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v

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

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
vs. PRESS REPUBLICAN NEWSPAPERS, INC.,
and LIBERTY GROUP SUBURBAN
NEWSPAPERS, INC.
Defendants.

)

)

)

) )
)

Civil CO

Action No~,~.U!!:\.
MPLAIT

cJ@~~.. ~!,f<?'D\~:GE

60NJ-Oi.iJ.Rv~OG~.L, Ee:f,,t:~s..=

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"1)

)

) JURY TRIA£M>l(,~~TE JUDGE NOLAN
)

)

)

) )

DOCKETED

)
) MAY 2 52001

)

NATURE OF THE ACTION

This is an action under Title I of the Americans with Disabilities Act of 19"90 (the

"ADA"), 42 U.S.c. §12101 et seq., and Title I of the Civil Rights Act of 1991, to correct

unlawful employment practices on the basis of disability. Defendant Press Republican

Newspapers, Inc. failed to accommodate Karri Chistiansen's disability of depression and

instead terminated her because of her disability. Defendant Liberty Group Suburban

Newspapers, Inc. is the successor of Press Republican Newspapers, Inc.

JURISDICTION AND VENUE 1. Jurisdiction ofthis Court is invoked pursuant to 28 U.S.C. §§451, 1331,1337, 1343, and 1345. This action is authorized and instituted pursuant to Section 107(a) of the ADA, 42 U.S.C. §12117(a), which incorporates by reference Sections 706(f)(1) and (3) of

__________________• ____•______________MB. . . . . . . ._

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Title VII of the Civil Rights Act of 1964 ("Title VII"), 42 U.S.c. §§2000e-5(f)(1) and (3),

and pursuant to Section 102 of the Civil Rights Act of 1991,42 U.S.C. §1981A.

2. Defendants each engage in business within the jurisdiction of the Northern

District of Illinois.

PARTIES

3. Plaintiff, Equal Employment Opportunity Commission (the "Commission"),

is an agency ofthe United States ofAmerica charged with the administration, interpretation

,
j

and enforcement of Title I of the ADA and is expressly authorized to bring this action by

f ,

Section 107(a) ofthe ADA, 42 U.S.C. § 121 17(a), which incorporates by reference Section

706(f)(1) ofTitle VII, 42 U.S.C. §2000e-5(f)(I).

4. At all relevant times Defendant Press Republican Newspapers, Inc. has been

a corporation doing business in the State of Illinois and has continuously had at least 15

employees.

5. At all relevant times Defendant Press Republican Newspapers, Inc. has

continuously been an employer engaged in an industry affecting commerce under Section

101(5) of the ADA, 42 U.S.C. §12111(5) and Section 101(7) of the ADA, 42 U.S.c.

§12111(7), which incorporates by reference Sections 701(g) and (h) ofTitle VII, 42 U.S.C.

§§2000e(g) and (h).

6. At all relevant times Defendant Press Republican Newspapers, Inc. has been

a covered entity under Section 101(2) of the ADA, 42 U.S.C. §1211 1(2).

7. At all relevant times Defendant Liberty Group Suburban Newspapers, Inc. has

..'- ~~~~--~----------------,----------------------~~--
v

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been a corporation doing business in the State of Illinois and has continuously had at least

15 employees.

8. At all relevant times Defendant Liberty Group Suburban Newspapers, Inc. has

,

~

continuously been an employer engaged in an industry affecting commerce under Section

•

101(5) of the ADA, 42 U.S.C. §12111(5) and Section 101(7) of the ADA, 42 U.S.C.

§12111(7), which incorporates by reference Sections 701(g) and (h) ofTitle VII, 42 U.S.C.

§§2000e(g) and (h).

9. At all relevant times Defendant Liberty Group Suburban Newspapers, Inc. has

been a covered entity under Section 101 (2) of the ADA, 42 U.S.C. §12111 (2).

STATEMENT OF CLAIMS

10. More than thirty (30) days prior to the institution of this lawsuit Karri

Chistiansen filed a charge with the Commission alleging violations ofTitle I ofthe ADA by

Defendant Press Republican Newspapers, Inc. At all relevant times she was a "qualified

individual with a disability" under Section 101(8) of the ADA, 42 U.S.C. §12111(8). All

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

11. On the evening of Thursday, February 4,f999,Karri Christiansen, the News

Editor ofDefendant Press Republican Newspapers, Inc., who had been off work due to her

disability, depression, since January 21, 1999, presented to Defendant Press Republican

Newspapers, Inc. a note from her treating psychologist stating that she was able to return

to work. She requested to return to work the following Monday. Instead of discussing her

plans to return to work, Defendant Press Republican Newspapers, Inc. immediately

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tenninated her in violation of Section 102(a) of the Americans with Disabilities Act, 42

u.S.c. § 12112(a).

