Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

FILED JUL 17 2.005

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION

I

Plaintiff,

v.

SHAW ENVIRONMENTAL, INC.

&

ENVIRONMENTAL DIMENSIONS, INC.,

Defendants.

)

~UERSN.UID>IIKSIt~RIictCUOUfKMI O

)~6CVO 10 6 3 FRB

)

CIVIL ACTION NO.

)

)

COMPLAINT

)

)

)

)

)

JURY TRIAL DEMAND

)

)

NATURE OF ACTION This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation, and to provide appropriate relief to Karla Spafford who was adversely affected by such practices. As alleged with greater particularity in the Statement of Claims below, the Equal Employment Opportunity Commission ("the Commission") alleges that Defendants Shaw Group, Inc. ("Shaw") and Environmental Dimensions, Inc. ("EDi") discriminated against Ms. Spafford, a female senior technician, on the basis of her sex. Furthermore, the Commission alleges that Defendants discriminated against Ms. Spafford in retaliation for filing a charge and employment discrimination lawsuit against her previous employer.

Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 2 of 6

JURISDICTION AND VENUE

I. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,

1343, and 1345. This action is authorized and instituted pursuant to Section 706(t)(1) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.§ 2000e-5(t)(l) and (3) ("Title

VII'') and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.

2. The employment practices alleged to be unlawful were committed within the

jurisdiction of the United States District Court for Eastern District of Missouri, Eastern Division.

PARTIES

3. Plaintiff, the Commission, is the agency of the United States of America charged

with the administration, interpretation and enforcement of Title VII, and is expressly authorized

to bring this action by Section 706(t)(l) and (3) ofTitle VII, 42 U.S.C. § 2000e-5(f)(l) and (3).

4.

At all relevant times, Defendant Shaw, a Louisiana corporation, has continuously

been doing business in the state of Missouri and the City of Bridgeton, and has continuously had

at least 15 employees.

5. At all relevant times, Defendant Shaw has continuously been an employer

engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of

Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).

6. At all relevant times, Defendant EDi , a New Mexico corporation, has

continuously been doing business in the state of Missouri and the City of Bridgeton, and has

continuously had at least 15 employees.

2

Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 3 of 6

7.

At all relevant times, Defendant EDi has continuously been an employer engaged

in an industry affecting commerce within the meaning of Sections 701(b), (g) and (b) of Title

VII, 42 U.S.C. §§ 2000e(b), (g) and (b).

STATEMENT OF CLAIMS

8.

More than thirty days prior to the institution of this lawsuit, Karla Spafford filed a

charge with the Commission alleging violations of Title VII by Defendants Shaw and EDi. All

conditions precedent to the institution of this lawsuit have been fulfilled.

9.

Since at leastJanuary 2001, Defendants Shaw and EDi have engaged in unlawful

employment practices at Shaw's Bridgeton clean up site, in violation of Sections 706(f)(l) and

(3) of Title VII, 42 U.S.C. §§ 2000e-2(a)(l) and (2), by selecting Ms. Spafford for lay off over

less qualified and experienced male senior technicians because of her sex, female.

10. Since at least January 2001, Defendants Shaw and EDi have engaged in unlawful

employment practices at the St. Louis clean up sites, in violation of Sections 706(f)(l) and (3) of

Title VII, 42 U.S.C. §§ 2000e-2(a)(l) and (2), by selecting Ms. Spafford for lay off over less

qualified and experienced male senior technicians in retaliation for her filing a Title VII lawsuit

against her previous employer who was also one of the subcontractors at the clean up site.

11. The effect of the practices complained of in paragraphs 9 and 10 above has been

to deprive Ms. Spafford of equal employment opportunities and otherwise adversely affect her

status as an employee becanse of her sex.

12 The unlawful employment practices complained of in paragraphs 9 and I0 above

were intentional.

3

Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 4 of 6

13. The unlawful employment practices complained of in paragraphs 9 and 10 above

were done with malice or with reckless indifference to the federally protected rights of Karla

Spafford.

PRAYER FOR RELIEF

Wherefore, the Commission respectfully requests that this Court:

A. Grant a permanent injunction enjoining Defendant Shaw, its officers, successors,

assigns, and all persons in active concert or participation with it from engaging in sex

disctimination and retaliation and any other employment practice which discriminates on the

basis of sex.

B. Grant a permanent injunction enjoining Defendant EDi, its officers, successors,

assigns, and all person in active concert or participation with it from engaging in sex

discrimination and retaliation and any other employment practice which discriminates on the

basis of sex.

C.

Order Defendant Shaw to institute and carry out policies, practices, and programs

which provide equal employment opportunities for women, and which eradicate the effects of

this past and present unlawful employment practice.

D. Order Defendant EDi to institute and carry out policies, practices, and programs

which provide equal employment opportunities for women, and which eradicate the effects of

this past and present unlawful employment practice.

E.

Order Defendant Shaw to make whole Karla Spafford, by providing appropriate

backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative

relief necessary to eradicate the effects of its unlawful employment practices.

4

Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 5 of 6

F.

Order Defendant EDi to make whole Karla Spafford, by providing appropriate

backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative

relief necessary to eradicate the effects ofits unlawful employment practices.

G. Order Defendant Shaw to make whole Karla Spafford, by providing

compensation for past pecuniary losses resulting from the unlawful employment practices

described in paragraphs 9 and I0 above, in amounts to be determined at trial

H. Order Defendant EDi to make whole Karla Spafford, by providing compensation

for past pecuniary losses resulting from unlawful employment practices described in paragraphs

9 and 10 above, in amounts to be determined at trial.

I.

Order Defendant Shaw to make whole Karla Spafford, by providing compensation

for past and future nonpecuniary losses resulting from the unlawful practices complained of in

paragraphs 9 and 10 above, including emotional pain, suffering, inconvenience, loss of

enjoyment of life and humiliation, in amounts to be determined at triaL

J.

Order Defendant EDi to make whole Karla Spafford, by providing compensation

for past and future nonpecuniary losses resulting from the unlawful practices complained of in

paragraphs 9 and 10 above, including emotional pain, suffering, inconvenience, loss of

enjoyment of life and humiliation, in amounts to be determined at trial.

K. Order Defendant Shaw to pay Karla Spafford punitive damages for its malicious

and reckless conduct described in paragraphs 9 and 10 above, in amounts to be determined at

trial.

L. Order Defendant EDi to pay Karla Spafford punitive damages for its malicious

and reckless conduct described in paragraphs 9 and 10 above, in amounts to be determined at

5

Case 4:06-cv-01063-FRB Document 1-1 Filed 07/17/2006 Page 6 of 6
trial. M. Grant such further relief as the Court deems necessary and proper in the public
interest. N. Award the Commission the costs of this action. JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted, JAMESL.LEE Deputy General Counsel GWENDOLYN YOUNG REAMS
~~ R6B~cuilNS6N rJ01
Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION St. Louis District Office Robert A. Young Federal Building 1222 Spruce, Room 8.100 St. Louis, MO 63103 (314) 539-7918
6

 
 Case 4:06-cv-01063-RWS Document 16 Filed 10/23/2006 Page 1 of 4

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

EQUAL EMPLOYMENT

)

OPPORTUNITY COMMISSION,

)

)

&

)

)

KARLA SPAFFORD,

)

)

Plaintiffs,

)

)

vs.

)

)

SHAW ENVIRONMENTAL, INC.

)

)

&

)

)

ENVIRONMENTAL DIMENSIONS, INC.)

)

Defendants.

)

Case No. 4:06CV01063 RWS JURY TRIAL DEMANDED

COMPLAINT

COMES NOW Plaintiff-Intervenor Karla Spafford (“plaintiff intervenor”), by and

through her attorneys, and for her Complaint against Shaw Environmental, Inc. (“Shaw”)

(collectively “defendants”), states as follows:

1. Plaintiff-Intervenor Karla Spafford brings this action for legal and equitable

relief to redress the injuries done to her by defendants.

2. Plaintiff-Intervenor brings her complaint under §706(f)(1) and (3) of Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C., §2000e-5(f)(1) and (3) (“Title VII”)

and Section 102 of the Civil Rights Act of 1991, 42 U.S.C., §1988a. Jurisdiction of this

Court is invoked pursuant to 28 U.S.C., §5, 451, 1331, 1337, 1343 and 1345.

