1:-1 THE UNITED STATES DISTRICT COURT FOR TilE DISTRICT OF COLUMBIA

JANE DOE, c/o O'Donoghuc & O'Donoghuc 4748 Wisconsin Avenue, N.W. Washington, D.C. 20016
P!aintin~
UNITED STATES OF AMERICA, Plainti fe-Intervenor,

Civil Action No. 02-2338 (RMU)

v.

DISTRICT OF COLUMBIA, c[ aI., Defendants.
------------ - - - - -
COi\lPLAIYf IN INTERVENTION

Plaintiff-lntcrvcnor, United States of America ("United States"), alleges:

I.

This action is brought on behalf or tile United States to enforce the provisions ofTitJe VII

of the Civil Rights Act of 1964, as amended, 42 U.S.c. § 2000e, ct seq. ("Title VII").

2. This Court has jurisdiction over this action under 42 USc. § 2000e-5(t) and

28 USc. § 1345.

3. Defendant District of Columbia is a governmental entity within the United States.

4. Defendant District of Columbia is a person within the meaning of Section 701(a) ofTitlc

VII, 42 USc. § 2000e(a), and an employer within the meaning of Section 701(b) ofTitlc VII,

42 U.S.c. § 2000c(b).

5, Defendant District or Columbia has discriminated against Jane Doe, and other females

simil<lrly sitll<lied, \\-iLh respeCL Lo hiring inLo and employment in emergcllcy medical Lechnician ("EMT") positions with the District of Columbia Fire and Emergency Medical Services Department ("FEr.'ISD") because ofiheir sex in violation of Section 703(a) of Title VII, 42 U.S.C § 20DOe-2(a), and Section 701 ofTitlc VII, 42 U.S.c. § 2000e(k), by, among other ways:
a. subjecting her and other female applicants for EMT positions in the District's FEMSD to a pre-hiring pregnancy test;
b. conditioning an offer of employment to her and other female applicants for EMT positions in the District's FEMSD upon a negative result orlhe pregnancy test;
c. subjecting her and other female EMTs in the District's FEMSD to discrimination based on their sex during their employment, which adversely affected the terms, conditions and privileges of their employment and included advising them (explicitly and implicitly) through a management official or officials oflhe defendant District that, if during their probationary periods they were or bccame pregnant, they were at risk of losing their jobs; and
d. failing or refusing to take appropriate action to remedy the effects of the discrimination.
6. As a result of defendant District of Columbia's discrimination as alleged in Paragraph 5, supra, Jane Doc and other females similarly situated who becamc pregnant during thcir probationary periods as EMTs felt compelled to, and did, tel1ninate thcir pregnancies by ;Jbortions in order nol to risk losing their jobs. 7. The Equal Employment Opportunity Commission ("EEOC") received a timely charge of discrimination filed by Jane Doc, in which she alleged, ill fer alia, that the District of Columbia
2

discriminated aeainsl her, nn the hasis of her sex, in vinlMinn nfTit1c VII

7. The United States Dcpiu1ment of Justice subsequently issued a notice of right- to-sue on

Jane Doc's charge. Having received such nolice afrighl-to-sue, plaintiff Jane Doc alleges, inter

alia, violations by defendant District ofCoJumbia of Section 703(a) of Title VII,

42 USc. § 2000e-2(a), and Section 701 ofTitic VII, 42 U.S.c. § 2000e(k), in her complaint.

8. The Assistant Attomey General for the Civil Rights Division of the United States

Department of .lusticc, by delegation from the Attorney General of the United States, has

certified under Section 706(1)(1) ofTitle VII, 42 USc. § 2000e-5(1)(1), that the above-

captioned case is of general public importance. See attachment hereto.

9. All conditions precedent to the filing of this complaint in intervention have been

performed or have occurred.

\VHEREFORE, plaintiff-intervenor United States prays that this Court:

a.

enter an order enjoining defendant District of Columbia from failing or refusing to

provide remedial rcliefsufficient to make whole Jane Doc, and other females

similarly situated, for the loss they have suffercd as a result of the discrimination

against thcm as alleged in this complaint in intervention; and

h. award compensatOlY damages to Jane Doc, and olher females similarly situated,

for mental and/or physical injuries incurred as a result of the discrimination

against them as alleged in this complaint in intervention, pursuant 10 and within

the statutory limitations ofSectiol1 102 oCthe Civil Rights Act of 1991,42 USc.

§ 19810.

The United States prays for such additional relicf as justice may require, together with its

3

costs and dishursements in this actioll_ JVRYOEMAND
The United States hereby demands a trial by jury of all issues so triable pursuant to Rule 38 ofthe Federal Rules of Civil Procedure and Section 102 of the Civil Rights Act of 1991, 42 V.S.c. § 1981 a.
R. ALEXANDER ACOSTA Assistant Attomcy General Civil Rights Division
. By: ~#?===DAViD~Z;::J JIN M·lf;il121To\~sKI Deputy Chief ANN L. LOUGHLIN Trial Attorney Employment Litigation Section Civil Rights Division U.S. Department of Justice Room 4024, PHB 950 Pennsylvania Ave., NW Washington, DC 20530 (202) 616-0474
4

 
 Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 1 of 7�

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JANE DOE I, JANE DOE II and JANE DOE III, c/o O'Donoghue & O'Donoghue 4748 Wisconsin Avenue, N.W. Washington, D.C. 20016
Plaintiffs,

UNITED STATES OF AMERICA,

,

Plaintiff-Intervenor,

v.

DISTRICT OF COLUMBIA, et al., Defendants.

Civil Action No. 02-2338 (RMU)

SETTLEMENT AGREEMENT This action was brought by Jane Doe I, Jane Doe II and Jane Doe III (the "Jane Does"), and by the United States against the District of Columbia (hereinafter referred to as "the District") to enforce the provisions of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e, et seq. ("Title VII"). In its complaint in intervention, the United States alleges that defendant District of Columbia (the "District"), through its Fire and Emergency Medical Services Department ("Fire Department"), has discriminated against the Jane Does and other similarly-situated women on the basis of their sex in violation of
Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a), among other ways, by:

Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 2 of 7�
(1) subjecting the Jane Does and other female applicants for Emergency Medical Technician ("EMT") positions in the Fire Department to a pre-employment pregnancy test; (2) conditioning offers of employment to the Jane Does and other female applicants for EMT positions in the Fire Department upon a negative result of the pregnancy test; (3) subjecting the Jane Does and other female EMTs in the Fire Department to employment discrimination based on their sex, which adversely affected the tel'ms, conditions, and privileges of their employment and included advising them (explicitly and implicitly) through a management official or officials of the District that, if during their probationary periods they were or became pregnant, they were at risk of losing their jobs; and (4) failing or refusing to take appropriate action to remedy the effects of the discrimination. As noted below, the District on April 21, 2005 filed a Notice of Offer of Judgment. The United States and the District, desiring that this action be settled by appropriate settlement agreement and without the burden of protracted litigation, agree to this Settlement Agreement, and to the jurisdiction of this Court over the parties and the subject matter of this action, as final and binding between themselves as to the issues raised in the complaint filed by the United States in this case and the matters resolved in this Settlement Agreement (" Agreement").
-2-

Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 3 of 7�
A. GENERAL PROVISIONS 1. The District, by and through its officials, agents, employees, and all persons in active
concert or participation with the District in the performance of employment or persOlmel functions, agree that federal law prohibits the District from engaging in any act or practice that unlawfully discriminates against any employee of, or applicant for employment with, the Fire Department because of that individual's pregnancy status.
2. The District agrees that federal law prohibits the District from retaliating against or in any respect adversely affecting any of the Jane Does or any other person because that person has opposed allegedly discriminatory policies or practices, has filed a charge with the United States Equal Employment Opportunity Commission ("EEOC"), or because of that person's participation in or cooperation with the initiation, investigation, litigation or administration of this case.
3. Any and all claims or counter-claims the District or its current or former employees have against any of the Jane Does shall be released.
4. The District has implemented and adopted nondiscriminatory employment policies that the Department of Justice's Office of Justice Programs approved in order to address the intervenors' allegations set forth in paragraphs number 1 and 2. The District agrees that its policy is to reasonably accommodate the pregnancies of female employees in the Fire Department.
5. The District shall provide training, as developed by the Fire Department, on the rights of pregnant employees and applicants pursuant to the Pregnancy Discrimination Act of 1978 and
.,
-.J-

Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 4 of 7�
Title VII of the Civil Rights Act of 1964 to all Fire and Emergency Medical Services personnel who are involved in the hiring, evaluation, and disciplining of employees in the Fire Department. A description of such training shall be submitted to the United States within one hundred and twenty (120) days from the date of entry of this Agreement for the United States' review, comment, and determination that such training is acceptable. Such training shall be completed within one (1) year from the date of entry of this Agreement. The District shall provide verification of the completion of this training to the United States within thirty (30) days of its completion. B. SPECIFIC RELIEF
In settlement of the complaints filed against it, the District stipulates and agrees to the following:
6. On April 21, 2005, pursuant to Rule 68 of the Federal Rules of Civil Procedure, the District filed with the United States District Court for the District of Columbia ("District Court") a Notice of Offer of Judgment in the amount of $1 01,000 plus reasonable attorneys fees for each of the Jane Does.
7. An express and material term of the Offer of Judgment was that "each defendant denies culpability andlor liability for or upon any and all claims asserted."
8. On May 6, 2005, each of the Jane Does filed with the District Court a separate notice that she accepted the District's Offer of Judgment.
9. Therefore, the District agrees to compensate each ofthe Jane Does as provided in the Offer of Judgment unless otherwise modified by agreement of plaintiffs and the District.
-4-

Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 5 of 7�
C. RECORD-KEEPING AND REPORTING 10. The District shall retain during the life of this Agreement all records reasonably
necessary to document the implementation of this Agreement. The District shall furnish records and documents demonstrating its compliance with the implementation of this Agreement to the United States within sixty (60) days of any written request to the District.
11. The District shall provide written notice to the United States of any disciplinary or other adverse employment action taken against any of the Jane Does during the life of this Agreement promptly after such action is tal<:en. The United States shall have the right to inspect and copy all documents related to such action upon reasonable notice to the District without fmiher order of the Court.
12. The District shall comply with the record-keeping requirements of Title VII as set forth in the regulation 29 C.F.R. § 1602.31. The Fire Department shall retain all records that come into its possession relating to complaints or charges of employment discrimination based on pregnancy filed against the District or its employees, agents or representatives with respect to the Fire Department: (a) through the Fire Department's internal grievance procedure; (b) with the EEOC; or (c) through or with any other federal, state or local agency authorized to receive such complaints. Begilming on October 1,2005, the District shall on a quarterly basis provide to the United States copies of such complaints or charges received during the preceding three (3) month period, thirty (30) days after the conclusion of such period. In addition, the United States shall have the right to inspect and copy all documents related to such complaints or charges upon reasonable notice to the District as is currently provided by federal law.
-5-

Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 6 of 7�
13. All docUments required to be provided by the District to the United States under this Agreement shall be sent to the following address: Chief, Employment Litigation Section, Civil Rights Division, U.S. Department of Justice, 950 Pennsylvania Avenue, N.W., Patrick Henry Building, Room 4500, Washington, DC 20530.
14. This Agreement shall remain in effect for a period of three years from the date of its entry, and this Agreement shall be dissolved and this action shall be dismissed at the end of such three-year period without any further order of the Court.
15. DOJ and the District shall bear their own costs and expenses, including attorney's fees.
16. The parties shall attempt to resolve informally any dispute that may occur under this Agreement. If the parties are unable expeditiously to resolve an issue, either party may move the Court for enforcement of the settlement agreement once the palty contending that a violation has occurred has first provided thirty (30) days written notice and an opportunity to cure any violation. Subject to the terms above, only the parties to this agreement may take action to enforce compliance with the terms of this Agreement. Subject to the terms above, the appropriate action to resolve such disputes shall be a motion to compel compliance. The Court shall resolve any disputes that may arise between the parties under it and enter such orders as may be appropriate to enforce the terms of this Agreement.
DONE AND ORDERED this __ day of _ _ _ _, 2005.
RICARDO M. URBINA UNITED STATES DISTRICT JUDGE
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Case 1:02-cv-02338-RMU Document 61 Filed 08/31/2005 Page 7 of 7�

Agreed and Consented To:
On behalf of Plaintiff-Intervenor, United States of America:
BRADLEY 1. SCHLOZMAN Acting Assistant Attorney General Civil Rights Division

On behalf of Defendant District of Columbia:
ROBERT 1. SPAGNOLETTI, Attorney General for the District of Columbia

Chief Employment Litigation Section
~;~
Member, Maryland Bar (no bar number) KRISTOFOR 1. HAMMOND Member, Virginia Bar, No. 44133 Attorneys Civil Rights Division U.S. Department of Justice 950 Pennsylvania Ave. N.W. Room 4906 PHB Washington, DC 20530 (202) 353-3011

~6.C4/~)
GEOR E C. VALENTINE Deputy Attorney General Civil Litigation Division
~~(~ IK BERLYJ . JO~ Chief General Litigation Section I
k~~ WENDEL V. HALL
Assistant Attorney General
Office of the Attorney General, D.C.
441 4th Street, N.W., Room 6S086
Washington, D.C. 20001
(202) 724-6608

-7-

 
 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Jane Doe I, II and III

Pl

aintiff,

vs.