12. The effect of the practices complained of above has been to deprive Karri

Chistiansen of equal employment opportunities because of her disability, depression.

.

.

13. The unlawful employment practices complained of above were intentional.

14. In about 1999 Defendant Liberty Group Suburban Newspapers, Inc. became

the successor ofPress Republican Newspapers, Inc. and continued to operate and publish the

newspapers for which Karri Christiansen had been the News Editor. On Infonnation and

belief Defendant Liberty Group Suburban Newspapers Inc. had notice of the charge of

discrimination filed by Karri Christiansen against Press Republican Newspapers, Inc.

PRAYER FOR RELIEF

WHEREFORE, the Commission respectfully prays that this Court:

A. Grant a pennanent injunction enjoining Defendants, their officers, management

personnel, employees, agents, successors, assigns, and all persons in active concert or

participation with it, from engaging in any employment practice which discriminates on the

basis of disability;

B. Order Defendants to institute and carry out policies, practices, and programs

which provide equal employment opportunities to qualified individuals with disabilities, and

which eradicate the effects of its past and present unlawful employment practices;

C. Order Defendants to make whole Karri Chistiansen by paying her back pay,

the value oflost fringe benefits, plus prejudgment interest, in amounts to be proved at trial,

------------,---------------------,-
v

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and other affirmative relief necessary to eradicate the effects of the unlawful employment

practices of Defendant Press Republican Newspapers, Inc.;

D. Order Defendants to make whole Karri Chistiansen by providing compensation

for pecuniary and non-pecuniary losses in amounts to be determined at trial;

E. Grant such further relief as the Court deems necessary and proper; and,

F. Grant the Commission its costs in this action.

I

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JURY TRIAL DEMANDED

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The Commission requests a jury trial on all questions offact raised by the Complaint.

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Respectfully submitted,

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GWENDOLYN YOUNG REAMS

"

Associate General Counsel

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EQUAL EMPLOYMENT

I

OPPORTUNITY COMMISSION lL

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GORDON G. WALDRON Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 500 West Madison Street
Suite 2800 Chicago, Illinois 60661 (312) 353-7525
C:\MYFILES\Open Cases\Press Republican\Complaint.wpd

Civil Cover She~.

http://www.ilnd.uscourts.gov/ vti_binishtml.dlIJPUBLIClFonns/cvcover.hl

CO~T NORG~ ut'TED STATES DISTRICT

J'yiJI,;)r;;.

NORTHERN DISTRICT OF IL~JNm)~'RAtE JUDG!': N~rA~

Civil Cover She'lC 3840

This automated JS-44 confonns generally to the manual JS-44 approved by the Judicial Conference ofthe United States in September 1974. The data is required for the use of the Clerk ofeourt for the purposc of initiating the civil docket sheet. The infonnation contained herein neither replaces nor supplements the filing and service ofpleadings or other papers as required by law. This fonn is authorized for use only in the Northern District of Illinois.

Plaintiff(s): U.S. Equal Employment Opportunity Commission

Defendant(s): Press Republican Newspapers, Inc., and Liberty Group Suburban Newspapers, Inc.

County of Residence:

County of Residence: DuPage

Plaintiff's Atty:

Gordon G. Waldron U.S. Equal Employment Opportunity Commission 500 W. Madison St., Suite 2800 Chicago, Illinois 60661 (312) 353-7525

Defendant's Atty:
DOCKETED
MAY 2 52001

II. Basis of Jurisdiction:

1 U.S. Gov't Plaintiff

Donald M. Craven

Craven & Thornton, PC

1005 North SeventtPStreet
Springfield,~-· 62iR~ .n

. (217) 544-1.7 -.:::;,-;::::: -~

U; c'.
d··

N
,-

rG'!>

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

rno

IV. Origin:

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

42 U.S.C. § 12117(a), Americans With Disabilities Act;

discrimination based. on disability.