1

Case 4:06-cv-01063-RWS Document 16 Filed 10/23/2006 Page 2 of 4
3. The unlawful employment practices complained of herein were committed within the Eastern District of Missouri.
4. Plaintiff-Intervenor Karla Spafford is a female citizen of the United States, who, at all times relevant herein, resided in Missouri.
5. At all relevant times, defendant Shaw, a Louisiana Corporation, has continuously been doing business in the State of Missouri and the City of Bridgeton, and has continuously had at least fifteen (15) employees.
6. At all relevant times, defendant Shaw has continuously been an employer engaged in an industry effecting commerce within the meaning of §§701(b)(g) and (h) of Title VII, 42 U.S.C., §§2000e(b), (g) and (h).
7. At all relevant times, defendant EDI, a New Mexico Corporation, has continuously been doing business in the State of Missouri and the City of Bridgeton, and has continuously had at least fifteen (15) employees.
8. At all relevant times, defendant EDI has continuously been an employer engaged in an industry effecting commerce within the meaning of §§701(b)(g) and (h) of Title VII, 42 U.S.C., §§2000e(b), (g) and (h).
9. Since at least January 2001, defendants Shaw and EDI have engaged in unlawful employment practices at Shaw’s Bridgeton cleanup site, in violation of §§706(f)(1) and (3) of Title VII, 42 U.S.C., §§2000e-2(a)(1) and (2) by selecting plaintiff Karla Spafford for layoff over less qualified and experienced male senior technicians because of her sex, female.
10. Since at least January 2001, defendants Shaw and EDI have engaged in unlawful employment practices at the St. Louis cleanup sites, in violation of §§706(f)(1) and
2

Case 4:06-cv-01063-RWS Document 16 Filed 10/23/2006 Page 3 of 4
(3) of Title VII, 42 U.S.C., §§2000e-2(a)(1) and (2) by selecting Karla Spafford for layoff over less qualified and experienced male senior technicians in retaliation for her filing a Title VII lawsuit against her previous employer, who is also one of the sub-contractors at the cleanup site.
11. The effect of the practices complained of above have deprived plaintiff Karla Spafford of equal employment opportunities and otherwise adversely affected her status as an employee because of her sex.
12. The unlawful employment practices complained of above were intentional. 13. The unlawful employment practices complained of above were done with malice and reckless indifference to the federally protected rights of plaintiff Karla Spafford. 14. As a result of defendants’ aforementioned conduct, plaintiff has lost compensation and benefits of employment, has suffered emotional pain, suffering, humiliation, embarrassment, mental anguish and loss of enjoyment of life. 15. Defendants’ conduct was undertaken with malice and reckless indifference to plaintiff’s federally protected rights. 16. Plaintiff has incurred, and will continue to incur, attorney’s fees and costs in connection with this matter. WHEREFORE, plaintiff prays for judgment in her favor and against defendants for lost wages and other benefits of employment, front pay, compensatory damages, punitive damages, appropriate injunctive relief; prejudgment interest, attorney’s fees and costs, and for such additional relief as this Court deems appropriate.
3

Case 4:06-cv-01063-RWS Document 16 Filed 10/23/2006 Page 4 of 4 Respectfully Submitted, UTHOFF, GRAEBER, BOBINETTE & BLANKE By: /s/ Charles W. Bobinette Charles W. Bobinette, #9806 Attorneys for Plaintiff Karla Spafford 906 Olive Street, Suite 300 St. Louis, Missouri 63101 Telephone: (314) 621-9550 Facsimile: (314) 621-2697 Email: cbobinette@ugbblaw.com
4

 
 Case 4:06=cv=01063=RWS Document 23 Filed 01/17t2007 Page 1 of 5 Case 4:06ocw01063=RWS Document 22 Filed 01/15/2007 Page 1 of 5

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

and

KARLA SPAFFORD,

Case No. 4:06CV01063 RWS

Plaintiff/I ntervenor,

VS.

SHAW ENVIRONMENTAL, INC.,

SHAW GROUP, INC.,

SHAW ENVIRONMENTAL &

INFRASTRUCTURE, INC.,

STONE & WEBSTER, INC., and

ENVIRONMENTAL DIMENSIONS, INC.)

)

Defendants.

)

JURY TRIAL DEMANDED

PLAINTIFF/INTERVENOR’S FIRST AMENDED COMPLAINT COMES NOW Plaintiff-lntervenor Karla Spafford (hereinafter "Spafford"), by and

through her attorneys, and for her first amended complaint against Shaw Environmental,

Inc. ("Shaw Environmental"), Shaw Group, Inc. ("Shaw Group"), Stone & Webster, Inc.

("Stone & Webster’’), Shaw Environmental & Infrastructure, Inc. ("Shaw E&I") (collectively

"Shaw") and Environmental Dimensions, Inc., ("EDi"), (collectively "defendants") states as

follows: 1. Spafford brings this action for legal and equitable relief to redress the injuries
done to her by defendants.

Case 4:06-cw01063-RWS Document 23 Filed 01/17t2007 Page 2 of 5 Case 4:06ocw01063-RWS Document 22 Filed 01/15/2007 Page 2 of 5
2. Spafford brings her complaint under §706(f)(1) and (3) of Title VII ofthe Civil Rights Act of 1964, as amended, 42 U.S.C., §2000e-5(f)(1 ) and (3) ("Title Vl I") and Section 102 of the Civil Rights Act of 1991,42 U.S.C., §1988a. Jurisdiction of this Court is invoked pursuant to 28 U.S.C., §5, 451, 1331, 1337, 1343 and 1345.
3. The unlawful employment practices complained of herein were committed within the Eastern District of Missouri.
4. Spafford is a female citizen of the United States, who, at all times relevant herein, resided in Missouri.
5. At all relevant times, defendant Shaw Group, a foreign corporation, is the parent company of defendant Shaw E&I, a foreign corporation, which is the parent company of Shaw Environmental, a foreign corporation, all of which have continuously been doing business in the State of Missouri in the City of Bridgeton and the City of St. Louis and have continuously had at least fifteen (15) employees.
6. At all relevant times, defendant Shaw Group was the parent company of defendant Stone & Webster, Inc., a foreign corporation, which was the predecessor to Shaw Environmental forwork performed and business conducted in the State of Missouri in the City of Bridgeton and the City of St. Louis and has continuously had at least fifteen (15) employees.
7. At all relevant times, defendant EDi, a New Mexico Corporation, has continuously been doing business in the State of Missouri in the City of Bridgeton, and has continuously had at least fifteen (15) employees.
8. At all relevant times, defendants have continuously been an employer engaged in an industry effecting commerce within the meaning of §§701 (b)(g) and (h) of
2

Case 4:06-cw01063-RWS Document 23 Filed 01/17t2007 Page 3 of 5 Case 4:06ocw01063-RWS Document 22 Filed 01/15/2007 Page 3 of 5
Title VII, 42 U.S.C., §§2000e(b), (g) and (h). 9. In or about February 2000, Spafford was hired by defendant EDi, subject to
approval of defendants Shaw, and continued to work under the control of defendants until she was terminated in April 2003.
10. Since at least August 2000, defendants engaged in unlawful employment practices in Missouri, in violation of §§706(f)(1) and (3) of Title VII, 42 U.S.C., §§2000e2(a)(1) and (2) in subjecting Spafford to disparate treatment, as compared to male employees and a hostile work environment because of her sex, female, by including but not limited to, not permitting Spafford to work on weekends, scrutinizing and criticizing her work activities, attempting to develop information against her to support her termination, subjecting her to assaults, threats, abusive language and property damage, failing to investigate her complaints of harassment and discrimination, directing fellow employees not to talk to her or assist her with the performance of her job duties, assigning her to isolated work areas, not providing herwith adequate bathroom facilities, refusing to provide her a private dressing room and/or locker room, setting her up to fail on a written radiological technical test and permitting a male employee to take the test home, transferring a male employee who failed the test to another subcontractor and selecting Spafford for layoff in April 2003 over less qualified and experienced male senior technicians.
11. Since at least August 2000, defendants have engaged in unlawful employment practices in Missouri, in violation of §§706(f)(1) and (3) of Title VII, 42 U.S.C., §§2000e-2(a)(1) and (2), in retaliation for her filing a Title VII lawsuit against her previous employer, Corvera Abatement Technologies, Inc., who is also one of the subcontractors
3

