IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

J[ GE KOOORAS

U.S. EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION,

MAGISTRATE JUDGE GERALDINE sOAT BROWN

5999
COMPLAINT

CHRIST HOSPITAL AND MEDICAL CENTER, ) Defendants.

JURY TRIAL DEMAND ~.:~!

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NATURE OF ACTION This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 199l, to correct unlawful employment practices on the basis of race, and to provide appropriate relief to Leveme P. Robinson who was adversely affected by such practices. The Commission alleges that Leverne P. Robinson was subjected to disparate treatment because of her race, African-American, and subsequently constructively discharged. These charges are alleged with greater particularity in paragraphs 7a-c below.
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 pursuant to Sections 706(0(1) and (3) of Title VII, 42 U.S.C, § 2000e-5(f)(1) and (3), 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 Illinois, Eastern Division.

PARTIES 3. Plaintiff, the U.S. 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 Sections 706(0(1) and (3) of Title VII, 42 U.S.C. §2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Christ Hospital and Medical Center, a division of Advocate Health Care (the "Employer"), an Illinois corporation, has continuously been doing business in the State of Illinois and the City of Oak Lawn, 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, Leveme P. Robinson filed a charge with the Commission alleging violations of Title VII by Defendant Christ Hospital and Medical Center. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. On or about December 27, 1998 Defendant Employer engaged in unlawful employment practices in violation of Section 703(a), and of Title VII, 42 U.S.C. §§2000e-2(a). These practices include: (a) Discriminating against Leverne P. Robinson because of her race, black, by
subjecting her to different terms and conditions of employment than her non-black coworkers;

(b) subjecting Leverne P. Robinson to discipline that non-black employees were not subjected to, and;
(c) creating a work environment that would compel a reasonable employee to resign and thus constructively discharging her because of her race.
8. The effect of the practices complained of in paragraphs 7a-c above has been to deprive Leverne P. Robinson of equal employment opportunities and otherwise adversely affect her status as an employee, because of her race.
9. The unlawful employment practices complained of in paragraphs 7a-c above were intentional.
10. The unlawful employment practices complained of in paragraphs 7a-c above were done with malice or with reckless indifference to the federally protected rights of Leverne P. Robinson.
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 participationwith it, from engaging in any employment practice that discriminates on the basis of race. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for African-Americans, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Leverne P. Robinson, by providing appropriate backpay with prejudgment interest, in amounts to be determined at triaI, and other
3

affirmative relief necessary to eradicate the effects if its unlawful employment practices, including reinstate her to her former position.
D. Order Defendant Employer to make whole Leverne P. Robinson, by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 7a-c above, including but not limited to job search expenses and medical expenses not covered by the Employer’s employee benefit plan, in amounts to be determined at trial.
E. Order Defendant Employer to make whole by providing Leverne P. Robinson compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 7a-c above, including emotional pain, suffering, inconvenience, loss of enjoyment of life, and humiliation, in amounts to be determined at trial.
F. Order Defendant Employer to pay Leverne P. Robinson punitive damages for its malicious and reckless conduct described in paragraphs 7a-c above, in amounts to be determined at trial.
Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Commission its costs of this action.
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint.
4

Respectfully submitted
C. Gregory Stewart General Counsel GwendoIyn Young Reams Associate General Counsel EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 180I "~
on
Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
500 West Madison Street Suite 2800 Chicago, Illinois 60661 (312) 353-8558

Civ!l Covgr Sheet

http://www.ilnd.uscourts.gov/ vti binlsbtmt.dll/PUBLICIForms/cvcover.ht

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS
. Civil Cover Sh 00C 5999
"l~i~~d’~4~ conforms generally to the manual JS-44 approved by the Judicial Conference of ~e United States in September 1974. The data is required for the use of the Clerk of Court for ~e propose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and se~ice of pleadings or other papers as required by law. This form is authorized for use ~ in the Northern District of Illinois.