VII. Requested in Complaint

Class Action: No

Dollar Demand:

Jury Demand: Yes

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

Signature: ~./1Cn-~)J WcJ.J,v----

C- Date:

(~~ /01

If any of this information is incorrect, please go back to the Civil Cover Sheet Input fonn using the Back button in your browser and

change it. Once correct, print this form, sign and date it and submit it with your new civil action. Note: You may need to adjust

the font size in yonr browser display to make the form print properly.

Revised: 06/28/00

In the Matter of

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UNITED S'fATES nIsTrucT COiJRT

NORTlIERN bISTRICt OF IttiN()IS

Eastern Division

Case Number:

.

MAGlSTRA'l"E JUDGE NOl!Jhll0

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

SIGNATURE

(A)

NAME
Gordon G. Waldron

Commission

STREET ADDRESS
500 W. Madison St. Suite 2800

STREET ADDRESS

(n

-n

500 W. Madison St. Suite 2800 ;'C

......

CqY'05TATFlZIP
Chicago, Illinois 60661

CITY1STATEIZIP
Chicago, Illinois 60661

:~':'-.:' ?:J'_..-

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

ARDC No. 02920646
MEMBER OF TRIAL BAR?

0 YES

TRIALATIORNEY?

0 YES

o NO
NO

Commission

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 01187589

MEMBER Of lRIALBAR?

0 YES

TRIAL ATIORNEY?

0 YES

DESIGNATED AS LOCAL COUNSEL?

0 YES

0 NO
0 NO
0 NO

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDC No. 06210804

oc:

MEMBER OF TRIAL BAR?

YES

TRIAL ATTORNEY? DESIGNATED AS LOCAL COUNSEL?

0 YES 0 YES

,......, NO
0 NO 0 NO

SIGNATURE

(D)

NAME

FJRM

STREET ADDRESS

CITY1STATEIZIP

TELEPHONE NUMBER

IDENTlFICAnON NUMBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR? TRIAL ATIORNEY? DESIGNATED AS LOCAL COUNSEL?

0 YES
0 YES
0 YES

NOO

 
 =_ _ _ _ _ _ _ __ _ _ __ '_ _- : -_ _ _ _..~ .. ""r__n"!mr_ _ _ _ _ _ _ _ _ _..._.......
:

DOCKETED IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTER DIVISION

OCT 1 9 2001

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
vs. PRESS REPUBLICAN NEWSPAPERS, INC.,
and
LIBERTY GROUP SUBURBAN NEWSPAPERS, INC.
Defendants.

)

)

)

) Civil Action No. 01 C 3840

)

)

)

Judge Norgle

)

)

)

)

Magistrate Judge Nolan

)

)

)

)

)

CONSENT DECREE

The Equal Employment Opportunity Commission (hereafter the "Commission" or "EEOC") filed this action against Press Republican Newspapers, Inc. ("Press") and Liberty Group Suburban Newspapers, Inc. ("Liberty") under Title I of the Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.c. §12101 et seq., and Title I of the Civil Rights Act of 1991. EEOC alleged that Press failed to reasonably accommodate Karri Christiansen's disability, and instead terminated her because of her disability. Press has denied the allegations. EEOC has alleged that Liberty is the Successor of Press.
The parties have determined to finally resolve this action through entry of this Consent Decree.
Findings Having carefully examined the terms and provisions ofthis Consent Decree and based on the pleadings, record and stipulations of the parties, the Court finds the following: 1. The Court has jurisdiction ofthe subject matter ofthis action and ofthe parties.

1

,_ _ _ _ _ _ _ _.,lIftl'ft'i1tDu. . . _ _ _ _ _ _ _I....., . . - . ._ _ _ _ _ _ _ _._. _•__ _ _ _ __
2. The terms and provisions ofthis Consent Decree are fair, reasonable, equitable andjust. The rights ofthe parties and ofKarri Christiansen, are adequately protected by this Consent Decree.
3. This Consent Decree conforms with the Federal Rules ofCivil Procedure and the ADA and is not in derogation ofthe rights and privileges ofany person. The entry ofthis Consent Decree will further the objectives of the ADA and will be in the best interests of Defendants, EEOC, and Kani Christiansen, and in the public interest.
4. Defendant Press Republican, Inc. has represented that it is no longer in business, and has merged into Defendant Liberty Group Suburban Newspapers. As a result, this Consent Decree provides no prospective injunctive relief against Press Republican, Inc. (other than paragraph 6 in regard to monetary relief and exhibit 7 in regard to letter of reommmendation). Should it later be determined that Press Republican, Inc. in fact has remained in business, the EEOC may seek additional reliefagainst it, ifit proves that Liberty violated the ADA.
5. Defendant Liberty Group Suburban Newspapers, Inc. ("Liberty") has represented that it has adopted, publicized and enforces the non-discrimination policy attached as Exhibit C.
WHEREFORE, upon the consent of the parties to this action, IT IS ORDERED, ADJUDGED AND DECREED:
6. a. Defendants shall pay to Karri Christiansen $22,000 in compensatory damages. No deductions for taxes or otherwise shall be made from that amount.
b. Defendants shall also pay Karri Christiansen $18,000 representing back pay and interest. Defendants may withhold Karri Christiansen's income taxes from the back pay amount, and may also withhold therefrom her share ofsocial security taxes. There shall be no withholding from the back pay amount ofDefendants ' share ofsocial security taxes, or ofany other amounts.
2