Case 4:06-cw01063-RWS Document 23 Filed 01/17t2007 Page 4 of 5 Case 4:06ocw01063-RWS Document 22 Filed 01/15/2007 Page 4 of 5
at Shaw’s job location and for making complaints of discrimination against defendants, by including but not limited to, not permitting Spafford to work when Corvera Abatement Technologies, Inc. was onsite, by scrutinizing and criticizing herwork activities, developing information against her to support her termination, directing fellow employees not to talk to her or assist her with the performance of her job duties, subjecting her to assaults, threats, abusive language and property damage, failing to investigate her complains of discrimination and harassment, assigning her to isolated work areas, not providing her adequate bathroom facilities, refusing to provide her a private dressing room and/or locker room, setting her up to fail a written radiological technical test and by selecting Spafford for layoff in April 2003 over less qualified and experienced male senior technicians.
12. Since April 2003, defendants have engaged in unlawful employment practices in Missouri, in violation of §§706(f)(1) and (3) of Title VII, 42 U.S.C., §§2000e2(a)(1 ) and (2) by refusing to rehire and/or recall Spafford from layoff because of her sex, female.
13. Since April 2003, defendants have engaged in unlawful employment practices in violation of §§706(f)(1) and (3) of Title VII, 42 U.S.C., §§2000e-2(a)(1) and (2) by refusing to rehire and/or recall Spafford from layoff, in retaliation for her filing a Title VII lawsuit against Corvera Abatement Technologies, Inc. and making complaints of discrimination against defendants.
14. The effect of the practices complained of above have deprived Spafford of equal employment opportunities and otherwise adversely affected her status as an employee because of her sex and in retaliation of her filing a complaint of discrimination.
4

Case 4:06-cw01063-RWS Document 23 Filed 01/17t2007 Page 5 of 5 Case 4:06ocw01063-RWS Document 22 Filed 01/15/2007 Page 5 of 5
15. The unlawful employment practices complained of above were intentional. 16. The unlawful employment practices complained of above were done with malice and reckless indifference to the federally protected rights of Spafford. 17. As a result of defendants’ aforementioned conduct, Spafford has lost compensation and benefits of employment, has suffered emotional pain, suffering, humiliation, embarrassment, mental anguish and loss of enjoyment of life. 18. Defendants’ conduct was undertaken with malice and reckless indifference to Spafford’s federally protected rights. 19. Spafford has incurred, and will continue to incur, attorney’s fees and costs in connection with this matter. WHEREFORE, Plaintiff/Intervenor Karla Spafford prays for judgment in her favor and against defendants for lost wages and other benefits of employment, front pay, compensatory damages, punitive damages, appropriate injunctive relief; prejudgment interest, attorney’s fees and costs, and for such additional relief as this Court deems appropriate.
Respectfully Submitted, UTHOFF, GRAEBER, BOBINETTE & BLANKE
By: Isl Charles W. Bobinette Charles W. Bobinette, #9806 Attorneys for Plaintiff Karla Spafford 906 Olive Street, Suite 300 St. Louis, Missouri 63101 Telephone: (314) 621-9550 Facsimile: (314) 621-2697 Email: cbobinette@ugbblaw.com

 
 Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff, and KARLA SPAFFORD,
Plainiff/Intervenor v. SHAW ENVIRONMENTAL, INC., and ENVIRONMENTAL DIMENSIONS, INC.,
Defendants.

)

)

)

)

)

)

)

)

)

) CIVIL ACTION NO. 4:06CV1063 FRB

)

)

) FIRST AMENDED COMPLAINT

)

)

)

)

JURY TRIAL DEMAND

)

)

NATURE OF ACTION This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation, and to provide appropriate relief to Karla Spafford who was adversely affected by such practices. As alleged with greater particularity in the Statement of Claims below, the Equal Employment Opportunity Commission (“the Commission”) alleges that Defendants Shaw Environmental, Inc. (“Shaw”) and Environmental Dimensions, Inc. (“EDi”) discriminated against Ms. Spafford, a female senior technician, on the basis of her sex. Furthermore, the Commission alleges that Defendants discriminated against her in retaliation for a previous discrimination suit brought by Ms. Spafford against a similar, nuclear cleanup company.
JURISDICTION AND VENUE

Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 2 of 6
1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337, 1343, and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.§ 2000e-5(f)(1) and (3) (“Title VII”) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.
2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for Eastern District of Missouri, Eastern Division.
PARTIES 3. Plaintiff, the Commission, is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant Shaw, a Louisiana corporation, has continuously been doing business in the state of Missouri and the City of St. Louis, and has continuously had at least 15 employees. 5. At all relevant times, Defendant Shaw has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h). 6. At all relevant times, Defendant EDi , a New Mexico corporation, has continuously been doing business in the state of Missouri and the City of St. Louis, and has continuously had at least 15 employees. 7. At all relevant times, Defendant EDi has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS

Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 3 of 6
8. More than thirty days prior to the institution of this lawsuit, Karla Spafford filed a charge with the Commission alleging violations of Title VII by Defendants Shaw and EDi. All conditions precedent to the institution of this lawsuit have been fulfilled.
9. Since at least February 2000, Defendants Shaw and EDi have engaged in unlawful employment practices at the St. Louis Airport cleanup site, in violation of Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. §§ 2000e-2(a)(1) and (2), by assigning Ms. Spafford to an isolated work area with no access to a bathroom or changing area, while male employees in the same position were provided both. Further, despite receiving above average performance evaluations, Ms. Spafford was selected to be laid off over other male senior technicians who were less qualified and less experienced.
10. Since at least February 2000, Defendants Shaw and EDi have engaged in unlawful employment practices at the St. Louis Airport cleanup site, in violation of Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-3(a), by directing her fellow employees not to associate with her and forbidding her from working on those days when the defendant in her pending discrimination suit was on site.
11. The effect of the practices complained of in paragraphs 9 and 10 above has been to deprive Ms. Spafford of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex.
12. The unlawful employment practices complained of in paragraphs 9 and 10 above were intentional.
13. The unlawful employment practices complained of in paragraphs 9 and 10 above were done with malice or with reckless indifference to the federally protected rights of Karla Spafford.

Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 4 of 6
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Shaw, its officers, successors, assigns, and all persons in active concert or participation with it from engaging in sex discrimination and retaliation and any other employment practice which discriminates on the basis of sex. B. Grant a permanent injunction enjoining Defendant EDi, its officers, successors, assigns, and all person in active concert or participation with it from engaging in sex discrimination and retaliation and any other employment practice which discriminates on the basis of sex. C. Order Defendant Shaw to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of this past and present unlawful employment practice. D. Order Defendant EDi to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of this past and present unlawful employment practice. E. Order Defendant Shaw to make whole Karla Spafford, by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices. F. Order Defendant EDi to make whole Karla Spafford, by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices. G. Order Defendant Shaw to make whole Karla Spafford, by providing

Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 5 of 6
compensation for past pecuniary losses resulting from the unlawful employment practices described in paragraphs 9 and 10 above, in amounts to be determined at trial
H. Order Defendant EDi to make whole Karla Spafford, by providing compensation for past pecuniary losses resulting from unlawful employment practices described in paragraphs 9 and 10 above, in amounts to be determined at trial.
I. Order Defendant Shaw to make whole Karla Spafford, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 9 and 10 above, including emotional pain, suffering, inconvenience, loss of enjoyment of life and humiliation, in amounts to be determined at trial.
J. Order Defendant EDi to make whole Karla Spafford, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 9 and 10 above, including emotional pain, suffering, inconvenience, loss of enjoyment of life and humiliation, in amounts to be determined at trial.
K. Order Defendant Shaw to pay Karla Spafford punitive damages for its malicious and reckless conduct described in paragraphs 9 and 10 above, in amounts to be determined at trial.
L. Order Defendant EDi to pay Karla Spafford punitive damages for its malicious and reckless conduct described in paragraphs 9 and 10 above, in amounts to be determined at trial.
M. Grant such further relief as the Court deems necessary and proper in the public interest.
N. Award the Commission the costs of this action. JURY TRIAL DEMAND

Case 4:06-cv-01063-RWS Document 302 Filed 045/024/2007 Page 6 of 6
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted,
ERIC DREIBAND General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
/S/ Robert G. Johnson ROBERT G. JOHNSON Regional Attorney
/S/ Barbara A. Seely BARBARA A. SEELY Supervisory Trial Attorney
/S/ Jan Shelly JAN SHELLY MO Bar No. 42085 Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION St. Louis District Office Robert A. Young Federal Building 1222 Spruce, Room 8.100 St. Louis, MO 63103 (314) 539-7918
Issues: 1.) Correct Sections [706(f)(1) and (3)] for the claims?? 2.) Correct relief asked for, especially when not monetary? Are we asking for any affirmative
relief? (I don’t think so) 3.) Are the correct parties being asked for the right relief? Is Shaw the only retaliation
defendant? What would EDi be retaliating for?

 
 i
IN THE UNITED I!."TATE.$ DISTRICT COURT FOR THE EASTERN DIS1/RIcr OF MISSOURI
EASTERN D~SJON
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

and KARLA SPAFFORD,

v,
SHAW GROUP INC.., and :ENVIRONMENTAL DIMENSIONS, INC.,
Defimdanrs.