District of Columbia,

Ronnie Few,

Samanthia Robinson,

Defendants

Case No.: 1:02-02338 (RMU)
Answer and Counterclaim (Jane Doe III)

DEFENDANT ROBINSON’S CONSOLIDATED DEFENSES, ANSWER AND COUNTERCLAIM
Comes now Defendant Samanthia Robinson, by and through the undersigned as counsel, and files her answer to Plaintiffs’ Complaint. Defendant asserts as to the following defenses that she believes is supported currently by facts or, based on facts otherwise within her possession, will be supported upon further investigation and an opportunity for discovery.
First Defense-Lack of Personal Jurisdiction- Fed.R.Civ.Pro 12(b)(1).
The court lacks Personal Jurisdiction over Defendant Robinson as a result of Plaintiff’s failure to properly serve Defendant Robinson, pursuant to Rule 4 of the Federal Rules of Civil Procedure.
Second Defense- Injury by Fellow Servant The injuries allegedly sustained, as set forth in the complaint were proximately, directly and solely caused by Defendants District of Columbia and Few. In no manner were any of said injuries caused by or contributed to by Defendant Robinson’s conduct.

Third Defense Immunity From Suit
Defendant Robinson is entitled to qualified and/or absolute immunity from suit. Fourth Defense
Each Plaintiff gave informed consent to having a surgical abortion and “physical harm, pain and severe emotional distress” was a known risk of this surgical procedure.
Fifth Defense Each Plaintiff assumed the risk of “physical harm, pain and severe emotional distress” by choosing to have a surgical abortion.
Sixth Defense Each Plaintiff failed to exhaust her administrative remedies.
Seventh Defense Plaintiffs fail to state a claim upon which relief can be granted.
Eighth Defense By failing to advise each Plaintiff properly as to her rights or as to the actual policy and customs of the District of Columbia as established by the final policymaker, Plaintiffs’ representatives, legal or otherwise, and/or other people are the proximate cause of any alleged emotional distress, physical harm and pain arising in connection with each Plaintiff’s surgical abortion.
Ninth Defense Defendant acted at all times consistently with all applicable laws, rules, regulations, constitutional provisions and standards of care. Defendant Robinson is not liable for the actions of employees of the District of Columbia based upon any legal theory.
Tenth Defense All of Plaintiffs’ claims may be barred in whole, or in part, by laches and other defenses to equitable or declaratory relief.

Eleventh Defense This Court lacks subject-matter jurisdiction over Plaintiffs’ claims for non-monetary relief to the extent that the Court has not already entered judgment in favor of defendants on these claims.
Twelfth Defense Defendant Robinson asserts the defenses or res judicata, claim preclusions and issue preclusion over Plaintiffs’ claims.
Answer 1. Contains no allegations which may be admitted or denied but which plaintiffs must
prove. To the extent there is any allegation in this paragraph as to Defendant Robinson, it is denied. 2. Contains no allegations which may be admitted or denied. 3. Denied, (see affirmative defenses numbers 1 & 2.) Defendant denies, to the extent a denial is required, that any of the complained of acts as to her conduct actually occurred. 4. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph as to any plaintiff as they are making fictitious name filing and defendant is prevented from knowing their identities. Defendants neither admits nor denies any allegation with respect to “all times relevant hereto” because each Plaintiff uses that phrase to refer to different times. Defendant neither admits nor denies any allegation as to any of Plaintiff’s motivations as she lack sufficient information to form a belief as to each Plaintiff’s motivation. 5. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 6. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.

7. Admitted in that Defendant Robinson was at one time was Interim Chief of Emergency Medical Services Operations (“EMSO.”) The term “at all time relevant hereto” is vague and undefined and as a result Defendant Robinson lacks information sufficient to either admit or deny this portion of the allegation.
8. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
9. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
10. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
11. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
12. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
13. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
14. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
15. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
16. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.

17. Admitted in part denied in part. Defendant admits to making a presentation to the 2001 class however lacks information sufficient to form a belief as to whether plaintiffs were present in that class, as their filings were made is fictitious names.
18. Denied. 19. Denied. 20. Denied. 21. Defendant Robinson lacks sufficient information to either admit or deny the allegations
contained in this paragraph. 22. Defendant Robinson lacks sufficient information to either admit or deny the allegations
contained in this paragraph. 23. Defendant Robinson lacks sufficient information to either admit or deny the allegations
contained in this paragraph. 24. Defendant Robinson lacks sufficient information to either admit or deny the allegations
contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 25. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 26. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 27. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 28. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.

Count I 29. The allegations contained in Paragraphs 1-28 are specifically answered as provided
above. 30. Defendant Robinson lacks sufficient information to either admit or deny the allegations
contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 31. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 32. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 33. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 34. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To

the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 35. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 36. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 37. This paragraph contains no allegations against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
Count II 38. The allegations in paragraphs 1 through 37 are specifically answered as provided above. 39. This paragraph calls for a legal conclusion which Defendant Robinson is not required to
admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 40. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 41. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. 42. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.

43. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
44. This paragraph contains no allegations against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. Count III
45. The allegations contained in paragraphs 1 through 44 are specifically answered as provided above.
46. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
47. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
48. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
49. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
50. Denied.

51. Denied to the extent that any conduct by Defendant Robinson caused any woman to have an abortion. Defendant Robinson lack sufficient information as to whether any plaintiff did have an abortion as they are pleading under fictitious names.
52. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
53. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
54. To the extent that this paragraph contains any allegation against Defendant Robinson, it is denied.
55. This paragraph does not contain any allegations against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. Count IV
56. The allegations contained in paragraphs 1 through 55 are specifically answered as provided above.
57. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
58. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
59. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.
60. Defendant Robinson lacks sufficient information to either admit or deny the allegations contained in this paragraph.

61. This paragraph contains no allegations against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. Count V
62. The allegations contained in paragraphs 1 through 61 are specifically answered as provided above.
63. Defendant admits to attending a training/orientation session for the 2001 class of EMTs as part of her duties as Interim Chief at EMSO. Defendant Robinson can neither admit nor deny what is meant by “among other things” in plaintiffs complaint as that term is too vague to answer.
64. Denied. 65. Denied. 66. Denied. 67. Denied. 68. Denied. 69. Denied. 70. Denied. 71. This Paragraph contains no allegations against Defendant Robinson. To the extent that
this paragraph contains any allegations against Defendant Robinson, it is denied. Count VI
72. The allegations contained in paragraphs 1 through 71 are specifically answered as provided above.
73. Denied. 74. Denied. 75. Denied. 76. Denied.

77. Denied. 78. Denied. 79. This paragraph contains no allegations against Defendant Robinson. To the extent that
this paragraph contains any allegations against Defendant Robinson, it is denied. Count VII
80. The allegations contained in paragraphs 1 through 79 are answered as provided above. 81. This paragraph calls for a legal conclusion which Defendant Robinson is not required to
admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 82. Denied. 83. Denied. 84. Denied. 85. Denied. 86. Denied. 87. There are no allegations in this paragraph against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 88. This paragraph calls for a legal conclusion which Defendant Robinson is not required to admit or deny but that Plaintiffs are required to prove. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied. 89. This paragraph contains no allegations against Defendant Robinson. To the extent that this paragraph contains any allegations against Defendant Robinson, it is denied.
Counterclaim – Slander
As a counterclaim against Plaintiffs, Defendant Robinson alleges:

1. Upon reasonable belief, on several dates since 2001 in locations within and outside of the District of Columbia, Plaintiffs in the presence and hearing of several persons maliciously, negligently or with reckless disregard for the truth spoke of and concerning Defendant Robinson false and defamatory words. Many of these statements were made to the District of Columbia Inspector General’s office, though while those statements may be privileged, Defendant Robinson alleges these statements were also made in non-privileged settings. In many of the conversations, the words that Plaintiffs used were slanderous per se or plaintiffs meant and intended to mean and was understood by the persons hearing such statements as slanderous as to Defendant Robinson. However, due to plaintiffs pleading under fictitious names, disclosure of plaintiffs’ true identity is required to establish the particular statements, to whom such slanderous statements were made, and the time at which such statements were made.
2. The words used by Plaintiffs were wholly false and made Defendant Robinson appear odious, infamous and ridiculous.
3. Thereby Defendant Robinson was injured in her reputation in the community and in her profession and caused her to be separated from the District of Columbia Fire/EMS against her will.
4. By virtue of Defendant Robinson’s constructive termination she lost and will continue to lose wages and pension benefits.
WHEREFORE – Defendant demands (a) that Plaintiff take nothing on Plaintiff’s claims (b) Defendant have a judgment against Plaintiff for the sum of Two Million One Hundred Thousand Dollars ($2,100,000.00) (c) That defendant be awarded costs herein (d) that

Defendant be awarded reasonable attorney fees; and (e) that the court grant such other and
further relief as the court may deem just and proper.
JURY DEMAND
Defendant Robinson demands a jury trial on all issues.
Dated this 9th day of March, 2004
By: Paul Strauss Bar #439967 Richard Bianco Bar #475319 Ronald L. Vavruska Jr. Bar #440760 Law Offices of Paul Strauss & Associates, PC 601 Pennsylvania Ave, NW, Suite 900 Washington, DC 20009

 
 11' TilE UNITED STATES DISTRICT COURT FOR TilE DISTRICT OF COLUMllIA

JANE DOE II,
cia O'Donoghue & O'Donoghue
4748 Wisconsin A venue, N.W. Washington, D.C. 20016
Plaintiff,
UNITED STATES OF AMERICA, Plainti ff-Intervenor,