I_.__'______________ ~ _....,...._ _ _ _ _ _ _ _ _ _ _ _ _ _ ....."U>t.........._ _ _ _ _ _ _ _
c. Defendants shaH pay Karri Christiansen $1,000 for purposes ofretaining counsel to review and advise on signing the release attached as Exhibit A.
d. Within 5 days of receipt of the a release (attached as exhibit A.) signed by Karri Christiansen, Defendants shaH deliver to Karri Christiansen at 1035 Superior Street, Two East, Oak Park, IL 60301 a check or checks totaling the above amounts (less the deductions specified above) payable to Karri Christiansen, and shaH also provide a copy of said check(s) to Gordon Waldron at EEOC at the address listed below. EEOC is not a party and has not played any role in connection with the negotiation or execution ofsaid release; EEOC has not approved said release, and has not advised Karri Christiansen with respect thereto; Karri Christiansen has been represented with respect to said release by her own private retained counsel.
7. Wayne Woltman, fonnerpublisher ofPress-Republican, shaH within, five days ofthe signing of this decree, provide Karri Christiansen at the address listed in paragraph 6 a letter of recommendation in a fonn identical to Exhibit B hereto.
8. EEOC and each Defendant shaH bear their own costs and attorneys' fees, provided, however, that nothing herein shall affect the parties' rights under the Stock Purchase Agreement dated July 1, 1999 between Wayne G. Woltman and Liberty, and the indemnification provisions contained therein.
9. EEOC agrees that this Consent Decree fuHy resolves the claims filed against Defendants in this lawsuit and the Charge ofDiscrimination filed by Karri Christiansen against Press Republican, Inc, # 210 99 1482.
Agreed
Nicholas M. Inzeo Acting Deputy General Counsel Gwendolyn Young Reams Associate General Counsel
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,_ _ _ _ _ _ _ _ _ .....- ,,~-="' -_ _ _ _ _ _I._ _ _ _ _- - - - - - - - - - - -

Equal Employment Opportunity Commission 1801 L Street, N.W. Washington, D.C. 20507

~D'+..~~. ~~ /(1JJk

Jo C. Hendrickson

( I

Regional Attorney-

Gordon Waldron Equal Employment Opportunity Commission 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 (312) 353-7525
Attorney for Press Republican Newspapers, Inc.
omey for Liberty Group Suburban Newspapers, Inc.
Judge Norgle C:\MYFILES\Open Cases\Press Republican\ConsentDecreeOctl.wpd

4

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In consideration for the agreements made by defendants in the Consent DecJ,c entered in the

prr.ess lawsuit styledllnirad SlaW EQI!II EmgIoyment Qpwrflmi'Y Gnmmj!lJ!jon PllIit!tift vs. RIlj:inb!ioRD

NewspllPers. Inc. BPd'Liberty Group Suburban New§l!!W1llS Inc" Defendnn1s, Civil !Action No. 01 C

3840, in the U.S. District Court for the Northern District of Illinois, including

of the gross

I

amountofFortyThousandDoUars ($40,000), KARRI E. CHRISTIANSEN,lIIld anyonell'l.imingtbJough

I

4haxges KARRIE. CHRISTIANSEN, Including her spouse, issue, agen1lI, xepxcsenlBtives; lIIld aSsigus (hereinafter

collecdvely refem:d to as "Christiansen") hereby irrevocably waives, releases, and

PRESS-

REPUBLICANNEWSPAPERS, INC. andLlBERTYGROUP SUBURBANNEWSP-'fERS, INC. (aud

each oftheir owners, parents, subsidiaries, divisions, affiIia!cd entities, succesSOl'S, preclbccssors. assigns,

cru-ges, I
officers, direc!Ors, stockhOlders, employees, attorneys, and ngents) from lillY and all

demands,

sums of money, daroAges, grieVllllCeS, CRl1Ses of action. and lawsuits of any kind:whatsoever, that

Christiansen might nol'1l have, has had, or claims to have had, or may assert to have abcrued. including

I

but not limited to clRims arising from, growing out of, or in any way coWiecred lwith, directly or

.