CaxNo. 4:06CVl 063 RWS

CONSENTP~

i IDtnll:bll:~oD

I

, Plainti. ffEqual

Emplo~

Oppottunity

C~!liO!1 ;

(htnitta.fblr

"EEOC")

instituted

this action alleging that Shaw Ol'Oup Inc. ~ "Shaw") and Environmental Dimensions, !

lnc. (herelDaftm' "EDi") di.scrimlna:ted against KarlaiSpaffOId in violation ofTitle VII of1he Civil
A*tt!
Rights Act 011964 and Title I oftht! Civil Rigbts of 1991 ("TItle: VIIW) by temIi1Ia1ing ber
vn. employment based on her sex and/or in retaliation protected activity under Title Karla

I
Spafford c-Spafford") was permitted by the Court t~ interVene, tbrou&b pri\'8t8 coun.sel.,. in the

EEOC's suit to &SBeft claims ~ Dcfendmus un~e:r Title VII.
Par pwposes ofseruement &lid compromise ~nlYt tbe EEOC, Spa.H01d and EDi
I
("Participating Parties") have advised the Court thatithey wish to msolve 1he i.Dstant ccmtroversy
without b: expc:nse. delay, and lnudCDl affurther Utifgation.

!
i

c04 THEREFORE, it ill the ftndiD,g of'this

made on the plca.di:D,gs and on the record s.s

a whole aDd upon agreement ofme Participating Patties, that: (i) this Courll:w jurisdiction over
(~i) the pattiL':!I to and the subject /WItter of thUllWtion, the requiJ'emeafa of Title VII will be
(+> catrled out by the implementation cftbis Dectee, this Declee iii intended to and does resolve

Dectte aU matters in comroveny in this lawsuit or /Hrectly :k1ated tQ this lawsuit among the

Participating Parties, and (Iv) the terms of this

colJStitutc a fair and equitable settlement

j

of aU issues in this lawsuit.

,

I
IT IS THEREFORE ORDRRBD, ADJUOO~m, AND DBCREED as follows:

I. General P~i.iIJR~
I
1. This Dec:tee, being em:ered wtth the ~t ofthe Plir:'tidpatiQg Parties for

11.. purposes ofsettlement. EDi denies any allegation ~f !l violation 01any applicable law, executive

order. stIItut..a.11Jle, ~tion or oontra.c\ made

EDi by the EEOC or Spafford. [t shall

i

:not be deemed an admi8!lion ofliability or ofa violljtiou ofTitle VII or any other !IJlPlicable law,

Ff executive order, statute, rule, nlgWatiOll. or conlIact 8Il)' kind.

2. EDl shall not UDlawfully disctiminat~ against its employees with resped: m hiring,
I
promotion, tiring, co.mpenaation, aclleduling or oth~ terms, oouditiOlUl or privilegu of

employment because of sender.

reta1ii :3. EDi .dlall not discritlililate or

I
Ilgainat any ])ttIIOJl 'becauao he or she: (a)

has opposed any practices alleged in this lawsuh as ~w1Ul under Title VD, (b) has panicipllted

in say investigation cOll.duC1ed UIl.deT Title VII ~cr.ed with or lCfldio.a \IP to this laW1!uit; (c)

hall panieiJlll1M in this lIlWllUit; or (d) hu benefited ~ will benefit in any way 11/1 B result ofthls

Coasent .Dec;;ree.

i
i
U. Relleffor cujrgtng Party

4. Onot before 1I1e latc:r ofAugust 10. iOO7, or within five (5) bUlliness days afEDi

I

.

and Spaffimi entering into a Set:Ilement Agx'eemeo.t,tEDi shall fonvartJ to Spafford's eounsel.

attome:r I
Charles Bobinctt.e, It check made jointly payable to $pafford and her

in !:he II1!1mmt of

(;:~ood-..--~~r~-"'1t~nc-(liIIiIl}(S2:iS(J81lJX)C

2

!

S25,000. On or before October 10, 2001,IIDi shalliforward a second check 10 Mr. Bobmette !
made payable joiutly to Spafford Md het attorney Uf the amount ofS20,OOO.

5.

oftrf Defendant shall forward a copy

cheeks referenced in Paragraph 4 above, to

Opportuflty the Regional Attorney. t.:qual Employment

Commission, 1222 Spruc::e. Room 8.100,

I
St. Louis, Missouri 63103, on or about the SlIme da~ that each check is seln to Mr. Bobinette.

IIL~g
cntnl 6. Within sixty (tiO) days after the ofthill Decree.1IDi shall provide msmdatory

Title

VII

mtinlng

for

alJ

of

Its

.IDlID!Iger5

and

I
superviSOll>

in

the

St.

Lew

area.

The content of this

PflMde I

t:ra.l.nhls sllllll inolulie lin employers obligation to

rompamble work conditions for female

i
and male employees. It shall also rove{ the employpc's obligations not 10 rr:uili1lUl against any
employee for tiling suits. ~ complainbi.. QI' opfilsing unlawtW employment activity

pursuant to Trtle vn. Tho tTIIining will be providedj by an outside c:on!Iacto.r ofDefeudant's i
choosing who wm submit its traini1lg 1'IllIblrials to tl/e Regio:o.s1 Attorney of the EEOC's St. Louis

DistriIOt Office, for approval not Iatcr'than 10 days #or to the training.

7.

br Within thirty (30) days ofproviding Title VII training pursuant to Paragraph

I
6, EDi shall send 10 the EEOC's Rogiomll Attorney ~ itl S1. Lou.is Office B report liBting the

uames and job titles of all U18I1Ilgttl'S who compl~ the training.

lV. POiltiDl aD~ PolieJel

,fthis 8. Within tbitty (30) days ofthe entry

Decree, EOi sball post and cause to

J :remain. posted copies ofthe noUa: attal:hed hereto Exhibit A. lit any of it!i st. Louis work sites,

Pfiodi

in locations publioly visible to all employees tOr a

oftwo (2) years starting ftom the date

of entry ofthis Decree.

, , i

9. Wilhin thl:rty (30) days oft:he entry ~fthl6 D~ree, EDi shall cause the policy

rre4+dent. attached hereto 8.9 Exhibit B to be signed by its

Exhibit B shall be made a part ofthe

t:r:aining %1'J1im'ed to in PZIIlI,gIap.h (5 above IUld shlllJ made a parr of ~II \llrittl.m

pc:rsomIcl policies within thn:e (3) mOlTfbs ofthe ~ , ofthi. Decree,

I
I

cm...-"""-"~.wI-m.N....a~\T_ _'I~Coauo<_~(S2lSQII).IlQC

3

i

v. Repc!rtillg, Reeord-tpblg, ad Access

10. Within three (3) IIlOllIlul ofthe entryrfthis Demee,.EDi !hllll prepare and submit

to the EEOC'II Ragional AttonlllY in itS St. Louis Dijstric:t Office a letter indicati.nS as follows:
a. That Exhibit A has been postfIld as required by PIU"IIgI'IIph 8, above;

b. TbJrt the t:I'Ilining requited by ~81'8graph 6 above has been completed;. and
c. Tba! Exhibit B has been si~ as required by p~ 9 above.

hlltry 11. Wilmn six (6) months ofthe date of oft.bili Decree and every six (6) manthR

repare I
tlI.eteaft« for the duration oftbis d.oorce, EDi !hall

and submit to the EEOC's Regional

Attorney in its St. Lews Office, II IVpOrt listing the ,arne of each applicant or employeel at any of I
its st. Louis work sites. who complalned of discrimfnation based on hislher sender or in
'fitlelI
n:taiilltioo for taking & proteo1J;d 1WIl0ll P1..lmlll1lt 10 VII. the dllte Md nature ofsuch

complaint, tho outcome of Defendant's investigati04 and the nature of relicf provided, ifany.