Plaintiff(s): U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
County of Residence:
Plaintiffs Arty: KEITH SPENCE U.S. EEOC - CHICAGO DISTRICT 500 W. MADISON, SUITE 2800 CHICAGO, IL 60661 312-353-8558

Defendant(s): CHRIST HOSPITAL & MEDICAL CENTER

County of Residence:

;2~~$T~#dant’s Arty:

MARY ELLEN CHERRY

ADVOCATE HEALTH

CARE

2025 WINDSOR DR.

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II. Basis of Jurisdiction:

1 U.S. Gov’t Plaintiff

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III. Citizenship of Principle Parties (Diversity Cases Only)
Plaintiff:- N/A Defendant:- N/A

IV. Origin’

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

Title VII of the Civil Rights Act of 1964 & Title I of the Civil Rights Act of 1991.

VII. Requested in Complaint

Class Action:

Dollar Demand:

Jury Demand:

VIII. This case Is NOT a refiling of a previously dismissed case. (If yes case number __ by Judge

Signature:~~~//~~~ Date:
If any of this information is incorrect, please go back to the Civi~ Cover Sheet Input form using the Back button in your browser and d~ange

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

In the Matter of

U.S. Equal Employment Opportunity Commission, Plaintiff,
,. O}jt "~g~ .....

Case Number:

Christ Hospital & Medical Center
Defendants.

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEY(S) FOR:

~U.S.,Equal Employment. Opportunity Commission, Plaintiff .......

(A)

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(B)

Keith L. St

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~,~M Equal Employment Oppo~unity Commission -~ ’ Equal Employment Opportunity Commission

STRE~TADDRESS 500 W. Madison St., Suite 2800

STREE’r a~,RESS 500 W. Madison St., Suite 2800

Chicago, IL 60661

C~TWSTAT’~,~ Chicago, IL 60661

TELE~,,ON,: NUM",".R (312) 886-9124

r~,.E~’,,OSE SU~UEr~ (312) 353-7582

(SEE,T~.~ ~ OS R~.VERSE~ ARDC NO.6257659

mE~T.~,CaT,O~ NUM~E~ (SEE ITeM ~ ON R~VERSE) ARDC NO. 01390635

MEMBER OE TRIAL BAR’/

YES

NO

X

MEMBER OF TR|AL BAR"

YES.

[~

NO []

TREAL ATTORNEY’,

YES

[~]

NO

[]

TRIAL ATTORNEY?

YES [’~ NO []

DESIGNATED AS LOC~..~/

YES []

NO

[]

OeSIGNA’rED AS LOCAL COUNSEl.’?

YES

[]

NO []

I! ,Y

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mploy~ent Oppo~unity Commission

ST~,.’r ADDRESS 500 W. Madison St., Suite 2800

ClTWSTATFJZl~ Chicago, IL 60661

’r~,.m,o~.UMU~ (312) 353-8551

I~EN’I’IF]CATIO~ NU~BER($EEITEM 4 OR REVERSE} A~DC NO,01 ig75~9

MEMBER OF TRIAL BAR? "TRIAL ATTORNEY? DESIGNATED AS LOCAL COUNSEL’.’

YES ~

YES

~

YES

~

NO

NO

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NO

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8[GNATURE NAME FIRM

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TELEPHONE NUMBER

[DENTIFICATIONNUM~ER{S£6ITEM4ONREVERSE)

MEMBER OF TRIAL BAR’~ TRIAL ATTORNEY’, DESIGNATED AS LOCAL COUNSEL’,

YES ~
YES ~ ~
YE~

NO ~
N~ ~ NOB ~

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 1 of 4

TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:00-cv-05999

US EEOC v. Christ Hosp & Med Assigned to: Hon. Geraldine Soat Brown Demand: $0 Cause: 42:1983 Civil Rights Act
Plaintiff United States Equal Employment Opportunity Commission

Date Filed: 09/29/2000 Date Terminated: 07/23/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Keith L. Spence Law Office of Keith L. Spence 10450 South Vincennes Chicago, IL 60643 (773)429-1374 Email: attyspence@intergate.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jean Powers Kamp United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7568 Email: jean.kamp@eeoc.gov ATTORNEY TO BE NOTICED
John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED

V. Defendant Christ Hospital & Medical Center

represented by Joan E. Gale Seyfarth Shaw LLP

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 2 of 4

Date Filed 09/29/2000 11/03/2000
11/28/2000 11/28/2000 11/28/2000 12/06/2000 12/06/2000

131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 346-8000 Email: jgale@seyfarth.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Angela Renee Mersch Wildman, Harrold, Allen & Dixon 225 West Wacker Drive Suite 3000 Chicago, IL 60606-1229 (312) 201-2000