Civil Action No. 02·2339 (RMU)

v.
DISTRICT OF COLUMBIA, ct rrL
Defendants . ........._ . _ - - - - -
COMPLAINT IN INTERVE1'TI01' Plaintiff-Intervenor, United States of America ("United States"), alleges: I. This action is brought on bchalfofthe United States to enforce the provisions of Title VI! or the Civil Rights Act of 1964, as amended, 42 U.S.c. § 2000c, ct seq. ("Title VII''), 2. This Court has jurisdiction over this action under 42 lJ.S.c. § 2000c-5(f) and 28 U,S,c. § 1345. 3. Defendant District ofColumhia is a governmental entity within the United States. 4. Defendant District of Columbia is a person within the meaning of Section 701(a) ofTitlc Vll, 42 U.S.c. § 2000e(a), and an employer within the meaning of Section 701 (b) of Title VII, 42 U,S,c. § 20000(1)). 5. Defendant District of Columbia has discriminated against Jane Doc II, and other females

similarly situated, with respect to hiring into and employment in emergency medical technician ("EMT") positions with the District of Columbia Fire and Emergency Medical Services Department ("FEMSD") because of their sex in violation of Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a), and Section 701 of Title VII, 42 U.S.c. § 2000c(k), by, among other ways:
a. sUbjecting her and other female applicants for EMT positions in the District's FEMSD to a pre-hiring pregnancy test;
b. conditioning an offer of employment to her and other female applicants for EMT positions in the District's FEMSD upon a negative result oflhe pregnancy test;
c. subjecting her and other female EMTs in the District's FEMSD to discrimination based on their sex during their employment, which adversely affected the tcnl1s, conditions and privileges of their employment and included advising them (explicitly and implicitly) through a management official or officials of the defendant District that, if during their probationary periods they were or became pregnant, they were at risk of losing their jobs; and
d. failing or refusing to take appropriate action to remedy the effects o[the discrimination.
6. As a result of defendant District of Columbia's discrimination as alleged in Paragraph 5, supra, Jane Doe II and other females similarly situated who became pregnant during their probationary periods as EMTs felt compelled to, and did, tcnninate their pregnancies by abortions in order not to risk losing their jobs. 7. The Equal Employment Opportunity Commission ("EEOC") received a timely charge of discrimination filed by Jane Doe Il, in which she alleged, infer alia, that the District of Columbia
2

discriminated against her, on the basis of her sex, in violation of Title VII. 7. Pursuant to Section 706 orTitlc VII, 42 U.S.c. § 2000e-5, the EEOC investigated the cbarge flIed by Jane Doc 1I, found reasonable cause to believe that her allegations of sex discrimination were hue, unsuccessfully attempted to achicve through conciliation a voluntary resolution oflhe charge, and subsequently referred that charge to the United States Department of Justice. Thereafter, the United States Depal1ment ofJustice issued a notice of right- to-sue on Janc Doc II's charge. Having rcceivcd such notice of right- to-sue, plaintiff Jane Doc II alleges, ill tel' alia, violations by defendant District of Columbia of Section 703(a) of Title VII, 42 U.S.c. § 2000c-2(a), and Section 701 ofTitle Vll, 42 U.S.c. § 2000c(k), in her complaint. 8. The Assistant Attorney General for the Civil Rights Division of the United Stales Department of Justice, by delegation from the Attorney General of the United States, has certified under Section 706(1)(1) of Title VII, 42 U.S.c. § 2000c-5(f)(1), that the abovecaptioncd case is of genera! public importance. See attachment hereto. 9. All conditions precedent to the filing of this complaint in intervention have been performed or havc occulTed.
WHEREFORE, plaintiff-intcrvenor United States prays that this Court: a. enter an ordcr enjoining defendant District of Columbia from failing or refusing to
provide remedial rcliefsufficient to make whole Jane Doc II, and other females similarly situated, for the loss they havc suffered as a result of the discrimination against them as aJleged in this complaint in intervention; and b. award compensatory damages to Jane Doe II, and other females similarly situated, for mental andlor physical injuries incuITed as a result of the discrimination
3

against them as alleged in this complaint in intervention, pursuant \0 and within
the statutory limit3tions of Section 102 of the Civil Rights Act of 1991,42 U.S.c.
§ 1981a.
The United States 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 issLics so triable pursuant to Rule
38 of the Federal Rules ofeivil Procedure and Section 102 of the Civil Rights Act of 1991, 42
u.S.c. § 1981 a.
R. ALEXANDER ACOSTA Assistant Attomey General Civil Rights Division
By:
DAVID 1. PALMER
lief i1.~~J,
OHN-~1C~Hiw'sKl
Deputy Chief ANN L. LOUGHLIN Trial Attorney Employment Litigation Section Civil Rights Division U.S. Department of Justice Room 4024, PHB 950 Pennsylvania Avc., NW Washington, DC 20530 (202l616-0474
4

 
 IN TilE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLU~IBIA

JANE DOE III, cia O'Donoghuc & O'Donoghuc 4748 \Visconsin Avenue, N.W. Washington, D.C. 20016
Plaintiff,
UNITED STATES OF AMERICA, Plaint! tT-Intervenor,

Civil Action No. 02-2340 (RMU)

v.
DISTRICT OF COLUMBIA, ct rrc,
Defendants.
COMPLAINT IN INTERVENTION Plaintiff.. Intervenor, United States of America ("United States"), alleges: I. This action is brought on bchalfofthc United States to enforce the provisions of Title VII orthe Civil Rights Act of 1964, as amended, 42 U.S.c. § 2000e, ct seq. ("Title VlI"). 2. This Court has jurisdiction over this action under 42 U.S.c. § 2000e-5(I) and
n USc. § 1345.
3. Defendant District of Columbia is a governmental entity within the United States. 4. Defendant District of Columbia is a person within the meaning of Section 701 (a) of Title VII, 42 U.s.C. § 2000c(£1), and an employer within the meaning ofSeetion 701(b) of Title VII, 42 USc. § 2000c(b). 5. Defendant District of Columbia has discriminated against Jane Doc III, and other females

similarly situated, with respect to hiring into and employment in emergency medical technician

("EMT") positions with the District of Columbia Fire and Emergency Medical Services

Department ("FEi'viSD") because of their sex in violation of Section 703(a) of Title VII, 42

USc. § 2000c-2(a), and Section 701 afIitle VII, 42 USc. § 2000c(k), by, among other ways:

a. sUbjecting her and other fCmale applicants for EMT positions in the District's

FEMSD to a pre~hiring pregnancy test;

b. conditioning an offer of employment to her and other female applicants for Et\..ff

positions in the District's FEMSD upon a negative result of the pregnancy test;

c. subjecting her and other female EMTs in the District's FEMSD to discrimination

based on their sex during their employment, which adversely affected the tenns,

conditions and privileges of their employment and included advising them

(explicitly and implicitly) through a management official or officials of the

defendant District that, if during their probationary periods they were or became

pregnant, they were at risk of losing their jobs; and

o.

failing or refusing to take appropriate action to remedy the effects of the

discrimination.

6. As a result of defendant District of Columbia's discrimination as a!leged in Paragraph 5,

s1Ipra, Jane Doe III and other females similarly situated who became pregnant during their

probationary periods as EMTs felt compelled to, and did, tenninate their prcgnancies by

abortions in order not to risk losing their jobs.

7. The Equa! Employmcnt Opportunity Commission ("EEOC") received a timely charge of

discrimination filed by Jane Doe 1lI, in which she alleged, inter alia, that the District of

2

Columbia discriminated against her, all the basis of her sex, in violation of Title VII. 7. The United States Department of Justice subsequently issued a notice of right-la-sue on Jane Doe III 's charge. Having received such notice of right-to-sue, plaintiff Jane Doc III alleges, illler alia, violations by defendant District of Columbia of Section 703(a) of Title VII, 42 USc. § 2000e-2(a), and Section 701 afTitle VII, 42 U.S.c. § 2000e(k), in her complaint. 8. The Assistant Attorney General for the Civil Rights Division of the United States Department of Justice, by delegation ii·om the Attorney General of the United States, has certified under Section 706(1)(1) afTitle VII, 42 U.S.c. § 2000e-5(1)(1), that the abo\'ecaptioned case is of general public importance. See attachment hereto. 9. All conditions precedent to the filing of this complaint in intervention have been performed or have occurred.
WHEREFORE, plaintiff.. intervenor United States prays that this Court: a. enter an order enjoining defendant District of Columbia from failing or refusing to
provide remedial rcliefsufficient to make whole Jane Doe Ill, and other females similarly situated, for the loss they have slli1cred as a result of the discrimination against them as alleged in this complaint in intervention; and b. award compensatory damages to Jane Doc llJ, and other females similarly situated, for mental andlor physical injuries incurred as a result of the discrimination against thcm as alleged in this complaint ill intervention, pursuant to and within the statutory limitations of Section 102 of tile Civil Rights Act of 1991,42lJ.s.C. § 1981a. The United States prays for such additional relief as justice may require, together with its
3

costs and disbursements in this action. JURY DEMAND
The United States hereby demands a trial by jury of all issucs so triable pursuant to Rule 38 of the Federal Rules of Civil Proccdure and Section 102 of the Civil Rights Act of 1991, .:1-2 U.S.C. § 1981a.
R. ALEXANDER ACOSTA Assistant Auomey General Civil Rights Division
By: ~~'-~J!L~_
DAVID J. PALMER
iJcf-ttf\..0 ~V' Jwi..
Il~ ~CiowSKI
Deputy Chief ANN L. LOUGHLIN Trial Attorney Employment Litigation Section Civil Rights Division U.S. Department of Justice Room 4024, PIlB 950 Pennsylvania Ave., NW Washington, DC 20530 (202) 616-0474
4

 
 CLOSED, JURY, TYPE-H
U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:02-cv-02338-RMU

DOE v. DISTRICT OF COLUMBIA et al Assigned to: Judge Ricardo M. Urbina Cause: 28:1441 Petition for Removal- Civil Rights Act

Date Filed: 11/25/2002 Date Terminated: 09/06/2005 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: Federal Question

Plaintiff JANE DOE, I

represented by Ellen O. Boardman O'DONOGHUE & O'DONOGHUE 4748 Wisconsin Avenue, NW Washington, DC 20016 (202) 362-0041 Fax: (202) 362-1200 Email: eboardman@odonoghuelaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Louis P. Malone O'DONOGHUE & O'DONOGHUE 4748 Wisconsin Avenue, NW Washington, DC 20016 (202) 362-0041 Fax: (202)237-1200 Email: lmalone@odonoghuelaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Intervenor Plaintiff UNITED STATES OF AMERICA

represented by Alicia Dyoni Johnson U.S. DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, NW Washington, DC 20530 (202) 353-1929 Fax: (202) 514-1005 Email: alicia.johnson2@usdoj.gov TERMINATED: 09/17/2004

ATTORNEY TO BE NOTICED
Ann L. Loughlin U.S. DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, NW Room 4024 PHB Washington, DC 20530 (202) 616-0474 Fax: (202) 353-8961 Email: ann.loughlin@usdoj.gov TERMINATED: 04/01/2004 ATTORNEY TO BE NOTICED
John M. Gadzichowski U.S. DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, NW Room 4018 PHB Washington, DC 20530 (202) 514-3834 Fax: (202) 514-1005 Email: john.m.gadzichowski@usdoj.gov ATTORNEY TO BE NOTICED
Karen D. Woodard U.S. DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, NW PHB-4038 Washington, DC 20530 (202) 514-7507 Email: karen.woodard@usdoj.gov ATTORNEY TO BE NOTICED
Kristofor J. Hammond U.S. DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, NW Room 4016 Washington, DC 20530 (202) 353-3011 Fax: (202) 514-1005 Email: kristofor.hammond@usdoj.gov TERMINATED: 10/06/2006 ATTORNEY TO BE NOTICED