12. Dw:ing the term of this D~. Wi +twl allow re:pre!lentatives ofthe
I
Commission to revi~ its oompliaace with this ~ by ~ ami plwtooopyin,g relevant

41t1l1M. ~tIi and reootds, interviewing employees

g(l;lI1el1t o1flcials on tbJ:ir prcmilIes, and

i.nspectins their pn:mi8es. Such review ofoompUmr shall be; initiab:d by writtel! notice: ttl

EDi's attorney ofltlCQJd. Vaoce Miller iJld Micba.el!Kass (via facsimile: 314-621-S06.5), with a

J

i

copy 10 Mike BrsdM\aw, Vice Ptesid_ <liEDi (YiajfllCaimil": 50S-341-3579) at least five (5)

bu!lnCS3 days in advaDCe orany impection ofDefeddant's dOCUIll.flllts or pnmrlses.

mrc VI. TiIIl"Ift ll1ld

I
of Decree

1:3. The term ofthis Decree shall be two~2) years.
14. By entering into this Decree, the ~~ parties do not intmd to resolve any
i clw:gl!!ll of discrir.nlnatiOl1 cummtly pending before ~ Cmn.mi.ssion ather than the cbar~ that
created the procedUIBl foundati~ for the Comp~ in this case. lS. This Decree shall be binding upon ~ perticiparlag parties hereto, their successot'S .
and assigDll. EDi shall affirmatively notify lillY ~ , ofEDi ome obligations ofthis
Consent Decree prior to 1m)' sale which may take P!fce.

C~-~'1.E1)l.~ __T~_~D<cn.(""""(>.Zi<""I).ooc

4

I

I
I 16. The Court shall retain j1lrisdie\iou o~this (;II.U5e for ptD'pOIH of compliaz:u;e and
i
i 17. Ex.cept at otherwise stated in P~ph 4, ea.eh party Iludl beat its own COllta IIIld
i

BY CONSENT:
FOR DEFENDAA'T:
~~)

FOR~F:
i
EQU~ EMPLOYMENT OPPORTIJNfIY COMlfSSION
i I

Jan5hflIy
AttogrIm for PIaintiffBEOC st. . Distriet Office Robert A. Young Fedcni.I Bldg.
1222 spruce. Room 8.100
Sf.. Lo~ MiS!lOUri 63103 (314) 39-7916 (314) 39-71i9j Fac!imile
~~
Karla
I !
5

I
EXIIIBI'f A
(On Company l~&d)

NOTICE TO ~PLOYEES

I
I
Fed=!.llaw probibits d.i5erimi.nai:ion against lany employee or applicant for employment
br beCause ofaend.e:r Dr in ma.liati0D !or com,plainiDa 5\U:h di~on. Applicants or i
employ1ilell may not be discrimitIfttM Il8IIinSt based ~ gendl!T with respect to hiring. promotion,
I
firing. compen&atiOll, or other ter.ma. conditions or Jovi1eaes ofemployment. Title vn also
I
prohibits 'R:'taIiation against c:mp]oYile$ because thC3\ have opposed practices tbcy believe:

dillirim.inale on the buiJ of gender or be:cause they!have filed ch.ll.rKcs with the EEOC or I
panioipl!U!d in or cooperated with an llEOC investiJfation.

Environmental Dimensirms, Inc. is commi~ to complying with such tedera1law in all
respects rui.d willllOt diacri.mh:l.ato against IIppll~ II[ld cmploYOlilS bocause of aendCl' md. win

not take any action against employees because they ~ve e:xerc.ised their right:! under the law.

~;Io7

~.. J

i

c.:~alI'1~.JI)1-1iNI1.-I~r~ .....,J~n.-(fiooIl(1:j354.m).l:>OC

6

I

I

i

!

I
I
I
EXHlB'TB
I
POlJC\' AGAINST GENDER Dl~ATlON Alii» RETALIATION

1
ApJ)licants and employees will be not be dis~ed. api.n!It based on their ge:(lder or in

remliation for apposing practices they believe discnrnate on the basjs of sex or be<:ause they

bave :filed cbargos with 1he EEOC or parti.cipat.ed inlor cooperated with an EEOC Investigation.

Employees are free to tcpott \nsUlnces ofporib1e sex dlscrlminadon or reralJallon to any

ma.oagement offici.al at. any time Or by calliug V~ Smith, Human Resou:rces Department,
an4I
at. (505) 341-3578. EDi baB estlJblillhed policiell prooedurtl!! to promplly invCIltigate such

tepoftsi

reports and to protect the perSODS making such

from retaliatioo. Employees also an:: free

fscriminatioo, I
to make in.quirles or complaints about posiiible sex.

IICIlI'.lIlI.llmrassment" or

re!&liatiQII to the EEoc, St. Louis District Office, lin Spruce, 8th Floor, Room 8.100, St.

Low~ Missouri. 63103, 314-539-1800.
I
~~)

I
I
i
i
i
t
I
I
I
I
i
I
I
I
!
i

I

I

I

I

C::~lIIIIlicIIIoIo~.mr.~8ooU1I\TIiII""IIY'-~~~Do.:.oo(A...l)lm"-'JI).DOC

7

,,I

 
 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

Plaintiff,

)

)

vs.

)

)

KARLA SPAFFORD,

)

Intervenor,

)

)

vs.

)

)

SHAW ENVIRONMENTAL, INC., et al., )

)

Defendants.

)

Case No. 4:06CV01063 RWS

MEMORANDUM AND ORDER This matter is before me on Plaintiff’s Motion to Dismiss with Prejudice [#46]. Plaintiff, Equal Employment Opportunity Commission, and Plaintiff/Intervenor, Karla Spafford, through their respective counsel, move to dismiss with prejudice all claims brought against the various defendants, The Shaw Group, Inc., Shaw Environmental, Inc., Shaw Environmental and Infrastructure, Inc. and Environmental Dimensions, Inc., in their entirety, with all the parties bearing their own costs and attorneys’ fees. The parties also request that I expressly retain jurisdiction over this case for a period of two (2) years for the limited purpose of hearing and resolving disputes and claims arising out of or relating to the interpretation or enforcement of the Consent Decrees entered into between the parties. I will grant this motion in its entirety. Accordingly, IT IS HEREBY ORDERED that Plaintiff’s Motion to Dismiss with Prejudice [#46] is GRANTED.

IT IS FURTHER ORDERED that I will expressly retain jurisdiction over this case for a period of two (2) years for the limited purpose of hearing and resolving disputes and claims arising out of or relating to the interpretation or enforcement of the Consent Decrees entered into between the parties.

Dated this 8th day of November, 2007.

_______________________________ RODNEY W. SIPPEL UNITED STATES DISTRICT JUDGE

2

 
 Case 4:06-cv.Q1063-RWS Document 43 Filed 0911812007 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

EQUAL EMPLOYMENT

)

OPPORTUNITY COMMISSION,

)

)

Plalntilr,

)

)

and

)

)

KARLA SPAFFORD,

)

)

Plalntllfllblervenot, )

)

v.

) C... No.: 4:06CV106J RWS

)

SHAW ENVIRONMENTAL,INC.

}

)

and

)

)

ENVIRONMENTAL DIMENSIONS, INC., )

)

Der.ndan"'. )

CONSENT DECREE IDtrodoctlon

Plaintiff Equal Employment Opportunity Commission (hereinafter "EEOC") instituted

this ""tion alleging that Shaw Environmental. Inc. (hereinafter "Shaw") ""d Environmental

DimensiOns, inc. (hereinafter "EDi'') discriminated against Karla Spafford in violation of Title

vn of the Civil Rights Act of 1%4 and Title I of the Civil Right. Act of 1991 (''Title VIr') by

terminating her employment based on her sex and/or in retaiiation for protected activity Wlder

Title Vn. Karla Spafford ("Spafford") was permitted by the Court 10 intervene, t1nough private

counael, in the BEOC's suil to ..sert claims against both dctimdanlll under Title vn.