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Jean Powers Kamp, Keith L. Spence as attorney(s) for plaintiff ( no summons(es) issued.) ( Documents: 1-1 through 1-3) (yap) (Entered: 10/02/2000)

SCHEDULE set on 11/3/00 by Hon. Charles P. Kocoras : Status hearing set to 9:30 12/6/00. At the initial hearing, parties to report on the following: 1. Possibility of settlement. 2. If no possibility of settlement exists, the nature and length of discovery necessary to prepare case for trial. Discovery plans need not be in writing unless ordered by the Court. Provisions of FRCivP 26 (a)(1) shall not apply unless expressly ordered by the Court. Plaintiff is directed to advise all other parties of the Court's action herein. Lead counsel for each party is required to attend the initial hearing. Mailed notice (sct) (Entered: 11/03/2000)

2 ATTORNEY APPEARANCE for defendant by Joan E. Gale, Angela Renee Mersch (fce) (Entered: 11/29/2000)

3 WAIVER of service of summons as to defendant sent on 9/29/00. (fce) (Entered: 11/29/2000)

5 UNOPPOSED MOTION by defendant for extension of time in which to file an answer or otherwise plead to complaint ; Notice. (cem) (Entered: 12/07/2000)

4 EXPEDITED REFERRAL ORDER: Case referred to Hon. Geraldine Soat Brown for settlement conference. Mailed notice. (sct) (Entered: 12/06/2000)

6 MINUTE ORDER of 12/6/00 by Hon. Charles P. Kocoras: Status hearing held. Defendant's unopposed motion for an extension of time answer or otherwise plead is granted to 01/08/01 [5-1]. Cause to be referred to Magistrate Judge Brown for a settlement conference. Mailed notice (cem) (Entered: 12/07/2000)

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 3 of 4

12/13/2000
01/04/2001 01/08/2001 03/07/2001
04/11/2001 05/10/2001 06/21/2001
07/19/2001 07/19/2001 07/19/2001 07/19/2001
07/23/2001

7 MINUTE ORDER of 12/13/00 by Hon. Geraldine Soat Brown : The referral of this matter having been assigned to Magistrate Judge Geraldine Soat Brown, an initial status hearing is hereby set before Magistrate Judge Brown on 01/04/01 at 9:30 a.m. in courtroom 1812 . Mailed notice (mw) (Entered: 12/15/2000)
8 MINUTE ORDER of 1/4/01 by Hon. Geraldine Soat Brown : Status hearing held. Settlement conference set for 1:30 p.m. on 3/7/01. The parties are to comply with Judge Brown's standing order for settlement conference. Mailed notices by judge's staff. (las) (Entered: 01/08/2001)
9 ANSWER by defendant and affirmative defenses to plaintiff's complaint [1-1]; Notice. (mw) (Entered: 01/09/2001)
10 MINUTE ORDER of 3/7/01 by Hon. Geraldine Soat Brown : Settlement conference held. Counsel for the respective parties are to exchange certain information identified at the settlement conference prior to the next status date before Judge Brown. Status hearing set before Judge Brown on 4/11/01 at 9:30 a.m. to discuss continuation of settlement conference. Notices mailed by judge's staff (rmm) (Entered: 03/09/2001)
11 MINUTE ORDER of 4/11/01 by Hon. Geraldine Soat Brown: Status hearing held and continued to 5/10/01 at 9:30 a.m. Ms. Moore-Gibbs is to advise the plaintiff's attorney about the next status hearing date. Notices mailed by judge's staff (vmj) (Entered: 04/16/2001)
12 MINUTE ORDER of 5/10/01 by Hon. Geraldine Soat Brown: Status hearing held. Settlement conference set for 6/21/01 at 1:30 p.m. Notices mailed by judge's staff (vmj) (Entered: 05/15/2001)
13 MINUTE ORDER of 6/21/01 by Hon. Geraldine Soat Brown : Continued settlement conference held. Parties reach agreement in principle subject to the finalized terms in the necessary documents. Status hearing set for 7/19/01 at 9:30 am . Mailed notices by judge's staff (cem) (Entered: 06/25/2001)
14 MINUTE ORDER of 7/19/01 by Hon. Geraldine Soat Brown : Status hearing held. Parties report case has settled (Entered consent decree.) Mailed notice by judge's staff. (yp) (Entered: 07/23/2001)
15 CONSENT by plaintiff to exercise of jurisdiction by a United States Magistrate Judge. (yp) (Entered: 07/23/2001)
16 CONSENT by defendant to exercise of jurisdiction by a United States Magistrate Judge. (yp) (Entered: 07/23/2001)
17 REASSIGNMENT ORDER of 7/19/01 Case reassigned to Honorable Geraldine Soat Brown from Honorable Charles P. Kocoras purusant to Local Rule 73.1 , Terminating the case referral to Hon. Geraldine Soat Brown (For further detail see order.) Mailed notice. (yp) (Entered: 07/23/2001)
18 MINUTE ORDER of 7/23/01 by Hon. Geraldine Soat Brown : Parties having reached a settlement and the court having entered a consent

