Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 1 of 8

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TN THE UNITED STATES DISTRICT COllRT FOR TIlE EASTERN DISTRIct OF PENNSYLVANIA

EQUAL EMPI,OYM)'~NT OPPQRTllNlTY )

COMMISSION.

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Plaintiff,

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AMERICAN INT.ERNATlONAL GROUP, INC.}

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CIVIL AClIONNU.:
~ JLUTIUALlJEMAND

NATUREOFTBE ACTION

Tb!!; n lID moo I.I&C~ Tttk va of the Civil Rights: Act of 1%4 a.'1d Titk I of the Civil

Rigllft Act of 1991 to oorrm:t unlawfill ::mpIQy:m,nl pr~ L'Ut d\SClirrJnale on tbe basis of'lII:'e

and \() provide lIppt'(!PJiate relidlo Curolyn Dwi~ ("Ms. I:XJzier"), IL"l African Ame:l;;.nn fumale,

by such practices wWle employed by Defendant, American Intd'MtionaJ Group, hw. ("AlG''). Ali micuLllixl witb grect<.'!' pa(,icularity in paragraphs. 7 and 8 belQW, ow C(1l{'_'tlissJon allege:> thm, Ms.

Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 2 of 8
simililfly ~ituated lknales, as "",,,,"1 as thereta1iatilluwffered by Ms. Thttier, Ms. J.Xcier and the class suikted lXWcte etru)w.-maf dimess ar:d wag" loss dMnagea.
J;JR)SPNJQN AND Vf\tNB
I. Jurisdlclioc.offhisC.oonisinvokOOpm:want to2gnS.c. H4;51, 1)31, 1337, 1343 iIl!d
1345. Thi~ !lelit;m \$ au!hmi.zed and iI:stiMed pUHiU\UlI !O ~706((; (1) and(3) otTilie YU oftheCivil
en Rig:.ts Adofl964, as am~, 42 US,C §~5(f)(1)and ("Title VIljand Secti()Jl102Qf
a . . d;;: il Rights Aft of 1991, 42 U.s.C. §':98Ja.
2, 11:,;. employment pnl(:\:lC>08 alleged to b", un.Ia.wfJl were and lire now being rommitted w,&jn the jurisdicu('\tl of !he United Slates for the Eastct:l District ofPennsyivania.
FhRIlfE
3. Plaintiit, the Equal Employment Opportuni\y Ci.'Ill'»nission (the "Coounission''), is the agency of Ihe United States \1J Amerits. c~ with lhe adrllnistration, inlelp!'etatiQll and enfuroenent ofTitk Vll, and in Eq>~ au!Mriud to bring this ",,:ion by Sooti<'m. 700(f)(1) :md (3) (lfTille VIT, aJJ arne00ed41 U.S.c. § 2{)1)1)(e}-5(t,{O a.nd P).
4. At all relevant ti:mm, Defendant, Amc:r:tanlnternilional GrQUP. Inc. ("AlG").lw been ooKl is now doing business in the Comm<mweallh ofPm.'1SYlvan!a iUld me City ofChadds FOrd m<I h.&R oon!muouMy luW. ill least J5 \lffiplQyee&.