Case 4:06-cv-01 063-RWS Documen! 43 Filed 0911812007 Page 2 of 6
For purposes of settlement and compromise only, Shaw, Spafford and the EEOC have
advised the Court that they wish to n:solve the instant controversy without the expense, delay,
and burden of further litigation; THEREFORE, it is the finding of this Court, made on the pleadings and on the record as
• whole and upon agreement of the parties, thet: (i) this Court has jurisdiction over the parties to and the subject matter of this action, (ii) the requirements ofTitle VII will be carried out by the implementation of this Decree, (iii) this Decree is intended to and does resolve all matters in controversy in this lawsuit among Shaw, Spafford and the EEOC, and (iv) the terms of this Decree constitute a fair and equitable settlemertt of all isaues between Shaw, Spafford and the EEOC in thi.lawsuit.
IT IS THEREFORE ORDERED. ADJUDGED, AND DECREED as follows: I. General Provfslon.
1. This Decree, being entered with the consent of Shaw, Spafford and the EEOC fur the purposes of settlemen~ shall not constitote an adjudication on the merits of this lawsuit and sban not be construed as an admission by Shaw that it violated any statute, executive order, regulation or common law, including but not limited ro Title Vll, or that any of the allegations or claims raised in this action were meritorious.
2. Shaw agrees that it shall continue ro act in accordance with the applicable employment laws and, therefore, shall not diseriminate against its employees with respect to hiring. promotion, firing, compensation, scheduling or other tetm&, conditions or privileges of employment because of gender.
3. Shaw agrees thaI it shall continue to act in accordance with the applicable employment laws and, therefore, shall not discriminate or retaliate agaillllt any peraon because be
2

Case 4:06-cy-01003-RWS Document 43 Filed 09/1812007 Page 3 of 6
0, .he: (a) bas opposed any pr.u;tices alleged in this lawsuit as unlawful Wider Title VII; (b) has participated in any Investigation conducted WIder Title Vl! connected with or leading up to this lawsuit; (c) bas participated in thi' lawsuit; or (d) bas benefited or will benefit in any way as a result ofthi, Consent Decree.
II. Relief for Cha1"Jllng Party 4. Within thirty (30) days following the entry of this Decree, Shaw shall submit to Spafford'. counscl, Charles Bobininette, the agreed-upon settlement amoWlI of fifty IhoU8and dollars ($50,000.00) pursuant to, and contingent upoo, the terms of a separate Settlement Agreement and General Releas. entered into between Shaw aod Spafford, of which the EEOC i. not a party. 5. Shaw shall forwan! copies of the settlement checks submitted to Spafford's counsel 10 the Regional Attorney, Equal Employment Opportunity Commission. 1222 Spruoe, Room 8.100, SI. Louis, Missouri 63103.
m, Tninlng
6. Within sixty (60) days following the entry of this Decree, Shaw shall provide mandatory Title VlI training to .11 ofil. managers aod supervisors at the SI. Louis Airport Site (SLAPS) regarding an employer'. obligation to provide comparable work conditions for female and male employ... and to not retaliate against any employee for engaging in protected activity or for opposing an unlawful employment practice under Title VII. A. part of this training, Shaw will redistribute to its mansgers and supervisors copies of its polici.. relating to equal employment opportunity. The materials to be U8ed in that training will be submitted in advance for approval by the Regional Attorney for the EEOC', SI. Louis District Office.
3

Case 4:06-cv-01063-RWS Document 43 Filed 09/18/2007 Page 4 of 6
7. Within thirty (30) day. after providing the training descn1led in Paragraph 6, Shaw shall submit to tbe Regional Attorney for the EEOC's St. Louis District Office a report listing the names and job titles of all managers and supervisor1l who completed the training.
IV. Pootlagllld Policies S. Shaw shall continue to poot all required equal ernploynlent opportunity po.t"", .t the SLAPS site and at all other locations where such po.1er1I are required. 9. Within thirty (30) days followins the entry of this Decree, Shaw shall submit to the Regional Attorney for the EEOC'. Sl Loui. District Office for approval a copy of its written equal ernploynlent opportunity policy, which will be addressed and distributed in the training referred to in Paragraph 6, and will continue to be a part of its personnel policies. Following approval, Shaw will post a copy of its equal ernploynlent opportunity policy at the SLAPS site for the duration orthat project.
V. Compllan•• RevIew
to. During the term of this Decree, Shaw shall allow representatives of the EEOC to
take reasonable measures to ensure Shaw's compliance with this Deeree. Such measures may include inspecting and photocopying relevant documents and records, interviewing pertinent individuals, and inapecting their premises. aefore any such measures can be initiated, the EEOC must notify Shaw'. counsel in writing of the measures that tbe EEOC i. seekins to take and allow Shaw's coun..1the opportunity to address the reasonableness of these measures.
VI. Term and ElJeet ..fDecree I t. The term of this Deeree shall he for a period oftwo (2) years or for the duration of time tha, Shaw continues to perfonn work on the SLAPS or SLDS sites, whichever OCCUr1l earlier.
4

Case 4:06-cv-01063-RWS Document 43 Filed 0911812007 Page 5 of 6
12. By entering into this Decree, Shaw IIIld the EEOC do not intend to resolve MY charges of discrimination currently pending before the Commission other tIum the charge that created the procedural foundation for the complaint in Ibis c....
13. The Court shall retain jurisdiction of Ibi. case for the purposes of compliMce and enforcement.
14. Shaw, Spafford and the EEOC shan bear their own casU and attorney's f....

b

9 - ~ SO ORDERED ON TIllS (dayor;

~ ,2007.

o LE ODNEYW.
UNITED STAT DISTRICT COURT BY CONSENT:

5

Case 4:06-cv·Ol063·RWS Document 43 Filed 09118/2007 Page 6 of 6

FOR SHAW ENVIRONMENTAL, INC.
By: (J g~ CRAIG I. HOEFE Polsinelli Shalton Flanlgan Sueltbaus 7733 Forsyth Boulevard, 121h Floor Clayton, Missouri 63105 (314) 727-7676 F",,: No. (314) 727·7166 choefer@po!sine16.com

FOR THE EQUAL EMPLOYMENT

OPPOJ.y'UNITY COMMISSION

By:

(~
I A

:(Ju..)

~.~

JEANP.KAMP

Acting KO\!ional Attorney

Supervisory Trial Attorney

FOR KARLA SPAFFORD

l ). By:

-.?~

CHARLIlS W. BOBlNB1TE

906 Olive Street

St. Louis, Missouri 63101 (314)621-9550

Fax No. (314) 621-2697 cbobinette@ugbblaw.oom

L or Trial Attorney ( EQUAL EMPLOYMEN COMMISSION 1222 Spruce Street, Rm. S.I00 81. Loui., Missouri 63103 (314) 539·7916

RTUNITY

6

 
 MOED - CM/ECF (LIVE) - Docket Report

https://ecf.moed.uscourts.gov/cgi-bin/DktRpt.pl?472602742161065-L_...

U.S. District Court Eastern District of Missouri (LIVE) (St. Louis) CIVIL DOCKET FOR CASE #: 4:06-cv-01063-RWS

CLOSED

Equal Employment Opportunity Commission v. Shaw Environmental, Inc. et al Assigned to: Honorable Rodney W. Sippel Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 07/17/2006 Date Terminated: 10/01/2007 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Barbara A. Seely EEOC 1222 Spruce Street Room 8.100 St. Louis, MO 63103 314-539-7910 Fax: 314-539-7895 Email: barbara.seely@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jan Shelly EEOC 1222 Spruce Street Room 8.100 St. Louis, MO 63103 314-539-7910 Fax: 314-539-7895 Email: jan.shelly@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert G. Johnson SEDEY HARPER, P.C. 2711 Clifton Avenue St. Louis, MO 63139 314-773-3566 Fax: 314-773-3615 Email: rjohnson@sedeyharper.com LEAD ATTORNEY

Melvin D. Kennedy EEOC

1 of 8

3/24/2008 3:40 PM

MOED - CM/ECF (LIVE) - Docket Report
V. Intervenor Plaintiff Karla Spafford
V. Defendant Shaw Environmental, Inc.
Defendant Environmental Dimensions, Inc.
2 of 8

https://ecf.moed.uscourts.gov/cgi-bin/DktRpt.pl?472602742161065-L_...
1222 Spruce Street Room 8.100 St. Louis, MO 63103 314-539-7910 Fax: 314-539-7895 Email: melvin.kennedy@eeoc.gov ATTORNEY TO BE NOTICED
represented by Charles W. Bobinette UTHOFF AND GRAEBER 906 Olive Street Suite 300 St. Louis, MO 63101 314-621-9550 Fax: 314-621-2697 Email: cbobinette@ugbblaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Craig J. Hoefer POLSINELLI AND SHALTON, P.C. 7733 Forsyth Boulevard 12th Floor St. Louis, MO 63105-1814 (314) 889-8000 Fax: (314) 727-7166 Email: choefer@polsinelli.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Michael B. Kass ARMSTRONG TEASDALE, LLP One Metropolitan Square Suite 2600 St. Louis, MO 63102-2740 314-621-5070 Fax: 314-621-5065 Email: mkass@armstrongteasdale.com ATTORNEY TO BE NOTICED
Russell C. Riggan
3/24/2008 3:40 PM

MOED - CM/ECF (LIVE) - Docket Report

https://ecf.moed.uscourts.gov/cgi-bin/DktRpt.pl?472602742161065-L_...