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CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket Report

Page 4 of 4

decree, the court hereby dismisses this case with prejudice with the court retaining jurisdiction to enforce the consent decree. terminating case Mailed notice by judge's staff. (yp) (Entered: 07/24/2001)

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 :::Minut", Order Form (06f97)

United States District Court, Northern District of Illinois

Name of Assigned Judge or Magistrate Judge
CASE NUMBER

Charles P. Kocoras 00 C 5999

Sitting Judge if Other than Assigned Judge
DATE

Geraldine Soat Brown
7/19/2001

CASE TITLE
MOTION:

EEOC vs. Christ Hospital and Medical Center

..

..

[In the followmgbox (a) mdlcatethe party filmgthe motion, e.g., plamtlff,defendant, 3rd party plamtlff, and (b) state briefly the nature

of the motion being presented.]

DOCKET ENTRY:

(I) o

Filed motion of [ use listing in "Motion" box above.]

(2) o

Brief in support of motion due ___.

(3) o

Answer brief to motion due___. Reply to answer brief due___.

(4) o

Ruling/Hearing on ___ set for ___ at ___.

(5) o

Status hearing[held/continued to] [set for/re-set for] on ___ set for ___ at ___.

(6) o

Pretrial conference[held/continued to] [set for/re-set for] on ___ set for ___ at ___.

(7) o

Trial[set for/re-set for] on _ _ _ at ___.

(8) o

[Bench/Jury trial] [Hearing] held/continued to ___ at ___.

(9) o
• (10)

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 General Rule 21 0 FRCP41 (a)(1) 0 FRCP41(a)(2).
[Other docket entry] Status hearing held. Parties report case has settled. Enter Consent Decree.
~

11) o

[For further detail see order (on reverse side of/attached to) the original minute order.]

No notices required, advised in open court.

No notices required.
.I Notices mailed by judge's staff.

Notified counsel by telephone.

Docketing to mail notices.

Mail AO 450 form.

Copy to judge/magistrate judge.

T1HG

courtroom

kf

deputy's

initials

01 JUL 20 Pi'\ 2: 38

mailing deputy initials

.'

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

DOCKETED

EQUAL EMPLOYMENT OPPORTUNITY )

JUL .2 :1 2001

COMMISSION

)

Plaintiff,
v.
CHRIST HOSPITAL AND MEDICAL CENTER Defendant.

)

No. 00 C 5999

)

)

)

Judge Kocoras

)

Magistrate Judge Soat Brown

)

)

)

CONSENT DECREE The Litigation

Plaintiff, Equal Employment Opportunity Commission (hereafter the "EEOC"), filed this

action on September 29,2000, alleging that Defendant Christ Hospital and Medical Center (now

known as Advocate Christ Hospital and Medical Center, hereinafter referred to as "Christ

Hospital") discriminated against Charging Party Leveme Robinson, in violation of Title VII of

the Civil Rights Act of1964, as amended, 42 U.s.C. § 2000e et seq. ("Title VII") and § 102 of

the Civil Rights Act of 1991,42 U.S.C. § 1981A, by subjecting Robinson to adverse terms and

conditions of employment on the basis of her race which caused her constructive discharge.