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... 'indirectly, Christiansen's employment relationship with Press-RepublicllD. Newspap~, Inc., and the

.

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manne.;, means, or circlJIll$iances of ChristillllScP's separation from employmtWt with l'rcsil-RepubIican

I

Newspapers, Inc., including but not 1imired In all claims asserted in the above-refe.:enced lawsuit and in

I
the charge filed by Christiansen with the EEOC, styled Katri E, Christiansen. Charging PartY. verSus

Press-RepubliclID New!lJ1l!Pers, Inc RC!lJ1ondent EEOC Chargc No. 2109914~2. Christiansen

acknowledges that ah~ has had an opportunity to secure the services ofan anomey to a~vise Christiansen of the nature of the ri~ts that Cbrisitansen woives in this General RelellSe IUld Wai~er of Claims, IUld

ChristillllSen further represents that she has read fue terms ofthis Gene.;al RelellSC and y"aiver of Claims,

has had sufficieat time In consider executing it, knows and understands the rights that s,he is waiving and
the terms and consequences ofher execution ofthis General Release and Waive.; of Qaims, and further
qtaims represents and ackno'?,'ledges that she executes this General Release and Waiver of I knoW!'ngly,

voluntarily, in good fuith, with a genuine intent In waive the rights identified herein, mtd that she has uot

been subjected to any du£ess, coercion, fraud, overreaching, or exploitation.

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KARlti E. CHRISTIANSEN

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Date

[SS4fO.i

',.''' .
. .
Exhibit B (Letter ofRecommendation)

To WhomItMayConcem:
Re: Katri C!yjstiansep.

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While I was theprincipal ownerandpublisherof'Press-RepublicIillNewspapers, Inc., Press-Republican twice employed I{an:i Christiansen, filst as a geuezal as~ent repoJ.te!' between 1991 and 1993, and more recently as news editor from 1998 to 1999. As news editor, Karri WIIS responsible fur coordinating all front section news co~e in PressRepubIican'~ Geneva, Batavia, and St. Chatles papers. Her du1i,es incl~ !riring IlUd
training reporters and editors, editing copy forstyle and substance, writingnews stories•.and
. JIelping to cooJ;dinate regional news. While employed by Press-RePublican, KIJIri demonstrated her abilities as a good writer, a good editor, and an able nev.lsroom repoJ.ter.
! ,
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Sincerely,

Wayne G. Woltman

lS.'J]97.1

_ _ _ .... _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .'~

"'~'_"'

'~

'""'I'!!II~

II_ _ IIHII

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EQUAL EMPLOYMENT OPPORTUNITY POLICY AND INTERNAL COMPLAINT PROCEDURE
The Company is committed to maintaining a workplace free from prohibited employment conduct, including discrimination or harassment on the basis of any characteristic protected by law; retaliation for engaging in protected activity; and faihire to provide reasonable accommodation for disability or religion. The Company provides an Internal Complaint Procedure (explained below) through which employees (including former employees) should bring reports if they feel that the Company has not fulfilled this commitment. The Company will not tolerate retaliation against any employee who makes a good faith report under this policy.
Employment Discrimination
The Company is committed to maintaining a workplace free of discrimination on the basis of any protected characteristic, including race, color, national origin, sex, age, religion, or disability (hereinafter called "Protected Characteristics"), and will take appropriate measures to prevent andlor stop it. Employment discrimination occurs when an employee is adversely affected with respect to any term or condition of employment (including hiring, compensation, advancement, discipline, or termination) because of a Protected Characteristic. Any employee who is aware of any conduct that may violate this policy should promptly report the conduct using the Internal Complaint Procedure.
Sexual and Discriminatory Harassment
The Company will not tolerate harassment based on any Protected Characteristic, and will take appropriate measures to prevent and/or stop any such harassment. Any individual who is aware ofany conduct that may violate this policy should promptly report the conduct using the Internal Complaint Procedure.
Harassment is broadly defined as any conduct, whether verbal or physical, that denigrates, insults, or offends a person or group on the basis of a Protected Characteristic where: (1) submission to such conduct is made an explicit or implicit term or condition of employment; (2) submission to or rejection of such conduct is used as a basis for any employment decision; or (3) such conduct has the purpose or effect of interfering with an employee's work performance or creating an intimidating, offensive or hostile working environment.
I. Sexual Harassment. Sexual harassment in violation of this policy includes, but is not limited to:
Sexually suggestive or vulgar comments or jokes; inappropriate comments about another person's sexual behavior or body; or insulting or ridiculing an employee because of his or her gender.