Defendant Shaw Environmental, Inc.
Defendant Shaw Environmental & Infrastructure, Inc. Defendant Stone & Webster, Inc. Movant Karla Spafford TERMINATED: 10/23/2006

LEWIS RICE 500 N. Broadway Suite 2000 St. Louis, MO 63102-2147 314-444-7784 Fax: 314-612-7784 Email: rriggan@lewisrice.com TERMINATED: 05/14/2007
Vance D. Miller ARMSTRONG TEASDALE, LLP One Metropolitan Square Suite 2600 St. Louis, MO 63102-2740 314-621-5070 Fax: 314-621-5065 Email: vmiller@armstrongteasdale.com ATTORNEY TO BE NOTICED
represented by Craig J. Hoefer (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Charles W. Bobinette (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 07/17/2006

# Docket Text
1 COMPLAINT against Defendants Shaw Environmental, Inc. and Environmental Dimensions, Inc. filed by the Equal Employment Opportunity Commission with Jury Demand. Waivers issued 2, Consents issued 3, Disclosure of Corporate Interest issued to Shaw Environmental, Inc. and Environmental Dimensions, Inc.. (Attachments: # 1 Civil Cover Sheet # 2 Original Filing Form)(CDD, ) (Entered: 07/18/2006)

3 of 8

3/24/2008 3:40 PM

MOED - CM/ECF (LIVE) - Docket Report

https://ecf.moed.uscourts.gov/cgi-bin/DktRpt.pl?472602742161065-L_...

07/17/2006 08/23/2006 09/11/2006 09/11/2006
09/12/2006 09/12/2006 09/12/2006 09/12/2006 09/19/2006 09/20/2006
09/25/2006 09/28/2006 10/05/2006 10/11/2006 10/23/2006

WAIVER of Service issued for Defendants Shaw Environmental, Inc. and Environmental Dimensions, Inc.. (CDD, ) (Entered: 07/18/2006)
2 ENTRY of Appearance by Craig J. Hoefer for Defendant Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 08/23/2006)
3 MOTION for Extension of Time to File Answer re 1 Complaint, (through October 5, 2006) by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 09/11/2006)
4 ORDER IT IS HEREBY ORDERED that defendant Shaw Environmental, Inc.'s Motion for anExtension of Time to Answer or Otherwise Respond to Plaintiff's Complaint [Doc. # 3] isGRANTED.IT IS FURTHER ORDERED that defendant Shaw Environmental, Inc., shall have to andincluding October 5, 2006, by which to answer or otherwise respond to plaintiff's Complaint. Signed by Judge Frederick R Buckles on 9/11/06. (KXS, ) (Entered: 09/11/2006)
5 ENTRY of Appearance by Vance D. Miller for Defendant Environmental Dimensions, Inc.. (Miller, Vance) (Entered: 09/12/2006)
6 ENTRY of Appearance by Russell C. Riggan for Defendant Environmental Dimensions, Inc.. (Riggan, Russell) (Entered: 09/12/2006)
7 ANSWER to Complaint by Environmental Dimensions, Inc..(Riggan, Russell) (Entered: 09/12/2006)
8 DISCLOSURE OF CORPORATION INTERESTS CERTIFICATE by Defendant Environmental Dimensions, Inc.Parent companies: None., Subsidiaries: None., Publicly held company: None.,. (Riggan, Russell) (Entered: 09/12/2006)
9 CJRA ORDER (jgw). Judge Frederick R Buckles termed. Case reassigned to Judge Rodney W. Sippel for all further proceedings (JWJ, ) (Entered: 09/19/2006)
10 RULE 16 ORDER: This case is assigned to Track 2: Standard; Joint Scheduling Plan due by 10/18/2006; Rule 16 Conference set for 10/24/2006 11:00 AM in Chambers before Honorable Rodney W. Sippel; Signed by Judge Rodney W. Sippel on 9/20/06 (CMA) (Entered: 09/20/2006)
11 ORDER - IT IS HEREBY ORDERED that the Rule 16 Conference shall be reset for October 27, 2006, at 11:30 a.m. in the chambers of the undersigned. Signed by Judge Rodney W. Sippel on 9/25/06. (LAH, ) (Entered: 09/25/2006)
12 ORDER - Joint Scheduling Plan due by 11/2/2006. Rule 16 Conference reset for 11/9/2006 10:00 AM in Chambers before Honorable Rodney W. Sippel.Signed by Judge Rodney W. Sippel on 9/28/06. (ARL) (Entered: 09/28/2006)
13 ANSWER to Complaint (and Affirmative Defenses) by Shaw Environmental, Inc..(Hoefer, Craig) (Entered: 10/05/2006)
14 MOTION for Leave to Intervene Pursuant to Fed.R.Civ.P.24. by Movant Karla Spafford (Attachments: # 1 Certificate of Service)(Bobinette, Charles) (Modified on 10/12/2006 to Add Filer - CMA) (Entered: 10/11/2006)
15 ORDER - IT IS HEREBY ORDERED that Plaintiff-Intervenor's Motion for Leave to Intervene 14 is GRANTED. Signed by Judge Rodney W. Sippel on

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10/23/2006 10/23/2006 11/02/2006 11/03/2006 11/03/2006 11/09/2006
01/15/2007 01/17/2007
01/17/2007 01/19/2007 01/26/2007 01/29/2007

10/23/06. (ARL) (Entered: 10/23/2006)
16 COMPLAINT against defendant Shaw Environmental, Inc. Jury Demand,, filed by Karla Spafford.(Bobinette, Charles) (Entered: 10/23/2006)
17 DISCLOSURE OF CORPORATION INTERESTS CERTIFICATE by Intervenor Plaintiff Karla Spafford. (Please note this document has been edited to reflect it is not a motion.) (ARL) (Entered: 10/24/2006)
18 JOINT SCHEDULING PLAN by Plaintiff Equal Employment Opportunity Commission. Joint Proposed Scheduling Plan. (Shelly, Jan) (Entered: 11/02/2006)
19 Defendant Environmental Dimensions, Inc.'s ANSWER to Complaint with Jury Demand Filed by Plaintiff/Intervenor Karla Spafford by Environmental Dimensions, Inc..(Riggan, Russell) (Entered: 11/03/2006)
20 ANSWER to Complaint (with Affirmative Defenses) by Shaw Environmental, Inc..(Hoefer, Craig) (Entered: 11/03/2006)
21 CASE MANAGEMENT ORDER This case is assigned to Track: 2 - Standard Motion to Join Parties due by 12/1/2006. Discovery Completion due by 7/10/2006. ADR Future Reference 4/2/2007. Dispositive Motions due by 8/14/2007. Jury Trial set for 2/11/2008 09:00 AM before Honorable Rodney W. Sippel. Signed by Judge Rodney W. Sippel on 11/9/06. (LAH, ) (Entered: 11/09/2006)
22 MOTION to Amend/Correct Case Management Order and for Leave to File Her First Amended Complaint by Intervenor Plaintiff Karla Spafford. (Attachments: # 1 First Amended Complaint)(Bobinette, Charles) (Entered: 01/15/2007)
Docket Text ORDER re 22 MOTION to Amend/Correct Case Management Order and for Leave to File Her First Amended Complaint by Intervenor Plaintiff Karla Spafford. (Attachments: # First Amended Complaint)(Bobinette, Charles) filed by Karla Spafford, GRANTED Signed by Judge Rodney W. Sippel on 1/17/07. (LAH, ) (Entered: 01/17/2007)
23 AMENDED COMPLAINT against defendant Shaw Environmental, Inc., Environmental Dimensions, Inc., Shaw Group, Inc., Shaw Environmental & Infrastructure, Inc., Stone & Webster, Inc. Jury Demand demand, filed by Karla Spafford.(LAH, ) (Entered: 01/17/2007)
24 MOTION for Reconsideration re Docket Text Order, Defendant Environmental Dimensions, Inc.'s Motion to Reconsider or, In the Alternative, Motion to Dismiss by Defendant Environmental Dimensions, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Riggan, Russell) (Entered: 01/19/2007)
25 MOTION for Extension of Time to File Response/Reply to Defendant EDi's Motion to Reconsider or, in the Alternative, Motion to Dismiss by Intervenor Plaintiff Karla Spafford. (Bobinette, Charles) (Entered: 01/26/2007)
Docket Text ORDER re 25 MOTION for Extension of Time to File Response/Reply to Defendant EDi's Motion to Reconsider or, in the Alternative, Motion to Dismiss by Intervenor Plaintiff Karla Spafford. (Bobinette, Charles) filed by Karla Spafford ; ORDERED GRANTED. Signed by Judge Rodney W.