V. Defendant DISTRICT OF COLUMBIA
Defendant RONNIE FEW
Defendant SAMANTHA ROBINSON

represented by Wendel Vincent Hall OFFICE OF THE CORPORATON COUNSEL 441 4th Street, NW Washington, DC 20001 (202) 724-6608 Fax: (202) 727-0431 Email: wendel.hall@dc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Longmeyer OFFICE OF THE CORPORATION COUNSEL 441 4th Street, NW 6th Floor-South Washington, DC 20001 (202) 724-6644 Fax: (202) 727-6014 Email: jennifer.longmeyer@dc.gov TERMINATED: 03/16/2004
represented by Wendel Vincent Hall (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jennifer L. Longmeyer (See above for address) TERMINATED: 03/16/2004
represented by Wendel Vincent Hall (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ronald Louis Vavruska, Jr. LAW OFFICES OF PAUL

Counter Claimant SAMANTHA ROBINSON
V. Counter Defendant JANE DOE, I

STRAUSS & ASSOCIATES 601 Pennsylvania Avenue, NW Suite 900 Washington, DC 20004 (202) 220-3100 Fax: 202-220-3103 Email: ronvavruska@aol.com ATTORNEY TO BE NOTICED
represented by Louis P. Malone O'DONOGHUE & O'DONOGHUE 4748 Wisconsin Avenue, NW Washington, DC 20016 (202)362-0041 Fax: (202)237-1200 Email: lmalone@odonoghuelaw.com ATTORNEY TO BE NOTICED

Date Filed 11/25/2002 11/25/2002 12/02/2002 12/06/2002 12/09/2002
12/09/2002

#

Docket Text

1 NOTICE OF REMOVAL from Superior Ct. DC, case number 02ca8643.(aet, ) Modified on 11/29/2002 (aet, ). (Entered: 11/29/2002)

SUMMONS Not Issued as to DISTRICT OF COLUMBIA ; RONNIE FEW ; SAMANTHA ROBINSON (aet, ) (Entered: 11/29/2002)

2 STANDING ORDER. Signed by Judge Ricardo M. Urbina on 12/02/02. (2) (Entered: 12/02/2002)

3 MOTION for Extension of Time to File Answer by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 12/06/2002)

4 NOTICE of Appearance by Jennifer L. Longmeyer on behalf of DISTRICT OF COLUMBIA (Longmeyer, Jennifer) (Entered: 12/09/2002)

MINUTE ENTRY ORDER granting 3 Motion for Extension of Time to

12/09/2002 12/13/2002 12/30/2002 02/19/2003 05/09/2003 05/12/2003 05/19/2003 05/23/2003 06/02/2003 06/05/2003 06/09/2003 06/16/2003 06/18/2003 06/19/2003

Answer. Signed by Judge Ricardo M. Urbina on 12/9/02.(2) (Entered: 12/09/2002)
5 ANSWER to Complaint with maximum number permitted by law by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/09/2002)
6 Original file, certified copy of transfer order and docket sheet received from DC Superior Court case no. 02ca8643. (bcs, ) Additional attachment(s) added on 12/16/2002 (bcs, ). (Entered: 12/16/2002)
7 First Amended ANSWER to Complaint with jury by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/30/2002)
Summons Issued (2) as to RONNIE FEW, SAMANTHIA ROBINSON. (aet, ) (Entered: 02/21/2003)
8 First MOTION for Extension of Time to File Report of LCvR 16.3(c) Conference by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 05/09/2003)
9 MEET AND CONFER STATEMENT. (Hall, Wendel) (Entered: 05/12/2003)
10 MOTION to Consolidate Cases by DISTRICT OF COLUMBIA, RONNIE FEW, SAMANTHIA ROBINSON. (Attachments: # 1 Text of Proposed Order)(Hall, Wendel) (Entered: 05/19/2003)
12 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. SAMANTHIA ROBINSON served on 5/10/2003, answer due 5/30/2003 (aet, ) (Entered: 06/04/2003)
11 Memorandum in opposition to motion re 10 Consolidation filed by JANE DOE I. (Boardman, Ellen) (Entered: 06/02/2003)
13 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE I. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/05/2003)
14 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE I. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/09/2003)
NOTICE OF CORRECTED DOCKET ENTRY. Document numbers 13 and 14 were entered in error. Cousel is instructed to refile said pleading. (Entered: 06/16/2003)
15 NOTICE of Appearance by Wendel Vincent Hall on behalf of RONNIE FEW (Hall, Wendel) (Entered: 06/18/2003)
MINUTE ENTRY ORDER granting 8 Motion for Extension of Time to

07/14/2003 07/28/2003 07/28/2003 07/29/2003
08/12/2003 08/13/2003
11/04/2003

File 16.3; granting 10 Motion to Consolidate Civil Actions 02-2338, 02-2339, 02-2340. The new action shall be captioned 02-2338 and civil actions 02-2339 and 02-2340 shall be dismissed from the court's docket. Recognizing the plaintiffs' concern about a joint trial, the court adds that, if they so desire, the plaintiffs may move for separate trials after discovery and the resolution of dispositive motions. Signed by Judge Ricardo M. Urbina on 6/19/03. Associated Cases: 1:02-cv02338-RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU (Entered: 06/19/2003)
16 STIPULATION to Dismiss Plaintiff's Claims for Declaratory and Injunctive Relief and To Establish Date for Answer by DISTRICT OF COLUMBIA. Associated Cases: 1:02-cv-02338-RMU,1:02-cv-02339RMU,1:02-cv-02340-RMU(Hall, Wendel) (Entered: 07/14/2003)
18 AFFIDAVIT FOR DEFAULT by JANE DOE I. (Attachments: # 1 Military Afidavit)(td, ) (Entered: 08/11/2003)
19 Clerk's ENTRY OF DEFAULT as to SAMANTHIA ROBINSON (td, ) (Entered: 08/11/2003)
17 MOTION for Default Judgment as to Defendant Robinson, MOTION for Extension of Time to Perfect Service by JANE DOE I. Responses due by 8/4/2003 (Attachments: # 1 # 2 Affidavit Donna OverkottSpell# 3 # 4 Text of Proposed Order)Associated Cases: 1:02-cv-02338RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU(Malone, Louis) (Entered: 07/29/2003)
20 NOTICE by DISTRICT OF COLUMBIA, RONNIE FEW Regarding Representation of Samanthia Robinson (Hall, Wendel) (Entered: 08/12/2003)
MINUTE ORDER striking motion 15 for default judgment as filed in 02-2339 and 02-2340. On June 19, 2003, the court granted the defendants' Motion 10 to Consolidate Civil Actions 02-2338, 02-2339, 02-2340 and directed that the "new action shall be captioned 02-2338 and civil actions 02-2339 and 02-2340 shall be dismissed from the court's docket." Nevertheless, the plaintiff filed a motion 15 for default judgment in civil actions 02-2339 and 02-2340. As stated previously, all submissions relating to civil actions 02-2338, 02-2339, 02-2340 must be filed in civil action 02-2338 because the other two actions were dismissed. Signed by Judge Ricardo M. Urbina on 8/13/03. (Entered: 08/13/2003)
21 Consent MOTION for Order to Schedule Rule 16(a) Conference by JANE DOE I. (Attachments: # 1 Text of Proposed Order)(Malone, Louis) (Entered: 11/04/2003)

01/27/2004
01/29/2004 02/02/2004 02/06/2004
02/09/2004 02/09/2004 02/09/2004 02/13/2004
02/13/2004 02/18/2004 02/18/2004 02/23/2004

22 ORDER granting motion for extention of time to perfect service; ordering defendant Robinson's counsel to enter appearance; setting dates for an opposition and reply to plaintiff's motion for default judgment. Signed by Judge Ricardo M. Urbina on 1/27/04. (Entered: 01/27/2004)
MINUTE ORDER entering the parties' joint stipulation of 7/14/03. Signed by Judge Ricardo M. Urbina on 1/29/04. (Entered: 01/29/2004)
23 First MOTION to Dismiss by SAMANTHIA ROBINSON. (Attachments: # 1 Text of Proposed Order)(Vavruska, Ronald) (Entered: 02/02/2004)
24 ENTERED IN ERROR..... MOTION to Amend/Correct Motion to Dismiss by SAMANTHIA ROBINSON. (Attachments: # 1 # 2)(Vavruska, Ronald) Modified on 2/9/2004 (cp, ). (Entered: 02/06/2004)
25 MOTION to Amend/Correct Motion to Dismiss by SAMANTHIA ROBINSON. (Attachments: # 1 # 2)(Vavruska, Ronald) (Entered: 02/09/2004)
NOTICE OF CORRECTED DOCKET ENTRY: Document No. 24 was Entered in Error and counsel was instructed to refile said pleading as last filing did not contain a motion. (cp, ) (Entered: 02/09/2004)
MINUTE ORDER granting 25 Motion to Supplement the Motion to Dismiss. Signed by Judge Ricardo M. Urbina on 2/9/04. (Entered: 02/09/2004)
26 Memorandum in opposition to motion re 23 Robinson Motion to Dismiss filed by JANE DOE I. (Attachments: # 1 Affidavit Declaration of Donna Spell and Exhibits# 2 Text of Proposed Order)(Malone, Louis) (Entered: 02/13/2004)
27 Memorandum in opposition to motion re 17 Default Judgment filed by SAMANTHIA ROBINSON. (Attachments: # 1 # 2 # 3)(Vavruska, Ronald) (Entered: 02/13/2004)
28 First MOTION for Extension of Time to Answer by RONNIE FEW. (Attachments: # 1)(Hall, Wendel) (Entered: 02/18/2004)
MINUTE ORDER granting 28 Motion for Extension of Time to Answer. Defendant Few's Answer is due on or before March 5, 2004. Signed by Judge Ricardo M. Urbina on 2/18/04. (Entered: 02/18/2004)
29 Joint MOTION to Withdraw Plaintiffs' Motion for Default Judgment and Defendant's Motion to Dismiss by JANE DOE I. (Malone, Louis) (Entered: 02/23/2004)

02/24/2004
02/25/2004 03/04/2004 03/09/2004 03/10/2004 03/16/2004 03/17/2004 03/18/2004 03/22/2004 03/22/2004 03/22/2004 03/26/2004 03/31/2004

MINUTE ORDER granting 29 Joint Motion to Withdraw Plaintiffs' Motion for Default Judgment and Defendants' Motion to Dismiss. The answer is due on or before March 9, 2004. Signed by Judge Ricardo M. Urbina on 2/24/04. (Entered: 02/24/2004)
30 MOTION to Intervene by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit Complaint in Intervention# 2 Text of Proposed Order)(Burgess, Joe) (Entered: 02/25/2004)
31 ANSWER to Complaint with Jury Demand by RONNIE FEW.(Hall, Wendel) (Entered: 03/04/2004)
32 Defendant Robinsons ANSWER to Complaint with jury demand, COUNTERCLAIM against JANE DOE I by SAMANTHIA ROBINSON.(Vavruska, Ronald) (Entered: 03/09/2004)
33 Memorandum in opposition to motion re 30 United States' Motion to Intervene filed by DISTRICT OF COLUMBIA, RONNIE FEW. (Hall, Wendel) (Entered: 03/10/2004)
34 NOTICE by DISTRICT OF COLUMBIA, RONNIE FEW of Withdrawal of Jennifer Longmeyer-Wood as Counsel for District of Columbia and Ronnie Few (Hall, Wendel) (Entered: 03/16/2004)
35 Second MOTION to Amend/Correct 7 Answer to Complaint by DISTRICT OF COLUMBIA, RONNIE FEW. (Attachments: # 1 # 2)(Hall, Wendel) (Entered: 03/17/2004)
36 NOTICE of Appearance by Ann L. Loughlin on behalf of UNITED STATES OF AMERICA (Loughlin, Ann) (Entered: 03/18/2004)
37 NOTICE of Appearance by Ellen O. Boardman on behalf of JANE DOE I (Boardman, Ellen) (Entered: 03/22/2004)
38 RESPONSE to Defendants District of Columbia's and Ronnie Few's Opposition to United States of America's Motion to Intervene filed by JANE DOE I. (Boardman, Ellen) (Entered: 03/22/2004)
39 REPLY to opposition to motion re 30 To Intervene filed by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit 1- Declaration of Louis P. Malone)(Loughlin, Ann) (Entered: 03/22/2004)
40 Plaintiffs/Counter-Defendants Jane Doe I, II and III ANSWER to Counterclaim of Defendant/Counter-Plaintiff Robinson by JANE DOE I.(Malone, Louis) (Entered: 03/26/2004)
41 NOTICE of Appearance by Alicia Dyoni Johnson on behalf of UNITED STATES OF AMERICA (Johnson, Alicia) (Entered: 03/31/2004)