, .

., .••••."."..... _ _ _ _ _ _ _, _ ,. . . . .I'I!I_ _,_ . _ _ _ _ _ _. ._ _ _ ....._ _ _ _.......

•

Improper or intrusive questions or comments about an employee's romantic or

sexual. experiences or preferences; or unwelcome or offensive sexual flirtations,

propositions, advances, or requests.

•

Using, displaying or communicating sexually suggestive or offensive words,

objects, pictures, calendars, cartoons, articles, letters, e-mail messages, computer

programs or Internet sites.

•

Making or t1u:eatening undesired physical contact (such as touching, embracing,

or pinching) or impeding another's movements in a deliberate manner.

•

Offering or providing employment benefits in return for sexual favors or an

employee's agreement to provide sexual favors; or taking or tlu:eatening to take

adverse action against an employee because the employee rejects requests for

sexual favors.

2. Discriminatory Harassment. Discriminatory harassment in violation of this policy includes, but is not limited to:

•

Comments or jokes that denigrate, insult, offend, or ridicule based on a Protected

Characteristic.

.

•

Creating a hostile work environment or otherwise singling out an individual for

abusive conduct based on that individual's Protected Characteristic.

•

Using, displaying or communicating words, objects, pictures, calendars, cartoons,

articles, letters, e-mail messages, computer programs or Internet sites that

denigrate, insult, offend or ridicule based on a Protected Characteristic.

Retaliation

The Company will not tolerate retaliation against any employee who seeks to enforce his or her right to work in an environment free of unlawful discrimination or harassment or who makes a good faith report under the Internal Complaint Procedure. Any employee who is aware of any conduct that may violate this policy should promptly report the conduct using the Internal Complaint Procedure.

Retaliation includes the following prohibited acts:

•

Taking or threatening to take adverse action against an employee because he or

she has made a good faith report or complaint about discrimination, sexual

harassment, discriminatory harassment or retaliation; because he or she has

participated or assisted in an investigation of an alleged violation of this policy; or

2

I'I!IHI!'!!tU.'_'' _ _ _ _ _ _..___..._ _ _ _...... _______~_ _ _ _ _."'••. •. ,.... ",,, ..._ _ _ _ _ _ _'_III...

because he or she has otherwise sought to enforce his or her rights under any employment law.

•

Threatening to take adverse action against an employee unless he or she agrees

not to make a report about discrimination, sexual harassment, discriminatory

harassment, or retaliation, participate in an investigation of an alleged violation of

this policy, or conceal the truth in such an investigation.

Reasonable Accommodatior!

The Company is cohlmitted to providing reasonable accommodation to enable qualified employees with disabilities to perform the essential functions of their jobs. Depending on the circumstances, reasonable accommodation may include modifying the work enviromnent, making facilities accessible, restructuring a job, adjusting work schedules, granting leave, or other measures.

The Company is also committed to providing reasonable accommodation of an employee's sincere religious observances and beliefs that conflict with normal job requirements.

Any employee who believes he or she needs accommodation based on disability or ' religion is responsible for bringing the matter to the attention of the Publisher at the location where he or she works or the Director of Human Resources, Maureen Wurfel. In the case of disability, the employee may be required to provide medical documentation establishing the existence of a disability, any job-related restrictions, and the estimated length of time for which accommodation is needed. The Company will keep all medical information confidential to the greatest extent practicable.

Any employee who believes he or she has been denied reasonable accommodation should promptly notify management pursuant to the Internal Complaint Procedure.

Internal Complaint Procedure

Any employee who believes that a violation of this policy has occurred, whether by a supervisor, manager, co-worker, subordinate or other person, should immediately inform the Publisher at the location where he or she works or the Director of Human Resources, Maureen Wurfel.