Christ Hospital has denied the allegations ofthe Complaint. As a result of the parties having

engaged in settlement discussions, the parties have agreed that this action should be finally

resolved by entry of this Consent Decree. This Consent Decree is not an admission of liability on

the part of Christ Hospital. This Consent Decree is intended to and does fully and finally resolve

any and all claims arising out ofthe Complaint.

l~

Findings Having examined the terms and provisions of this Consent Decree and based on the pleadings, records, and stipulations of the parties, this Court finds the following: A. This Court has jurisdiction over the subject matter ofthis action and over the parties. B. The terms and provisions of this Consent Decree are fair, adequate, reasonable, equitable and just. The rights of the parties are adequately protected by this Consent Decree. C. This Consent Decree conforms with the Federal Rules of Civil Procedure and Title VII. The entry of this Consent Decree will further the objectives of Title VII and will be in the best interest of the parties and the public. D. NOW THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:
Non-Discrimination I. In all matters arising from or relating to employment, Christ Hospital, its officers
,
agents, employees, successors, and assigns shall not discriminate on the basis ofrace. Non-Retaliation
2. Christ Hospital, its officers, agents, employees, successors, and assigns shall not retaliate against, penalize or otherwise prejudice any employee, former employee or applicant for employment because such person has opposed any practice made unlawful by Title VII; filed a Complaint or Charge; testified, assisted, or otherwise participated in any manner in any investigation, proceeding, hearing or litigation under Title VII; asserted any right under this Consent Decree; or otherwise exercised his or her rights under Title VII.
-2-

Monetary Relief 3. Christ Hospital shall pay to Leverne Robinson monetary damages in the sum of $40,350.00, of which $5,000.00 represents back pay and $35,350.00 represents compensatory damages and Ms. Robinson's attorneys fees. Payment will be made as follows: After the Consent Decree has been entered and within ten (10) business days after Christ Hospital receives a Release form executed by Leverne Robinson, approved by her own private attorney, Christ Hospital shall send by certified mail, three checks to G. Clinton Gaston & Associates, Leverne Robinson's attorney, located at 39 South LaSalle, Suite 1100, Chicago, Illinois 60603. One check shall be for back pay in the amount of $5,000.00 less the employee's share of all legally required taxes and other withholdings. Christ Hospital shall be responsible for payment of employer taxes, which includes and is limited to appropriate deductions for state and federal taxes and FICA. The second check shall be in the sum of$22, 016.67 representing compensatory damages. The third check shall be for attorneys fees in the sum of$13,333.33 and shall be payable to G. Clinton Gaston & Associates. Christ Hospital shall send a copy of the checks to the EEOC.
Notice Posting 4. Within ten (10) days after the Court's entry of this Consent Decree and for the duration of this Decree, Christ Hospital shall continuously post the notice annexed hereto as Exhibit A at the following prominent locations frequented by Christ Hospital employees: in the Human Resources Department and outside the employee cafeteria. Within ten (10) days after the Consent Decree is entered Christ Hospital shall certifY in writing to the Chicago District Office
-3-

of the EEOC that the Notice has been posted, and shall infonn the EEOC of the locations where it has been posted.
Record Keeping and Reporting 5. Christ Hospital shall maintain all records concerning its implementation of this Consent Decree. Christ Hospital shall maintain records of any complaints it receives ofrace discrimination, its investigation of such complaints, and any response or action taken in the event there is a finding of race discrimination. 6. Beginning six (6) months after entry of this Consent Decree and every six (6) months thereafter for the duration of the Consent Decree, Christ Hospital shall furnish EEOC with reports reflecting infonnation detailed in the records described in Paragraph 5 of this Consent Decree. Christ Hospital's last report will be submitted to EEOC two (2) weeks prior to the date on which the Decree is to expire. 7. For the tenn of the Consent Decree and upon five (5) business days notice to Christ Hospital, if EEOC has reasonable grounds to believe that Christ Hospital is not in compliance with the tenns of this Consent Decree, EEOC shall have access to Christ Hospital's facilities to review and copy any relevant non-privileged documents located at its facility and to interview any personnel employed by Christ Hospital for the purpose of detennining Christ Hospital's compliance with the tenns of this Consent Decree. Christ Hospital shall provide a privilege log to EEOC for any relevant documents withheld from EEOC pursuant to an assertion by Christ Hospital that the documents contain privileged infonnation. In the event EEOC deems it necessary to review any of the documents designated as privileged by Christ Hospital, the EEOC shall so seek an Order from the Court.
-4-