03/31/2004
04/01/2004 04/08/2004
04/08/2004
08/05/2004 08/05/2004 08/05/2004 08/09/2004 08/26/2004 09/17/2004 09/17/2004 09/29/2004 10/01/2004 12/21/2004 02/22/2005

42 Memorandum in opposition to motion re 35 Defendant District of Columbia's Motion for Leave to Amend Its Answer to Add Certain Affirmative Defenses filed by JANE DOE I. (Attachments: # 1 Text of Proposed Order)(Malone, Louis) (Entered: 03/31/2004)
43 NOTICE by UNITED STATES OF AMERICA of Withdrawal and Substitution of Counsel (Loughlin, Ann) (Entered: 04/01/2004)
44 NOTICE of Appearance by John M. Gadzichowski on behalf of UNITED STATES OF AMERICA (Gadzichowski, John) (Entered: 04/08/2004)
45 NOTICE of Appearance by Kristofor J. Hammond on behalf of UNITED STATES OF AMERICA (Hammond, Kristofor) (Entered: 04/08/2004)
46 ORDER granting 30 Motion to Intervene. Signed by Judge Ricardo M. Urbina on 8/5/04. (Entered: 08/05/2004)
47 MEMORANDUM OPINION. Signed by Judge Ricardo M. Urbina on 8/5/04. (Entered: 08/05/2004)
49 Intervenor COMPLAINT filed by UNITED STATES OF AMERICA.(td, ) (Entered: 09/01/2004)
MINUTE ORDER denying 21 Motion for Order. Signed by Judge Ricardo M. Urbina on 8/9/04. (Entered: 08/09/2004)
48 ANSWER to Complaint in Intervention by DISTRICT OF COLUMBIA.(Hall, Wendel) (Entered: 08/26/2004)
50 NOTICE by UNITED STATES OF AMERICA Withdrawal of Appearance (Johnson, Alicia) (Entered: 09/17/2004)
51 NOTICE of Appearance by Karen D. Woodard on behalf of UNITED STATES OF AMERICA (Woodard, Karen) (Entered: 09/17/2004)
52 MEET AND CONFER STATEMENT. (Hall, Wendel) (Entered: 09/29/2004)
53 MEET AND CONFER STATEMENT. (Vavruska, Ronald) (Entered: 10/01/2004)
54 ORDER denying 35 Motion to Amend Answer. Signed by Judge Ricardo M. Urbina on 12/21/04. (Entered: 12/21/2004)
NOTICE of Hearing: An Initial Status Conference is set for 4/26/2005 at 9:45 AM in Courtroom 12 before Judge Ricardo M. Urbina. If not already done, the parties are to meet and confer and filed their Local 16.3 Report at least seven (7) days prior scheduled hearing date.(jwd) (Entered: 02/22/2005)

02/22/2005 04/21/2005 04/26/2005
04/26/2005 05/06/2005 05/06/2005 05/06/2005 08/31/2005 09/06/2005 09/14/2005 09/14/2005 09/14/2005

55 STANDING ORDER Signed by Judge Ricardo M. Urbina on February 22, 2005. (jwd) (Entered: 02/22/2005)
56 NOTICE of Offer of Judgment under Fed. R. Civ. P. 68 by DISTRICT OF COLUMBIA (Hall, Wendel) (Entered: 04/21/2005)
Minute Entry for proceedings held before Judge Ricardo M. Urbina: Status Conference held on 4/26/2005. Discovery due by 9/30/2005. Dispositive Motions are due by 11/4/2005. Oppositions to Dispositive Motions are due by 12/5/2005. Replies to Oppositions to Dispositive Motions are due by 12/19/2005. Motions to Amend Pleadings or Join Parties are due by 5/31/2005. Oppositions to Motions to Amend Pleading or Join Parties are due by 6/30/2005. Replies to Oppositions to Motions to Amend Pleadings or Join Parties are due by 7/15/2005. Proponent's Rule 26(a)(2)(B) Statement is due by 6/30/2005. Opponent's Rule 26(a)(2)(B) Statement is due by 8/1/2005. An Interim Status Conference is set for 10/4/2005 at 10:14 a.m. in Courtroom 12 before Judge Ricardo M. Urbina, at which time the Court will schedule a Final Status Hearing in the case. (Court Reporter William D. McAllister.) (jwd) (Entered: 04/26/2005)
57 INITIAL SCHEDULING ORDER. Signed by Judge Ricardo M. Urbina on 4/26/05. (Entered: 04/26/2005)
58 NOTICE OF ACCEPTANCE OF OFFER OF JUDGMENT by JANE DOE, I (Boardman, Ellen) (Entered: 05/06/2005)
59 NOTICE OF ACCEPTANCE OF OFFER OF JUDGMENT (JANE DOE II) by JANE DOE, I (Boardman, Ellen) (Entered: 05/06/2005)
60 NOTICE OF ACCEPTANCE OF OFFER OF JUDGMENT (JANE DOE III) by JANE DOE, I (Boardman, Ellen) (Entered: 05/06/2005)
61 NOTICE of Settlement Agreement (Proposed) for Approval and Entry by the Honorable Judge Ricardo M. Urbina by UNITED STATES OF AMERICA (Hammond, Kristofor) (Entered: 08/31/2005)
62 STIPULATED ORDER Signed by Judge Ricardo M. Urbina on September 6, 2005, approving settlement agreement. (jwd) (Entered: 09/06/2005)
63 NOTICE of Acceptance with Offer of Judgment by JANE DOE, I (Malone, Louis) (Entered: 09/14/2005)
64 NOTICE Notice of Jane Doe II Acceptance of Offer of Judgment and Offer of Judgment With Proof of Service Thereof by JANE DOE, I (Malone, Louis) (Entered: 09/14/2005)
65 NOTICE of Jane Doe III's Acceptance of Offer of Judgment, Offer of Judgment Together With Proof of Service Thereof by JANE DOE, I

09/15/2005
09/29/2005 09/30/2005 09/30/2005 10/13/2005 10/13/2005 10/14/2005 10/14/2005 10/14/2005 10/14/2005

(Malone, Louis) (Entered: 09/14/2005)
66 MOTION for Bill of Costs by JANE DOE, I. (Attachments: # 1 # 2 # 3 Exhibit One to Declaration of Louis P. Malone III in Support of Plaintiffs' Motion for Awardable Costs# 4 Exhibit Two to Declaration of Louis P. Malone III in Support of Plaintiffs' Motion for Awardable Costs# 5 Text of Proposed Order)(Malone, Louis) (Entered: 09/15/2005)
67 Consent MOTION for Extension of Time to File Response/Reply as to 66 MOTION for Bill of Costs by DISTRICT OF COLUMBIA. (Attachments: # 1 Text of Proposed Order)(Hall, Wendel) (Entered: 09/29/2005)
MINUTE ORDER granting 67 Motion for Extension of Time. The defendant shall submit its response to the plaintiff's motion for bill of costs on or before October 13, 2005. Signed by Judge Ricardo M. Urbina on 9/30/05. (md) (Entered: 09/30/2005)
Set Deadlines/Hearings: Defendant Response to Plaintiff's Motion for Bill of Costs due by 10/13/2005 (jwd) (Entered: 09/30/2005)
68 Consent MOTION for Extension of Time to Oppose Plaintiffs' Motion for Bill of Costs and To Set Deadline For Plaintiffs' Reply by DISTRICT OF COLUMBIA. (Attachments: # 1 Text of Proposed Order)(Hall, Wendel) (Entered: 10/13/2005)
69 Consent MOTION for Entry of Final Judgment Certificate of Sevice and Proposed Order by JANE DOE, I. (Attachments: # 1 # 2)(Malone, Louis) (Entered: 10/13/2005)
MINUTE ORDER granting 68 Consent Motion for Extension of Time. The defendant's response on or before October 20, 2005. The plaintiffs' reply is due on or before November 3, 2005. Signed by Judge Ricardo M. Urbina on 10/14/05. (md) (Entered: 10/14/2005)
Set Deadlines/Hearings: Defendant's Respons to Plaintiffs' Motion for Bill of Cost due by 10/20/2005. Plaintiffs' Reply due by 11/3/2005. (jwd) (Entered: 10/14/2005)
70 ORDER Signed by Judge Ricardo M. Urbina on October 14, 2005, granting 69 Consent Motion for Entry of Final Judgment. (jwd) (Entered: 10/14/2005)
71 FINAL JUDGMENT Signed by Judge Ricardo M. Urbina on October 14, 2005, in favor of Plaintiffs against Government of the District of Columbia, in the amount of $101,000.00 plus reasonable attorneys fees accrued to 4/21/2005, to be determined by the Court at a later date, in accordance with the Offers of Judgment made by the Government of

10/20/2005
11/04/2005 11/04/2005 11/07/2005 09/05/2006 09/05/2006 10/05/2006 10/06/2006
10/06/2006

the District of Columbia on 4/21/2005, accepted by the Plaintiffs on 5/6/2005 and filed with the court on 9/14/2005.(jwd) (Entered: 10/14/2005)
72 Memorandum in opposition to motion re 66 Plaintiffs' Motion for Awardable Costs filed by DISTRICT OF COLUMBIA. (Attachments: # 1 Exhibit Exhibit 1 Explanation# 2 Exhibit Spreadsheet of Charges# 3 Text of Proposed Order)(Hall, Wendel) (Entered: 10/20/2005)
73 Consent MOTION for Extension of Time to File Response/Reply as to Order on Motion for Extension of Time to November 4, 2005 by JANE DOE, I. (Malone, Louis) (Entered: 11/04/2005)
74 REPLY to opposition to motion re 66 Plaintiffs' Motion for Awardable Costs filed by JANE DOE, I. (Attachments: # 1)(Malone, Louis) (Entered: 11/04/2005)
MINUTE ORDER granting 73 Consent Motion for Extension of Time to File Reply nunc pro tunc. Signed by Judge Ricardo M. Urbina on 11/7/05. (md) (Entered: 11/07/2005)
75 ORDER granting in part and denying in part 66 the plaintiffs' motion for attorneys' fees and costs. Signed by Judge Ricardo M. Urbina on 9/5/2006. (md) (Entered: 09/05/2006)
76 MEMORANDUM OPINION. Signed by Judge Ricardo M. Urbina on 9/5/2006. (md) (Entered: 09/05/2006)
77 Consent MOTION for Extension of Time to Make Payment Of Award Of Attorneys' Fees by DISTRICT OF COLUMBIA, RONNIE FEW. (Hall, Wendel) (Entered: 10/05/2006)
MINUTE ORDER granting 77 consent motion for extension of time. Defendant District of Columbia shall pay the plaintiffs attorneys' fees award of $126,965.05 on or before November 6, 2006. Signed by Judge Ricardo M. Urbina on 10/6/2006. (md) (Entered: 10/06/2006)
78 NOTICE OF WITHDRAWAL OF APPEARANCE as to UNITED STATES OF AMERICA. Attorney Kristofor J. Hammond terminated. (Hammond, Kristofor) (Entered: 10/06/2006)