All reports will be referred to the Publisher for investigation, review or other appropriate action. The Publisher or hislher designee will conduct a prompt, thorough investigation or review of the report to determine what has happened. All facts concerning any report (including the identities of the complaining party, the person alleged to have violated this policy, and other witnesses) will be kept conficiential fi·om anyone who does not have a legitimate reason to know about them, subject to management's need to investigate and take appropriate remedial measures.

3

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If the Company concludes that this policy has been violated, it will take prompt corrective action reasonably designed to end the violation and to prevent any further violations from occurring. Such corrective action may include disciplinary action against anyone found to have violated this policy, up to and including immediate termination ofemployment.
After the Company has completed its investigation or review and determined whether this policy has been violated, it will advise the complaining party ofthe results of the investigation or review and the corrective action, if any, that is being taken as a result.
If you have any questions about this policy, please contact the Director of Human Resources, Maureen Wurfel.

4

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?865794388369414-L_35...
NOLAN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-03840

EEOC v. Press Republican, et al Assigned to: Hon. Charles R. Norgle, Sr Demand: $0 Cause: 42:12101 Americans with Disabilities Act

Date Filed: 05/24/2001 Date Terminated: 10/19/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Gordon G. Waldron United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7525 Fax: (312)35 -8555 Email: gordon.waldron@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory M. Gochanour United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 886-9124 Email: gregory.gochanour@eeoc.gov ATTORNEY TO BE NOTICED

John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED

V.

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Defendant Press Republican Newspapers, Inc.
Defendant Liberty Group Suburban Newspapers, Inc.

represented by Steven L. Brenneman Ford & Harrison 55 East Monroe Street Suite 2900 Chicago, IL 60603-5709 (312) 332-0777 Email: SBrenneman@fordharrison.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
James M. Gecker Katten Muchin Rosenman LLP 525 West Monroe Street Suite 1600 Chicago, IL 60661 (312) 902-5200 Email: james.gecker@kattenlaw.com ATTORNEY TO BE NOTICED
represented by Steven L. Brenneman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
James M. Gecker (See above for address) ATTORNEY TO BE NOTICED

Date Filed 05/24/2001
07/20/2001 07/23/2001 08/09/2001 08/09/2001

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Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of Gordon G. Waldron, Gregory M. Gochanour and John C. Hendrickson as attorney(s) for plaintiff EEOC ( No summons(es) issued.) ( Documents: 1-1 through 1-3) (hp) (Entered: 05/25/2001)
10 WAIVER of service of summons as to defendant Press Republican sent on 6/14/01. (air) (Entered: 11/07/2001)
2 WAIVER of service of summons as to defendant Liberty Grp Sub sent on 6/14/01 (las) (Entered: 07/25/2001)
3 ATTORNEY APPEARANCE for defendants Press Republican Newspaper, Inc. and Liberty Group Suburban Newpapers, Inc. by Steven L. Brenneman and James M. Gecker. (cem) (Entered: 08/10/2001)
4 UNOPPOSED MOTION by defendants' to extend time to answer or otherwise respond ; Notice. (vmj) (Entered: 08/21/2001)

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08/20/2001 09/13/2001 09/21/2001 10/05/2001 10/19/2001

5 MINUTE ORDER of 8/20/01 by Hon. Charles R. Norgle Sr: Defendants' unopposed motion to extend time to answer or otherwise plead is granted [4-1]. Counsel shall comply with Rule 26. Mailed notice (vmj) (Entered: 08/21/2001)
6 UNOPPOSED MOTION by defendants to extend time to answer or otherwise respond ; Notice (las) (Entered: 09/24/2001)
7 MINUTE ORDER of 9/21/01 by Hon. Charles R. Norgle Sr : Defendants' unopposed motion to extend time to answer or otherwise respond is granted [6-1]. Counsel shall file an agreed written status report on 11/13/01. Mailed notice. (las) (Entered: 09/24/2001)
8 MINUTE ORDER of 10/5/01 by Hon. Charles R. Norgle Sr : Enter agreed order extending the time for defendants' to file an answer. The date for defendants to file their answers is extended from 10/5/2001 to 11/5/2001. Telephoned notice (eav) (Entered: 10/11/2001)
9 MINUTE ORDER of 10/19/01 by Hon. Charles R. Norgle Sr : Terminating case. (Entered Consent Decree.) Mailed notice (lc) (Entered: 10/19/2001)

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