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01/29/2007 01/30/2007
02/09/2007
02/16/2007
03/16/2007 04/02/2007 04/17/2007 05/04/2007
05/04/2007 05/04/2007 05/11/2007

Sippel on 1/29/06. (ARL) (Entered: 01/29/2007)
26 MOTION for Extension of Time to File Answer re 23 Amended Complaint By Intervenor/Plaintiff by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 01/29/2007)
Docket Text ORDER re 26 MOTION for Extension of Time to File Answer re 23 Amended Complaint By Intervenor/Plaintiff Until After the Court Has Ruled on Edi's Motion For Reconsideration, or Alternatively, to Dismiss by Defendant Shaw Environmental, Inc.; ORDERED Granted - RWS; Signed by Judge Rodney W. Sippel on 1/30/07 (CMA) (Entered: 01/30/2007)
27 RESPONSE to Motion by Karla Spafford as to Shaw Environmental, Inc., Environmental Dimensions, Inc., Shaw Group, Inc., Shaw Environmental & Infrastructure, Inc., Stone & Webster, Inc. re 24 MOTION for Reconsideration re Docket Text Order, Defendant Environmental Dimensions, Inc.'s Motion to Reconsider or, In the Alternative, Motion to Dismiss filed by Intervenor Plaintiff Karla Spafford, Defendants Shaw Environmental, Inc., Environmental Dimensions, Inc., Shaw Group, Inc., Shaw Environmental & Infrastructure, Inc., Stone & Webster, Inc.. (Attachments: # 1 Affidavit of Karla Spafford# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5)(Bobinette, Charles) (Entered: 02/09/2007)
28 REPLY to Response to Motion re 24 MOTION for Reconsideration re Docket Text Order, Defendant Environmental Dimensions, Inc.'s Motion to Reconsider or, In the Alternative, Motion to Dismiss filed by Defendant Environmental Dimensions, Inc.. (Attachments: # 1 Exhibit C)(Riggan, Russell) (Entered: 02/16/2007)
29 MOTION to Amend/Correct 21 Case Management Order, by Defendant Environmental Dimensions, Inc.. (Riggan, Russell) (Entered: 03/16/2007)
30 First MOTION to Amend/Correct Complaint by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1)(Shelly, Jan) (Entered: 04/02/2007)
31 ENTRY of Appearance by Michael B. Kass for Defendant Environmental Dimensions, Inc.. (Kass, Michael) (Entered: 04/17/2007)
Docket Text ORDER: Re: 30 First MOTION to Amend/Correct Complaint by Plaintiff Equal Employment Opportunity Commission. (Attachments: # )(Shelly, Jan) filed by Equal Employment Opportunity Commission; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 5/4/07. (KJF, ) (Entered: 05/04/2007)
32 AMENDED COMPLAINT against defendant Shaw Environmental, Inc. , filed by Equal Employment Opportunity Commission.(KJF, ) (Entered: 05/04/2007)
Docket Text ORDER: Re: 29 MOTION to Amend/Correct 21 Case Management Order, by Defendant Environmental Dimensions, Inc.. (Riggan, Russell) filed by Environmental Dimensions, Inc.; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 5/4/07. (KJF, ) (Entered: 05/04/2007)
33 MOTION to Withdraw as Attorney ;attorney/firm Russell C. Riggan by Defendant Environmental Dimensions, Inc.. (Riggan, Russell) (Entered: 05/11/2007)

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05/14/2007 05/15/2007 05/16/2007 06/28/2007 06/29/2007 07/12/2007
07/19/2007
08/17/2007 08/20/2007 08/23/2007 08/23/2007 08/28/2007

Docket Text ORDER: Re: 33 MOTION to Withdraw as Attorney ;attorney/firm Russell C. Riggan by Defendant Environmental Dimensions, Inc.. (Riggan, Russell) filed by Environmental Dimensions, Inc., ; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 5/14/07. (ARL) (Entered: 05/14/2007)
34 MOTION for Extension of Time to Complete Mediation by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 05/15/2007)
Docket Text ORDER: Re: 34 MOTION for Extension of Time to Complete Mediation by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) filed by Shaw Environmental, Inc., ; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 5/16/07. (LGK, ) (Entered: 05/16/2007)
35 MOTION for Extension of Time to Complete Mediation by Defendants Shaw Environmental, Inc., Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 06/28/2007)
Docket Text ORDER: Re: 35 MOTION for Extension of Time to Complete Mediation by Defendants Shaw Environmental, Inc., Shaw Environmental, Inc.. (Hoefer, Craig) filed by Shaw Environmental, Inc.; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 6/29/07. (KJF, ) (Entered: 06/29/2007)
36 ADR Compliance Report by Plaintiff Equal Employment Opportunity Commission, Intervenor Plaintiff Karla Spafford, Defendants Shaw Environmental, Inc., Environmental Dimensions, Inc., Shaw Environmental, Inc., Shaw Environmental & Infrastructure, Inc., Stone & Webster, Inc. Parties did settle. (Nowogrocki, James) Modified on 7/13/2007 (LGK, ). (Entered: 07/12/2007)
37 SCHEDULING ORDER: ORDERED that counsel shall file, within 30 days of the date of this order, a stipulation for dismissal, a motion for leave to voluntarily dismiss, or a proposed consent judgment. Failure to timely comply with this order shall result in the dismissal of this action with prejudice. Dismissal Paper(s) due by 8/20/2007.. Signed by Judge Rodney W. Sippel on 7/19/07. (LGK, ) (Entered: 07/19/2007)
38 ORDER - IT IS HEREBY ORDERED that a status conference shall be held Thursday, August 23, 2007 at 4:00 p.m., in my chambers. Signed by Judge Rodney W. Sippel on 8/17/07. (LAH, ) (Entered: 08/17/2007)
39 Consent Decree by Plaintiff Equal Employment Opportunity Commission, Intervenor Plaintiff Karla Spafford, Defendant Environmental Dimensions, Inc.. (Shelly, Jan) (Entered: 08/20/2007)
40 ENTRY of Appearance by Melvin D. Kennedy for Plaintiff Equal Employment Opportunity Commission. (Kennedy, Melvin) (Entered: 08/23/2007)
41 Minute Entry for proceedings held before Judge Rodney W. Sippel : Status Conference held on 8/23/2007. (Court Reporter - Shannon White.) (FTR Gold yes or no: no.) (proceedings started: 4:08.) (proceedings ended: 4:36.) (LAH, ) (Entered: 08/24/2007)
42 MOTION for Extension of: Dispositive Motion Deadlines by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) (Entered: 08/28/2007)

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08/29/2007
09/18/2007 09/19/2007 10/01/2007 11/06/2007 11/08/2007

Docket Text ORDER: Re: 42 MOTION for Extension of: Dispositive Motion Deadlines by Defendant Shaw Environmental, Inc.. (Hoefer, Craig) filed by Shaw Environmental, Inc., ; ORDERED GRANTED. Signed by Judge Rodney W. Sippel on 8/29/07. (ARL ) (Entered: 08/29/2007)
43 Consent Decree by Plaintiff Equal Employment Opportunity Commission. (Shelly, Jan) (Entered: 09/18/2007)
44 CONSENT JUDGMENT... SEE DECREE.... Signed by Judge Rodney W. Sippel on 9/19/07. (LGK, ) (Entered: 09/24/2007)
45 CONSENT JUDGMENT - SEE CONSENT DECREE. Signed by Judge Rodney W. Sippel on 10/1/07. (LGK, ) (Entered: 10/01/2007)
46 MOTION to Dismiss Case with Prejudice by Intervenor Plaintiff Karla Spafford. (Bobinette, Charles) (Entered: 11/06/2007)
47 MEMORANDUM AND ORDER - IT IS HEREBY ORDERED that Plaintiff's Motion to Dismiss with Prejudice 46 is GRANTED. IT IS FURTHER ORDERED that I will expressly retain jurisdiction over this case for a period of two (2) years for the limited purpose of hearing and resolving disputes and claims arising out of or relating to the interpretation or enforcement of the Consent Decrees entered into between the parties. Signed by Judge Rodney W. Sippel on 11/8/07. (KJF, ) (Entered: 11/08/2007)

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