 
 CLOSED, JURY, TYPE-H
U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:02-cv-02339-RMU

DOE v. DISTRICT OF COLUMBIA et al Assigned to: Judge Ricardo M. Urbina Cause: 28:1441 Petition for Removal- Civil Rights Act

Date Filed: 11/25/2002 Date Terminated: 08/11/2003 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: Federal Question

Plaintiff JANE DOE, II

represented by Louis P. Malone O'DONOGHUE & O'DONOGHUE 4748 Wisconsin Avenue, NW Washington, DC 20016 (202) 362-0041 Fax: (202)237-1200 Email: lmalone@odonoghuelaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant DISTRICT OF COLUMBIA
Defendant RONNIE FEW

represented by Jennifer L. Longmeyer OFFICE OF THE CORPORATION COUNSEL 441 4th Street, NW 6th Floor-South Washington, DC 20001 (202) 724-6644 Fax: (202) 727-6014 Email: jennifer.longmeyer@dc.gov TERMINATED: 03/16/2004 LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Wendel Vincent Hall OFFICE OF THE CORPORATON

Defendant SAMANTHA ROBINSON
Movant UNITED STATES OF AMERICA

COUNSEL 441 4th Street, NW Washington, DC 20001 (202) 724-6608 Fax: (202) 727-0431 Email: wendel.hall@dc.gov ATTORNEY TO BE NOTICED

Date Filed 11/25/2002 11/25/2002 12/02/2002 12/06/2002 12/09/2002
12/09/2002
12/09/2002
12/13/2002

#

Docket Text

1 NOTICE OF REMOVAL from Superior Ct. DC, case number 02ca8891. () (aet, ) (Entered: 11/26/2002)

2 NOTICE OF RELATED CASE by DISTRICT OF COLUMBIA . Case related to Case No. 02-2338. (aet, ) (Entered: 11/26/2002)

3 STANDING ORDER. Signed by Judge Ricardo M. Urbina on 12/02/02. (2) (Entered: 12/02/2002)

4 MOTION for Extension of Time to File Answer by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 12/06/2002)

5 NOTICE of Appearance by Jennifer L. Longmeyer on behalf of DISTRICT OF COLUMBIA (Longmeyer, Jennifer) (Entered: 12/09/2002)

MINUTE ENTRY ORDER granting 4 Motion for Extension of Time to Answer . Signed by Judge Ricardo M. Urbina on 12/9/02. (2) (Entered: 12/09/2002)

6 ANSWER to Complaint with maximum jury number allowed by law by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/09/2002)

7 Original file, certified copy of transfer order and docket sheet received from DC Superior Court case no. 02ca8891. (bcs, ) Modified on 12/16/2002 (bcs, ). Additional attachment(s) added on 12/16/2002 (bcs, ). (Entered: 12/16/2002)

12/30/2002 02/19/2003 05/09/2003 05/12/2003 06/05/2003 06/09/2003 06/16/2003 06/18/2003 06/19/2003 06/19/2003
07/14/2003 07/29/2003

8 First Amended ANSWER to Complaint with jury by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/30/2002)
Summons (2) Issued as to RONNIE FEW, SAMANTHIA ROBINSON. (aet, ) (Entered: 02/21/2003)
9 First MOTION for Extension of Time to File Report of LCvR 16.3(c) Conference by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 05/09/2003)
10 MEET AND CONFER STATEMENT. (Hall, Wendel) (Entered: 05/12/2003)
11 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE II. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/05/2003)
12 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE II. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/09/2003)
NOTICE OF CORRECTED DOCKET ENTRY. Document numbers 11 and 12 were entered in error. Counsel is instructed to refile said pleadings. (aet, ) (Entered: 06/16/2003)
13 NOTICE of Appearance by Wendel Vincent Hall on behalf of RONNIE FEW (Hall, Wendel) (Entered: 06/18/2003)
CASE HAS BEEN CONSOLIDATED PURSUANT TO ORDER FILED 6/19/03. (td, ) (Entered: 06/19/2003)
MINUTE ENTRY ORDER granting 8 Motion for Extension of Time to File 16.3; granting 10 Motion to Consolidate Civil Actions 02-2338, 02-2339, 02-2340. The new action shall be captioned 02-2338 and civil actions 02-2339 and 02-2340 shall be dismissed from the court's docket. Recognizing the plaintiffs' concern about a joint trial, the court adds that, if they so desire, the plaintiffs may move for separate trials after discovery and the resolution of dispositive motions. Signed by Judge Ricardo M. Urbina on 6/19/03. Associated Cases: 1:02-cv02338-RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU (Entered: 06/19/2003)
14 STIPULATION to Dismiss Plaintiff's Claims for Declaratory and Injunctive Relief and To Establish Date for Answer by DISTRICT OF COLUMBIA. Associated Cases: 1:02-cv-02338-RMU,1:02-cv-02339RMU,1:02-cv-02340-RMU(Hall, Wendel) (Entered: 07/14/2003)
15 MOTION for Default Judgment as to Defendant Robinson, MOTION for Extension of Time to Perfect Service by JANE DOE I. Responses due by 8/4/2003 (Attachments: # 1 # 2 Affidavit Donna Overkott-

02/25/2004 03/10/2004

Spell# 3 # 4 Text of Proposed Order)Associated Cases: 1:02-cv-02338RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU(Malone, Louis) (Entered: 07/29/2003)
16 MOTION to Intervene by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit Complaint in Intervention# 2 Text of Proposed Order)(Burgess, Joe) (Entered: 02/25/2004)
17 Memorandum in opposition to motion re 16 Intervention filed by DISTRICT OF COLUMBIA, RONNIE FEW. (Hall, Wendel) (Entered: 03/10/2004)

 
 CLOSED, JURY, TYPE-H
U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:02-cv-02340-RMU

DOE v. DISTRICT OF COLUMBIA et al Assigned to: Judge Ricardo M. Urbina Cause: 28:1441 Petition for Removal- Civil Rights Act

Date Filed: 11/25/2002 Date Terminated: 08/11/2003 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: Federal Question

Plaintiff JANE DOE, III

represented by Louis P. Malone O'DONOGHUE & O'DONOGHUE 4748 Wisconsin Avenue, NW Washington, DC 20016 (202) 362-0041 Fax: (202)237-1200 Email: lmalone@odonoghuelaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant DISTRICT OF COLUMBIA

represented by Jennifer L. Longmeyer OFFICE OF THE CORPORATION COUNSEL 441 4th Street, NW 6th Floor-South Washington, DC 20001 (202) 724-6644 Fax: (202) 727-6014 Email: jennifer.longmeyer@dc.gov TERMINATED: 03/16/2004 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant RONNIE FEW
Defendant SAMANTHA ROBINSON Movant UNITED STATES OF AMERICA

represented by Wendel Vincent Hall OFFICE OF THE CORPORATON COUNSEL 441 4th Street, NW Washington, DC 20001 (202) 724-6608 Fax: (202) 727-0431 Email: wendel.hall@dc.gov ATTORNEY TO BE NOTICED

Date Filed 11/25/2002 11/25/2002 12/02/2002 12/06/2002 12/09/2002
12/09/2002
12/09/2002

#

Docket Text

1 NOTICE OF REMOVAL from Superior Ct. DC, case number 02ca9114. () (aet, ) (Entered: 11/26/2002)

2 NOTICE OF RELATED CASE by DISTRICT OF COLUMBIA . Case related to Case No. 02-2338. (aet, ) (Entered: 11/26/2002)

3 STANDING ORDER. Signed by Judge Ricardo M. Urbina on 12/02/02. (2) (Entered: 12/02/2002)

4 MOTION for Extension of Time to File Answer by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 12/06/2002)

5 NOTICE of Appearance by Jennifer L. Longmeyer on behalf of DISTRICT OF COLUMBIA (Longmeyer, Jennifer) (Entered: 12/09/2002)

MINUTE ENTRY ORDER granting 4 Motion for Extension of Time to Answer . Signed by Judge Ricardo M. Urbina on 12/9/02. (2) (Entered: 12/09/2002)

6 ANSWER to Complaint with maximum number in jury as

12/13/2002
12/30/2002 02/19/2003 05/09/2003 05/12/2003 06/05/2003 06/09/2003 06/16/2003 06/18/2003 06/19/2003 06/19/2003

allowed by law by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/09/2002)
7 Original file, certified copy of transfer order and docket sheet received from DC Superior Court case no. 02ca9114. (bcs, ) Modified on 12/16/2002 (bcs, ). Additional attachment(s) added on 12/16/2002 (bcs, ). (Entered: 12/16/2002)
8 First Amended ANSWER to Complaint with jury by DISTRICT OF COLUMBIA.(Longmeyer, Jennifer) (Entered: 12/30/2002)
Summons (2) Issued as to RONNIE FEW, SAMANTHIA ROBINSON. (aet, ) (Entered: 02/21/2003)
9 First MOTION for Extension of Time to File Report of LCvR 16.3(c) Conference by DISTRICT OF COLUMBIA. (Longmeyer, Jennifer) (Entered: 05/09/2003)
10 MEET AND CONFER STATEMENT. (Hall, Wendel) (Entered: 05/12/2003)
11 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE III. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/05/2003)
12 ENTERED IN ERROR.....AFFIDAVIT FOR DEFAULT and Military Affidavit by JANE DOE III. (Cohen, Maydad) Modified on 6/16/2003 (aet, ). (Entered: 06/09/2003)
NOTICE OF CORRECTED DOCKET ENTRY. Document numbers 11 and 12 were entered in error. Counsel is instructed to refile said pleadings. (aet, ) (Entered: 06/16/2003)
13 NOTICE of Appearance by Wendel Vincent Hall on behalf of RONNIE FEW (Hall, Wendel) (Entered: 06/18/2003)
Case has been consolidated pursuant to order filed 6/19/03. (td, ) (Entered: 06/19/2003)
MINUTE ENTRY ORDER granting 8 Motion for Extension of Time to File 16.3; granting 10 Motion to Consolidate Civil Actions 02-2338, 02-2339, 02-2340. The new action shall be captioned 02-2338 and civil actions 02-2339 and 02-2340 shall be dismissed from the court's docket. Recognizing the plaintiffs' concern about a joint trial, the court adds that, if they so desire, the plaintiffs may move for separate trials after discovery and the resolution of dispositive motions. Signed by Judge Ricardo M. Urbina on 6/19/03. Associated Cases: 1:02-cv-02338RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU (Entered: 06/19/2003)

07/14/2003 07/29/2003
02/25/2004 03/10/2004

14 STIPULATION to Dismiss Plaintiff's Claims for Declaratory and Injunctive Relief and To Establish Date for Answer by DISTRICT OF COLUMBIA. Associated Cases: 1:02-cv-02338RMU,1:02-cv-02339-RMU,1:02-cv-02340-RMU(Hall, Wendel) (Entered: 07/14/2003)
15 MOTION for Default Judgment as to Defendant Robinson, MOTION for Extension of Time to Perfect Service by JANE DOE I. Responses due by 8/4/2003 (Attachments: # 1 # 2 Affidavit Donna Overkott-Spell# 3 # 4 Text of Proposed Order)Associated Cases: 1:02-cv-02338-RMU,1:02-cv-02339RMU,1:02-cv-02340-RMU(Malone, Louis) (Entered: 07/29/2003)
16 MOTION to Intervene by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit Complaint in Intervention# 2 Text of Proposed Order)(Burgess, Joe) (Entered: 02/25/2004)
17 Memorandum in opposition to motion re 16 Intervention filed by DISTRICT OF COLUMBIA, RONNIE FEW. (Hall, Wendel) (Entered: 03/10/2004)