Training 8. Within forty-five (45) days after entry of this Consent Decree, Christ Hospital shall arrange for additional training of managers, coordinators, and superVisors of Christ Hospital regarding requirements of Title VII. Christ Hospital shall submit to EEOC for approval, materials regarding the training session, including the credentials ofthe trainer, prior to such training. Within five (5) days after the completion of the training described above, Christ Hospital will certify to EEOC that the training has been completed, the name(s) of the person(s) conducting the training, the time(s), duration and date(s) the training was held and a list identifying by name and position all individuals who received the training.
Duration of DecreelRetention of Jurisdiction 9. The terms of this Consent Decree shall be in effect (and the Court will retain jurisdiction of this matter to enforce this Decree) for a period of two (2) years from the date on which this Consent Decree is entered. The duration of this Consent Decree may be extended by the Court if the Court, acting on a motion filed by EEOC prior to the expiration of the 2-year period finds, after opportunity for a full hearing, that extension ofthe Consent Decree is warranted.
Costs and Attorneys' Fees 10. Each party to this action shall bear its own attorney's fees, costs, and expenses.
Dispute Resolution 11. If EEOC has reasonable cause to believe that Christ Hospital has violated any of the terms ofthis Consent Decree, EEOC shall notify Christ Hospital in writing and Christ Hospital will then have ten (l0) business days in which to satisfy EEOC that there has not been a violation or that the violation has been corrected. If at the expiration of such time period, EEOC
-5-

has not been so satisfied, then EEOC may immediately apply to the Court for appropriate relief. 12. When this Consent Decree requires the submission by Christ Hospital or reports,
notices, or other materials to the Commission, such materials shall be mailed to: Christ Hospital Settlement, Equal Employment Opportunity Commission, Chicago District Office, Legal Division, 500 West Madison, Suite 2800, Chicago, Illinois 60661.

ENTERED AND APPROVED FOR:
Equal Employment Opportunity Commission .
GWENDOLYN YOUNG REAMS Associate General Counsel

Advocate Christ Hospital and Medical Center
~~~ anE:Gaie
SEYFARTH SHAW 55 East Monroe Street Suite 4200 Chicago, Illinois 60603 (312) 346-8000

Trial Attorney
Equal Employment Opportunity Commission Chicago District Office 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 (312) 886-9120
-6-

ENTER::~~~~~~~~~~_ __
Honorable G raldine Soat Brown United States District Magistrate Judge
-7-

,< '
NOTICE TO ALL ADVOCATE CHRIST HOSPITAL EMPLOYEES
This Notice is posted pursuant to the settlement of a lawsuit filed by the United States Equal Employment Opportunity Commission (EEOC) against Advocate Christ Hospital and Medical Center (Christ Hospital), in the United Sates District Court for the Northern District of Illinois No. 00 C 5999. In the suit, the EEOC alleged that Christ Hospital discriminated against a former employee based on her race. Christ Hospital has denied all allegations.
The parties to the lawsuit have agreed to resolve it by entering into a Consent Decree. Christ Hospital does not admit any liability by entering into the Consent Decree. Under the terms of the Consent Decree, Christ Hospital has agreed that it will:
I. Not engage in any employment practice which discriminates on the basis of race;
2. Pay appropriate compensation to the individual who filed the charge of discrimination;
3. Provide additional training to managers, coordinators and supervisors concerning laws prohibiting employment discrimination;
4 Provide certain reports and information to EEOC for a period of two years.
Title VII of the Civil Rights Act of 1964, as amended, prohibits employers from discriminating on the basis of sex, race, color, religion or national origin. The Equal Employment Opportunity Commission is the agency responsible for enforcing Title VII. If you have any complaints of discrimination or questions concerning your rights under Title VII, you may contact the EEOC at the address and phone number given below.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED OR REMOVED
This Notice must remain posted for two years from the date shown below and must not be altered, defaced or covered by any other material. Any complaints ofdiscrimination or questions concerning this Notice or compliance with its provisions may be directed to the Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661, (312) 353-2713.

lohnRowe Director of the Chicago District Office of the Equal Employment Opportunity Commission
Dated:_ _ _ _ __

Paul Macuga Vice President, Human Resources Advocate Christ Hospital
Dated:_ _ _ _ _ __