5. AI all rekvllnt ti.!:::l\lS, Defundant EmplfJ:,w has oo!'!linl.l';)ll"iy been an amployer~ inaniOOustry at1l:ctingtommerce witlt:n Ow meaningoIScctions 701{hj, (g) and (h) of1irle VIT, 42l;$.C ~§ 200(1(e){b1 (g);;.nd (hl.
SiL\1Jl,M£tfI OF CtA:!M$
6. MOrt thanlhirty days: prim' to the iMtillltion of lhi;; lawm-n, Carolyn Dt>zier filed a
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Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 3 of 8
~,~rgc with 1Iw CQIIlIIl~on alleging violations o;;fTitle VlIb, Defmde.:rt Employu. AU OOnditiOIl~ precedent to the instimtion ofthj, lawMt have been f,JifillOO.
7. Sin.:e allea$t Man:h of20()4, Defendant Employtr hll$ Cfljpged in unlawful empklyment
proctict:! ~ :t! c,'lad& Foro. Pcnru:yl:vamlllrxalm in vIDlati01lllf~i<ln 703(a}( I) o;;t'TrtJe vn, 42
U.S.C ~ 2fl1)O(O).2(Il)!)), hy fzlling to pnm:ote hb. Dozier lind a clam; <:IfSlmilarlysiruated fenales which inclu6;s Rhonda Smith and T<Tt)' Mool': booauoo ofthnir!'lKe (Afric.w An::moOOl), based uplln indd-ents which include, but am not limi!~d to, the following:
{a) Carol,n Dozier 11M been crnployed with AIG~itICe February 26, 1996 and at aU rekMmt
Ijrn~ !wid th<; poaailion ofSenkl: Quality Sp<;t;'ialj.,'t R.Iwnda Smith w bea; ....np!oyed wid! AlG
eliteJIIfl(l 8. 1m and Mali rekWan! times, held the pm3t100ofQu.lltity AAIlllUlre Sp!cialtsL Teary
Moore has been employed "ritt AlG sinru Septem:.er of 1m lIlld ar all !1Jlevan! tirr.cs, held the
positioll of StWling.'Tmffic CoordjtlllWr within AlG's Natkmal Call Management Center. Ms. Doxier, M~ Smith and Ms. Mbote are AfricanAmric.an females.
(b) On or about JlI.!!!.Ii!1Y 8. 2Q(l4, two Qualit), ~ S~ poslnQtl$ hl:etlllC VIlI'A.Ot BOOt Ms. Dozior lind MI, Smith applied lOr lind were ilte:newed fur the ""1!illble Qw!ity Astumnec S'J?~isorposiU:ms:n February of 2004.
(c) Th~ knowledg~ and/or skills f!Xjuim;j fur Ih~ Quality A$$unmce Supen'i~or pOSitions ioc.:nded, but was not :imitOO to; (1) two)WI5 experience in a Mit cenicr opentioos trtVirtll\lnenl
including two ~ sqx:rvlwry ~mc"" and (2) wurtin!l1omw~ "fthe policies, JlfOCedln;I$
and pract:ices of the ca1! ttmtb' sates and st:r">'ire f'uncti;m fur J,u-tr; and homoownets Md gtnend bcsiucss 0pe!atjons of AJGM plus P&C ;i;x:nce.
(d) Both Ms. I)(,zjer Wid M~. Smith. were qualified fur the available Quality As~urance

Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 4 of 8
5up¢tYism positioll~ lIlld had !h" requirtd know!~ audio! skills required which include. but are not limlltil k' :be fuUl'wing: (1) /1.18, Dozier iw :v:rvW in DefeF(l:ant'$ QI.-'tI1i1) A!iSUIDIloo Depa:rtrncr:t JlIl " Quality A!W.mmce SpC<:laMt since Oct<:Jber of 1997 and as a S<:mior QlI3lity AlWttrU!Ce Speeialist sinee April of1002. She bas he.m 'e~PQnSjble fur managing anpl"yecs ar:.d projoc:. in her mie as II $tuior Quality Assurance Specialist for AIG 33d in he: p~ious employment; (2) M" Smith has served in ~t'$ Q.u.lity Assurance Dqnuunml >l.$ a Quality Assum:oce SpeeiallstiinceJlllyof:UiOIJ She also iw ::xperiem:e ~g ffilployee; and projects
:.as whLemnployed withAIG alld pri(l!'~Uory experi(1!oo III herpruvioi1S employment; Mal (J)
BoIh M~. Dozier lIlld Ms, SmilhiIDl proficient wilt Excel. (e) Tn ar:.d arelllld MIIlci: of2004, lhe (W(l Quality NiMll"MltC Supervisor potiii01Jll we:-c
awardctl Ie ,ess qll3lif.ed lIlldiw!eM experiene<:d white femalcs.
(f) On oraboul Ap.:il of2004, two Quality Special/stll posllions be.camnacant. Ms. Moore
applied fer ar:.d was interviewed IDr lin availableQua.lity Specialist i1 position.
(g) The knowledge and/or skill> n:qui~ for 6eQualitySpeci:uistnpositions included, bet
was nOI Ihrdtoo :0: (I) One year taperiellDe wilt. AlGas an ilQilfal1CC oonsuhant. customer Serv1ce
~tarive orothe:- !lIm"lienal ~ and (2) wmking knowledge mille peiicies, proeedure$ and
practiccsoft.1k. call cenfer sales Md ~ f.mction for m.!o ar.d homoownemt::id generailmine5s operations of.AlOM along with slrDng ."rbat and ,..Titter! rv:mmu!lication skills.
(h) Ms. MQQI"C was qualilled for :he available Quality ~ali$l; nposition and had Ix
I"e<J.uired knowledge llfIdfoukills reqL1!t'rl which include, b:!tare ndllnnited to, the fullowing: (\) ),{so MoJ;;re had over fOllf yean of direct expeti/)C(;C in Defendant'$ Cal! M 'oogem\!Jl~ Cetr.e~; and (2:):ID<,: had $(Jven yean; ~perier.<:t' In !he insura.~ irniustry.
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Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 5 of 8
(J) In iIDd amundMayof2004, the two Qt:<ilit'j Specialist llpcSitioru; were all'!ltded 10 less qlril.lified and/or le.;~ ~-ieI'.Cod white females.
S. SiIll::e at least Maxnof2004, Defenda:ll EmployerhM engag::d in nnlawful cmployMwt pr;u-t~ at iii: Chadds Ford, PeMs)1vania location in violation ofSlXltkm 704{aX I) ofTiDe Vll,':'.2 U.S.C. § 2000(ej-2(aX11 byretpJiating~t Ms.l}(lzier as r....UOl\o-,,:
(a) Follo.....1niS; her eun..selection fur ihe Quality Alk-ura:nce Supervisor position, Ms. Dozier :<Otified Dewooant'll HUIIlZJJ ResoWt'es rep:reswlillive of her belief thaI slm waa denied !he promotioo to the Supeniwryposition DuOO upon t.« rao::e.:;nd alleged iliscrirninati..m in amian:nmd Mav:h 0: 2004. Tbewaftcr. Ms. DOlier was given the lowes! IIllflW evaluaHoo she had ev;;r =cived since rnxo:ning ernploy>::d wlL'l Defend.ant.
9. The ~:Ject of the prnct1Ctl$ cmrplainerl of If) plU'll.gntphs ] and S, and their m$pCclive
&U~parts, above Jw bee:! to depriVt Carolyn Iftnicr and a clan of $imilarly ~ituatod A.f"rlcan b..".l1oocan females of equal employment opportu:nities, including prnmotionlud'l-1mecment in the wo:i:place. ar.d olbern,m adversely afIbet Ihcir stat..lS J$ Mlployee:s b:lewJSe "ftheir f!¢(>
9. 'The Iltli: complained ofin paragraptl$ 7 and 8, ar.d fucirrespC\.'"!;!vesub-pallil, above were
intentionaL
10. The Q"'llawfW. emp1oymen! pra;;;ices oompilQmd of in pMlgraphs 7 and &, am13leir respective.mb~ above wet>; I,.!one with rdl($S indi:ffe:en;;;¢ W the fedenlilyproteeted rigbTh of Carni)'l'l Dozier and aclas.s of !illilLtrlysilUtlted Afrka;; Amerit:an females as emp!oy¢es.