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 448 F.Supp.2d 137 (2006)
Jane DOES I, II, and III, Plaintiffs, v.
DISTRICT OF COLUMBIA et al., Defendants.
Civil Action No. 02-2338 (RMU).
United States District Court, District of Columbia.
September 5, 2006.
1389 *138 *139 Ellen O. Boardman, Louis P. Malone, O'Donoghue & O'Donoghue, Washington, DC, for Plaintiffs.
Wendel Vincent Hall, Office of the Corporation Counsel, Washington, DC, for Defendants.
MEMORANDUM OPINION
RICARDO M. URBINA, District Judge.
GRANTING IN PART AND DENYING IN PART THE PLAINTIFFS' MOTION FOR ATTORNEYS' FEES AND COSTS
I. INTRODUCTION
The plaintiffs, female emergency medical technicians with the District of Columbia's Fire and Emergency Medical Services Department ("FEMSD"), filed this action in 2002, alleging sex discrimination and deprivation of constitutional rights. The parties settled the suit in September 2005 and, pursuant to the settlement agreement, the case is now before the court on the plaintiffs' motion for attorneys' fees and costs. Because the plaintiffs are prevailing parties and because most (but not all) of the fees and costs requested are reasonable, the court grants in part and denies in part the plaintiff's motion.
II. BACKGROUND
The plaintiffs are women who were hired as emergency medical technicians with the FEMSD. The plaintiffs allege that after the FEMSD hired them, they received letters from the District of Columbia informing them that all female applicants had to take a pregnancy test. Compl. ¶ 15. The letter went on to inform them that, as a condition of employment, the pregnancy test had to be negative. Id. During their new hire training program, the FEMSD also informed the plaintiffs that their employment could be terminated if they became pregnant during the first year of their employment. Id. ¶ 18. After the plaintiffs learned that they were pregnant, they terminated their pregnancies for fear of losing their jobs. Id. ¶¶ 22-23.
"Following some extensive motion practice," and after the Department of Justice intervened, the District of Columbia made an offer of judgment to each of the three plaintiffs in the amount of $101,000.00 "plus reasonable attorneys' fees to be determined by the Court." Order (Sept. 6, 2005) at 4. The plaintiffs now move the court to accept their attorneys' fees calculations. The court now turns to the plaintiffs' motion.
III. ANALYSIS

A. Legal Standard for Attorneys' Fees
Federal Rule of Civil Procedure 54(d) requires a party seeking attorneys' fees and "related non-taxable expenses" to file a motion with the court. FED.R.Civ.P. 54(d)(2)(A). The motion "must specify the judgment and 140 the statute, rule, or other *140 grounds entitling the moving party to the award." Id. It must also state the amount or provide a fair amount of the award sought. Id.; see also Herbin v. Dist. of Columbia, 2006 WL 890673, at *2 (D.D.C. Apr.4, 2006).
Under 42 U.S.C. § 1988 and under Title VII of the Civil Rights Act of 1964, a district court may, in its discretion, award reasonable attorneys' fees to the prevailing party. Palmer v. Rice, 2005 WL 1662130, at * 9 (D.D.C. July 11, 2005) (citing 42 U.S.C. § 2000e-5(k)); Talley v. Dist. of Columbia, 433 F.Supp.2d 5, 7 (D.D.C. 2006). A court's determination of the appropriate attorneys' fees, in other words, is based on a two-step inquiry. First, the court must determine whether the party seeking attorneys' fees is the prevailing party. A prevailing party "is one who has been awarded some relief by a court." Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep't of Health and Human Res., 532 U.S. 598, 603, 121 S.Ct. 1835, 149 L.Ed.2d 855 (2001).
Second, the court must determine whether the attorneys' fees sought are reasonable. "The most useful starting point for determining the amount of a reasonable fee is the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate." Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983). The plaintiff bears the burden of demonstrating that the number of hours spent on a particular task is reasonable. Role Models Am., Inc. v. Brownlee, 353 F.3d 962, 970 (D.C.Cir.2004). The plaintiffs "supporting documentation must be of sufficient detail and probative value to enable a court to determine with a high degree of certainty that such hours were actually and reasonably expended." Id. (quoting In re Olson, 884 F.2d 1415, 1428 (D.C.Cir.1989) (internal punctuation omitted); see also Covington v. Dist. of Columbia, 57 F.3d 1101, 1107 (D.C.Cir.1995) (stating that "a fee applicant bears the burden of establishing entitlement to an award, documenting the appropriate hours, and justifying the reasonableness of the rates"). "To determine the number of 'hours reasonably expended,' the district court must exclude hours that are 'excessive, redundant, or otherwise unnecessary.'" Palmer, 2005 WL 1662130, at * 9 citing Hensley, 461 U.S. at 434, 103 S.Ct. 1933). With respect to the reasonable hourly rate, attorneys' fees in civil rights actions in this Circuit are reasonable if they conform to the Laffey Matrix[1] created by the United States Attorneys' Office. Covington, 57 F.3d at 1109 (explaining that an attorneys' fees award is reasonable if it is calculated on the basis of rates prevailing in the community and that the Laffey matrix is evidence of prevailing market rates).
B. Most of the Fees Sought are Reasonable[2]
1. The Reasonable Hourly Rate
Although the plaintiffs' attorneys charge rates below market rates, the plaintiffs argue that the court should base its determination of the appropriate hourly rate on the Laffey Matrix. Pls.' Mot. at 6. Further, the plaintiffs argue 141 that the court *141 should base its determination of the appropriate hourly rate on the current Laffey Matrix, rather than the Laffey Matrix that was in effect at the time the attorneys completed the work for which they now seek compensation. Pls.' Mot. at 5-6. The defendants object to an attorneys' fee award based on the current Laffey Matrix. Defs.' Opp'n at 8.
Attorneys who practice privately and for profit but charge "reduced rates reflecting noneconomic goals" are entitled to receive attorneys' fees based on the prevailing market rate. Save Our Cumberland Mountains, Inc. v. Hodel, 857 F.2d 1516, 1524 (D.C.Cir.1988) (concluding that "Congress did not intend the private but publicspirited rate-cutting attorney to be penalized for his public spiritedness by being paid on a lower scale than either his higher priced fellow barrister from a more established firm or his salaried neighbor at a legal services clinic"). In this case, the plaintiffs' attorneys charge "hourly rates that are below the market rate for work associated with complex civil litigation." Pls.' Mot. Ex. 1 ("Malone Decl.") ¶ 13. For example, the plaintiffs' attorneys charge between $150.00 to $175.00 per hour in matters of employment law. Id. According to the plaintiffs' attorneys, the

reduced rates "reflect [the firm's] decision to provide affordable legal services to working men and women in the District of Columbia and throughout the United States who cannot afford to pay market rates for such representation." Id. ¶ 14. According to the Laffey Matrix, the reasonable hourly rate for attorneys with the level of experience of the plaintiffs' lead counsel is 8405.00. The defendants do not challenge the plaintiffs' assertion that their attorneys' rates reflect non-economic goals.[3] Thus, the court concludes that the plaintiffs' attorneys reduced rates reflect non-economic goals, and that the plaintiffs' attorneys are entitled to attorneys' fees based on the Laffey Matrix. Save Our Cumberland Mountains, Inc., 857 F.2d at 1524.
The court's next inquiry turns on the issue of the appropriate Laffey Matrix. The plaintiffs argue that the court should base its award determination on the current Laffey Matrix, Pls.' Mot. at 6, while the defendants argue that the court should base its award determination on the Laffey Matrix prevailing at the time when the litigation was conducted, Defs.' Mot. at 8.
"[C]ompensation received several years after the services were rendered as 0907 it frequently is in complex civil rights litigation0907is not equivalent to the same dollar amount received reasonably promptly as the legal services are performed, as would normally be the case with private billings." Missouri v. Jenkins by Agyei, 491 U.S. 274, 283, 109 S.Ct. 2463, 105 L.Ed.2d 229 (1989). That is, "to roughly compensate for delay in payment, a district court has the authority to award current market rates instead of historic market rates, so long as the use of current instead of historic rates would not overcompensate counsel, 'generating a windfall for the plaintiff's attorneys.'" Covington v. Dist. of Columbia, 839 F.Supp. 894, 902 (D.D.C. 1993), aff'd, 57 F.3d 1101 (D.C.Cir.1995); see also Murray v. Weinberger, 741 F.2d 1423, 1433 (D.C.Cir.1984). In this case, the plaintiffs' attorneys' work on this matter began in September 2001. Pls.' Mot. Ex. 2 ("Attorney Time Records") at 1. The case did not settle until 142 almost exactly four years later. Pls.' Mot. at 2. Because "an *142 appropriate adjustment for delay in payment0907whether by the application of current rather than historic hourly rates or otherwise is 0907 within the contemplation of [§ 1988]," Jenkins by Agyei, 491 U.S. at 283-284, 109 S.Ct. 2463, the court concludes that the reasonable hourly fees in this case are the hourly fees established in the 2005 Laffey Matrix.
2. The Number of Hours Reasonably Expended on the Litigation
The plaintiffs seek reimbursement for 625.75 hours of attorney work totaling $194,656.30 in attorneys' fees and $5,288.40 in costs. Pls.' Mot. at 4. The defendants argue that 625.75 hours are unreasonable because the "plaintiffs needed to do no factual investigation, only attended two Rule 16 meetings, and appeared in Court exactly once." Defs.' Opp'n at 1. Specifically, the defendants make the following objections to the requested fee award: (a) the plaintiffs' attorneys' practice of billing in quarter-hour increments inflates the total number of hours; (b) the plaintiffs should not be reimbursed for the hours spent on legal work related to claims against codefendant Robinson; (c) some of the charges0907particularly the charges for research and for meetings and telephone conferences0907are not sufficiently detailed or the entries "lump[ ] tasks together without specifying the time spent on each;" and (d) the plaintiffs are not entitled to costs. Defs.' Opp'n at 6, 9. The court addresses each of these arguments in turn below.
a. Billing in Quarter Hour Increments
The plaintiffs' law firm bills clients in "quarterly hour increments." Malone Decl. ¶ 9. According to the defendants, the plaintiffs' law firm's practice of billing in quarter-hour increments overstates the total number of hours worked. Defs.' Opp'n at 9. While the D.C. Circuit has not discussed the reasonableness of billing in quarter-hour increments, some district courts have reduced the requested fee awards when the attorneys billed in this fashion. See, e.g., Lopez v. San Francisco Unified Sch. Dist., 385 F.Supp.2d 981, 993 (N.D.Cal.2005); Mahtesian v. Snow, 2004 WL 2889922, at * 9 (N.D.Cal. Dec.14, 2004); Zucker v. Occidental Petroleum Corp., 968 F.Supp. 1396, 1403 (C.D.Cal. 1997); Miller v. Bowen, 639 F.Supp. 832, 836 (E.D.N.C.1986). Other district courts, however, have not reduced the requested fee awards where it is the regular practice of the law firm to bill in quarter-hour increments.[4]See, e.g., Branham v. Snow, 2006 WL 1750443, at *5 (S.D.Ind. June 19, 2006); Bd. of Educ. of Frederick County v. LS. ex rel. Summers, 358 F.Supp.2d 462, 470 (D.Md.2005); Herrejon v. Appetizers And, Inc., 1999 WL 116598, at *3 (N.D.Ill. Feb.22, 1999); Morimanno v. Taco Bell, 979 F.Supp. 791, 799

