03/09/2006

14 Joint PRELIMINARY REPORT AND DISCOVERY SCHEDULE filed by U.S. Equal Employment Opportunity Commission. (Royal, S.) (Entered: 10/18/2005)
15 SCHEDULING ORDER: Discovery ends on 1/26/2006. Summary Judgement Motion due by 2/15/2006. If no Summary Judgement Motion filed, then the Proposed Pretrial Order due by 2/27/2006. Signed by Judge Janet F. King on 10/19/05. (lwc) (Entered: 10/19/2005)
16 Initial Disclosures by Home Improvement Financial Services, Inc..(Crenshaw, John) (Entered: 10/27/2005)
17 Order GRANTING Consent to Jurisdiction by US Magistrate Judge. Case reassigned to Judge Janet F. King for all further proceedings. Signed by Judge G. Ernest Tidwell on 11/2/05. (jlm) (Entered: 11/02/2005)
18 CERTIFICATE OF SERVICE Response to Interrogatories from Plaintiff by Home Improvement Financial Services, Inc..(Crenshaw, John) (Entered: 11/02/2005)
19 CERTIFICATE OF SERVICE Of Plaintiff Equal Employment Opportunity Commission's First Request For Production Of Documents to Defendant by U.S. Equal Employment Opportunity Commission.(Royal, S.) (Entered: 12/14/2005)
20 NOTICE to Take Deposition of Don Hunter filed by Home Improvement Financial Services, Inc. (Crenshaw, John) (Entered: 01/05/2006)
21 NOTICE to Take Deposition of Lisa Gober filed by Home Improvement Financial Services, Inc. (Crenshaw, John) (Entered: 01/05/2006)
22 Consent MOTION for Extension of Time to Complete Discovery by U.S. Equal Employment Opportunity Commission. (Royal, S.) (Entered: 01/23/2006)
23 ORDER GRANTING 22 Motion for Extension of Time to Complete Discovery. Discovery ends on 3/13/2006. The deadline for filing any summary judgment motions shall be extended accordingly. Signed by Judge Janet F. King on 1/24/06. (epm) (Entered: 01/31/2006)
24 First MOTION to Stay Case Pending Mediation by Home Improvement Financial Services, Inc.. (Crenshaw, John) (Entered: 02/07/2006)
25 ORDER GRANTING 24 Motion to Stay Case Pending Mediation. The Court STAYS discovery in this case for 30 days. The parties are directed to advise the Court of the status of said mediation on or before March 9, 2006. Signed by Judge Janet F. King on 2/8/06. (epm) (Entered: 02/09/2006)
26 CERTIFICATE OF SERVICE for Responses to Request for Production by Home Improvement Financial Services, Inc..(Crenshaw, John) (Entered: 02/21/2006)
27 MOTION for Extension of Time to Stay Case by U.S. Equal Employment Opportunity Commission. (Royal, S.) (Entered: 03/09/2006)
28 ORDER GRANTING 27 Motion for Extension of Time, and STAYS discovery for an additional seven business days thru 3/20/2006. The parties are directed to inform the Court of the status of their efforts to finalize the settlement of this matter on or before 3/20/2006 . Signed by Judge Janet F. King on 3/9/2006. (adg) (Entered: 03/10/2006)

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CM/ECF LIVE v3 - U.S. District Court - Docket Report

https://ecf.gand.uscourts.gov/cgi-bin/DktRpt.pl?115424319299883-L_3...

03/21/2006 03/22/2006 03/30/2006 03/31/2006
03/31/2006 04/19/2006 04/20/2006

29 NOTICE of Settlement by U.S. Equal Employment Opportunity Commission (Royal, S.) (Entered: 03/21/2006)
Submission of 29 Notice of Settlement, submitted to Magistrate Judge Janet F. King. (adg) (Entered: 03/22/2006)
30 PROPOSED CONSENT ORDER Consent Decree. (Royal, S.) (Entered: 03/30/2006)
31 CONSENT DECREE- Defendant shall provide Rod Freeman settlement in the amount of $5,000.00 within two weeks of the entry of this Consent Decree by the Court. The racial harassment policy and procedure referenced in the Consent Decree shall be revised and re-instituted within 90 days of the entry of this Consent Decree. Upon the Court's execution and entry of this Consent Decree, this case shall be DISMISSED with prejudice. Each party shall bear its own costs and attorneys' fees. Signed by Judge Janet F. King on 3/31/2006. (see Consent Decree for further directives)(adg) (Entered: 03/31/2006)
Civil Case Terminated. (adg) (Entered: 03/31/2006)
32 Acknowledgment of Full Satisfaction of Attorney's Lien by Thompson, Rollins, Schwartz and Borowski. (Kosten, Lawrence) Modified on 4/20/2006 accurately reflect e-filed document (adg). (Entered: 04/19/2006)
Notification of Docket Correction re 32 Stipulation of Dismissal. Modified on 4/20/2006 to accuratly reflect e-filed document as an Acknowledgment of Full Satisfaction of Attorney's Lien. (adg) (Entered: 04/20/2006)

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