(N.D.Ind.1997). Because the plaintiffs have already reduced their fee request by 154 hours, Malone Decl. ¶ 11, and because the plaintiffs' law firm bills all of its clients in quarter-hour increments, the court declines to reduce the requested fee award as a result of the law firm's practice of billing in quarterhour increments.
143 *143 b. Reimbursement for Work on Claims Against Co-Defendant Robinson
The defendants argue that the plaintiffs should not receive attorneys' fees for the plaintiffs' attorneys' work on claims against co-defendant Robinson. Defs.' Opp'n at 10. Robinson was the Interim Chief of the FEMSD and, during the new hire training program, she informed the plaintiffs that their employment could be terminated if they became pregnant in the during the first year of their employment. Compl. ¶¶ 7, 17-20. The plaintiffs sued defendant Robinson in her official capacity and individually for constitutional and common law torts. Pls.' Reply at 7. In their exhibit to the opposition brief, the defendants object to paying attorneys' fees for the legal work on claims against Robinson because the work on those claims did not contribute to the plaintiffs' success on their claims against the District of Columbia. Defs.' Opp'n at 10-11. "Where the plaintiff has failed to prevail on a claim that is distinct in all respects from his successful claims, the hours spent on the unsuccessful claim should be excluded in considering the amount of a reasonable fee." Hensley, 461 U.S. at 440, 103 S.Ct. 1933. But, "[w]here a lawsuit consists of related claims, a plaintiff who has won substantial relief should not have his attorney's fee reduced simply because the district court did not adopt each contention raised." Id. Here, the plaintiffs' claims against Robinson are related to their claims against the District of Columbia because the claims against the District of Columbia and those against Robinson have the same factual basis: Robinson's statements to the female trainees. Further, the plaintiffs sued Robinson not only in her individual capacity, but in her official capacity as well. Thus, the plaintiffs' success on their claims against the District of Columbia is also related to their success on the official capacity claims against defendant Robinson. The court accordingly declines to reduce the requested fee award by the time spent litigating claims against defendant Robinson.
c. Adequacy of Detail
The defendants also argue that many of the plaintiffs' attorneys' research charges and the charges for meetings and telephone conferences are vague and lump together multiple tasks, and as such, do not allow the court to ascertain the reasonableness of the research. Defs.' Opp'n at 11-13. As stated supra, the plaintiffs bear the burden of establishing the reasonableness of their fee request. Role Models Am., Inc., 353 F.3d at 970. The plaintiffs' "supporting documentation must be of sufficient detail and probative value to enable a court to determine with a high degree of certainty that such hours were actually and reasonably expended." Id. (internal punctuation omitted).
The plaintiffs' time records in the instant matter are, in many instances, lacking in adequate detail. For example, many entries contain descriptions that state "research" or "research regarding causes of action" or "research for litigation case binder." See Role Models Am., Inc., 353 F.3d at 971 (holding that litigant could not recover attorneys' fees for generic time entries, such as "research" and "writing," because the court cannot verify the reasonableness of such billings). Other entries "lump together multiple tasks, making it impossible to evaluate their reasonableness." Id. Finally, practically all of the entries for meetings and telephone conferences "are replete with instances where no mention is made of the subject matter of the meeting, telephone conference, or work performed during hours billed." In re Meese, 907 F.2d 1192, 1204 (D.C.Cir.1990).
144 *144 Recognizing the inadequacy of their time records, the plaintiffs' reply brief includes a supplemental declaration providing greater detail. The supplemental declaration, for example, explains the subject matter of the research, the subject matter discussed at many of the meeting and telephone conferences, and also describes the many instances in which the plaintiffs' law firm did not bill the clients for duplicative work. See generally Pls.' Reply, Ex. 3 ("Supp. Malone Decl."). The supplemental declaration provides enough information and detail to allow the court to ascertain the reasonableness of the fee request. The court concludes that the research entries and the entries related to meetings and telephone conferences are reasonable. The research, for example, pertains to the issues prevalent in this case, such as the use of pseudonyms in discrimination cases, defenses to

the District of Columbia's arguments, notice requirements, and damages issues. Id. ¶¶ 8-12, 19, 20, 25-29, 37-41, 50-52, 60. The meetings and conferences were also related to the subject matter of the litigation and include, inter alia, discussions with the Department of Justice, discussions about the settlement offers with the plaintiffs, and discussions with the defendants themselves, as well as with other team members. Supp. Malone Decl. ¶¶ 10, 14, 15, 17, 21-23, 31-35, 41-46, 48-50, 52-59. The court therefore concludes that the plaintiffs are entitled to attorneys' fees for the time they spent on research and in meetings and telephone conferences.[5]
The court, however, does reduce the plaintiffs' requested fee award because the number of partner hours spent on the matter compared to the number of associate hours is excessive. The partners in this matter spent 335.25 hours on this matter, while the associates, law clerk and paralegals spent a combined 290.50 hours on this matter. Because "a partner should be performing supervisory work," Adolph Coors Co. v. Truck Ins. Exchange, 383 F.Supp.2d 93, 97 (D.D.C.2005), the court will therefore reduce the number of compensable partner hours by half. Thus, the court reduces the time expended by Louis Malone from 226.75 hours to 113.75 hours. The court also reduces the time expended by Ellen Boardman and Richard Hopp from 99.75 hours to 49.875 hours and from 8.75 hours to 4.375 hours, respectively. Because the applicable hourly rate for Malone and Boardman is $405 and because the applicable hourly rate for Hopp is $360, the court reduces the total attorneys' fees request by $67,691.25.
d. Costs
Because the offer of judgment stated that the plaintiffs are entitled to "reasonable attorneys' fees,"[6] the defendants argue that the plaintiffs are not entitled to costs. Defs.' Opp'n at 6. Under Rule 68, however, a defendant making an offer of judgment must pay the plaintiffs' costs. FED.R.CIv.P. 68 (stating that "a party defending against a claim may serve upon the adverse party an offer to allow judgment to be taken against the 145 defending party for the money or property or to the effect specified in the offer, with costs *145 then accrued"). The defendants made the offer of judgment "pursuant to Rule 68." Because Rule 68 provides for costs, the defendants' offer of judgment need not explicitly state that the defendants will pay costs for the defendants to be liable for costs.[7]Greenwood v. Stevenson, 88 F.R.D. 225, 230 (D.R.I.1980) (explaining that "when contracting parties use terms of art, they will be deemed to have 'intended' the full legal meaning of those words"); see also Gen. Ry. Signal Co. v. Wash. Metro. Area Transit Auth., 875 F.2d 320 (D.C.Cir.1989) (interpreting legal terms of art in a contract according to their legal meaning). Thus, the defendants must pay the plaintiffs both costs and reasonable attorneys' fees.
Having concluded that the defendants must pay the plaintiff costs, the court's next inquiry centers on the types of costs that the plaintiffs are entitled to receive. The plaintiffs argue that they are entitled to costs for computerized legal research and for the private process servers. For the reasons that follow, the court concludes that the plaintiffs are not entitled to recovery of these costs.
The terms costs as used in Rule 68 is synonymous with the costs in 28 U.S.C. § 1920. Gil de Rebollo v. Miami Heat Ass'ns, Inc., 137 F.3d 56, 66 (1st Cir.1998). The costs allowable under § 1920 include:
(1) Fees of the clerk and marshal;
(2) Fees of the court reporter for all or any part of the stenographic transcript necessarily obtained for use in the case;
(3) Fees and disbursements for printing and witnesses;
(4) Fees for exemplification and copies of papers necessarily obtained for use in the case;
(5) Docket fees under section 1923 of this title;
(6) Compensation of court appointed experts, compensation of interpreters, and salaries, fees, expenses, and costs of special interpretation services under section 1828 of this title.
28 U.S.C. § 1920.

The plaintiffs seek reimbursement for private service of process costs and for the costs of computerized research. Computerized research is not considered a cost pursuant to § 1920. Attrezzi, LLC v. Maytag Corp., 436 F.3d 32, 43 (1st Cir. 2006).[8] The plaintiffs thus cannot recover the costs of computerized legal research.
The plaintiffs also seek reimbursement for the private process server. Pls.' Reply at 18. The Second, Fifth, Sixth, Seventh, and Ninth Circuits interpret § 1920(1)'s phrase "fees of the clerk and marshal" to include private process servers' fees because the service of summonses and subpoenas is now done almost exclusively by private parties, rather than by the marshal. See, e.g., Gaddis v. United States, 381 F.3d 444, 456 (5th Cir.2004); Arrambide v. Wal-Mart Stores, Inc., 33 Fed. Appx. 199, 202-203 (6th Cir.2002); U.S. Equal Employment Opportunity Comm'n v. W & O, Inc., 213 F.3d 600, 624 (11th Cir.2000); Collins v. Gorman, 96 F.3d 1057, 1060 (7th Cir.1996); U.S. for Use and Benefit of Evergreen Pipeline Const. Co., Inc. v. Merritt Meridian Const. Corp., 95 F.3d 153, 172 (2d Cir.1996); Alflex Corp. v. Underwriters Labs., Inc., 914 F.2d 175, 178 (9th Cir.1990). The 146 Eighth Circuit, on the other hand, construes the text of § 1920 literally. Crues v. KFC Corp., *146 768 F.2d 230 (8th Cir.1985). This Circuit's court of appeals "begin[s] as always, with the statute's language." Friends of Earth, Inc. v. Environmental Protection Agency, 446 F.3d 140, 144-45 (D.C.Cir.2006) (interpreting the word "daily" in a statute to mean every day, even where the agency implementing the statute argued that the literal interpretation of the term contravened the statute's purpose). The text of § 1920 only allows for recovery for "fees of the clerk and marshal." Because § 1920 does not provide for reimbursement of the costs of a private process server, the costs the plaintiffs seek to recover are not reimbursable under § 1920.
IV. CONCLUSION
For the foregoing reasons, the court grants in part and denies in part the plaintiffs' motion for attorneys' fees and costs. An order consistent with this Memorandum Opinion is issued the 5th day of September, 2006.
[1] The Laffey Matrix is "a schedule of charges based on years of experience." Herbin v. Dist. of Columbia, 2006 WL 890673, at *4 (D.D.C. Apr.4, 2006).
[2] As a preliminary matter, the court notes that the defendants do not dispute that the plaintiffs are prevailing parties. Further, pursuant to the settlement agreement, the defendants agreed to pay reasonable attorneys' fees as determined by this court. Thus, the only task left for the court is to determine the appropriate amount of attorneys' fees that the defendants must pay the plaintiffs.
[3] Indeed, the defendants do not object to the plaintiffs' arguments that they are entitled to attorneys' fees based on hourly rates higher than those actually charged by their attorneys.
[4] Taking a middle-of-the-road approach, the Eighth Circuit reviews the attorney time records for instances where one-quarter of an hour was billed for a meeting or telephone conference because "these are the most likely examples where overbilling may have occurred" and converts the charges into tenth-hour charges. Republican Party of Minn. v. White, 456 F.3d 912 (8th Cir.2006). Because there are only a few instances where the plaintiffs' attorneys charged a quarter of an hour for a meeting or a telephone, the court does not adopt the Eighth Circuit approach here.
[5] The defendants also object to many of the entries because the plaintiffs "lump together" multiple tasks into one entry and do not break down the specific amount of time spent on each task. Defs.' Opp'n at 13. The plaintiffs' practice of block billing, while not a practice to be encouraged, does not prevent the court from making a determination as to whether the hours devoted to a particular task were reasonable. Indeed, the plaintiffs' supplemental declaration provides an adequate amount of detail to assist the court in its determination.
[6] Under § 1988 and Title VII actions, attorneys' fees are recoverable as costs. 42 U.S.C. § 1988(b), 42 U.S.C. § 2000e-5(k).
[7] Indeed, the defendants do not even argue that they believed the offer of judgment excluded costs.

[8] Although Attrezzi holds that computer research costs may be shifted under § 1988, the parties' settlement agreement only provides for recovery of attorneys' fees and not any other costs under § 1988.
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