PRAJ"ERjlOR&ELfEF Whcrefure, the Cocunissiun respte:fuilyrequests lhat this Court: A. Gr"otapermanett in;unctkm eujo:iui!:zDetbJdarlt Empl¢yer, it~ llifJCtT>., WC(XlS:Wr.£,
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Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 6 of 8
assi!l}lS, lUld ail per~0C!8 it. acIive concert or panicipatioll wi:h :t, from engaging in ~oy othe: anployme01 prac:itc which discrL-n.i:nates 00 the bases qf race 3:ld!or re!alilll:ion.
B 000Defendant Employerto i!Witll.te~ tarry ;;rJtpolicies, pmt:Iitet4IlUdJlW~ whle.!': pmvieceq,.;a! mnploytncmopporu;..'1ities ror AfiicanA1nerioln employees, which ptTl'l'Ide for !Ill opportunity to b.~ pTUmoledlativWICc in the workplace, and which emdicate the elfOC!l of i!s past and pmWlt Ilr.l~wful mlP10ymcm pmmicO!L
C, ONer DeferuIa.nt Empln)l!;f to institute and C1UT'J out Mti-diP;;rimi!!.!l1ioo and ;mtj. .-ecalilllioo policies III!d ooncpl;ritlt pwccdtll'W;.
D. Orner Defendant Employer to institute and curry out complaint procooure~ which
enoourage emplo)'e£:$ :0 oome furwaru with. cOJO;llaints regardir.g vio:ations ofill! policiCl'. against
diserimiruttkm aM retaliation.
E. Order D<.;:~1rn. Ett:ployer to insti"tJle 3Jld OILTj" out a trainin,g prognm:: ".,hie:, shall
pcomoU" superviwr accountability imposing un all nWl>J.8C1"$ ahd supervisory pet"$(llttle1 a duty to aceivdymooironheif workareas roer,surerompEar.cewith policies oonon-di.ocdmirutkmand m:i.-ecaliallon: and ~uiring an m_gen lUld supervisort; to repc«1 any iJWk!ents aJtdJor romptamls of dioorimination and/or retaliation of whkh !hey bt>xime aware to !he depar\:nd1: chilfgtld with handling ~uch romplainll!_
F. Order Defendant Employer to!Il.!lk~ wht,je Carolyn I">oz:er and a c_;Q$$ of iiirniisrly situated fo:nal<lS by providing appNprilW: back pay, with prejudgm<:n! In\efes1. in::unounte to b¢ <k"~ned at trilIl, llld other afii."Tl'l.!ttive re!jefnu~ to eradicate !he effect, of itt uo;a",M emp!oyr:wllt prnct:lOO3.
G. Order Defendant Employer 10 make- whole Carolyn Do:tier and a clal!$ of~irni1i11"ly situated females 'j' f\llwidillg ("(Irup<:'JWt1on for past and.l'urute peet..1iary ~ MUlting f:uru !he
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Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 7 of 8 unhwib! employment practices descrlbt:d in parngruphs 7 and 8, and their re~live :rub-patt$, above, including, but not limited to out-of·pockct losse" in amounts to be determined lit trial.
IL On:\N Defendant Employerto m!lke whole Carolyn Do2ier:me. it c;ass ofsimiiJliy ~ilUaled fana!<;s byproviding roIllF~onfix pust;md future a~p~lI1Y iOliWll refu:lir.g from the UilJawf..!l practices rompia;aed ufin partlj;f<rphs 7 WH.I ~ and their respective SIl~pjftS. ahcve., including p.C1I Mid suffering,. humiliatron, emmJS#lMnt, loss oflift·s enjoyment anti ?;~
d~on, Wlriety onJ inc-Om'<IDleno:>, k'1 amounlS ro t>e dct~rnE>J It. trial
1 Order Defendanr Employer w pay Ca:olyn Dozier and :l.'C1l1S~ of similarly situated females plloirivc dmlages for il.5 malicious and te('kleGs nooduct describE>J in paragrnphs 7 and 8, artd thcirrespeclive sub-parts, aJxrve, in amounh to be del!m1lincd;tl trial.
J" Grant $ucb further rehciWI ~ Cllurt cooms n~e5sa:ry and prop.:r III t!'lf> publk
mtwM.
K. Awatd the Commiwioo its costs Qf this lICtiUll.
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Case 2:05-cv-05032-LS Document 1 Filed 09/21/2005 Page 8 of 8
J:JRY TRlAJ.DFMAtm
JAMES~LEf
DC]Xlly O=! C{llmsel
GWENDO\'mYO\~C REAMS
Ai$OCiale G.;n.;rtol Counm 'J.5. EQUAL EM!'LOYMENT OPPORn:},ITY COMMlSS10N 1110 I L. Slrem, NW WMlbington, DC 2:1507
~ "'::'.C ' ,!z.~ ftflJ)
Regional Attofl:lot'i
EQUAL EMP!..OYMENT UPPORTUNITY
COMMISSION Philadelphia District Offie" TIle Bour5(! BIdding 21 S,5"'Strtc:.t,SlIite400 Philadelphi&, FA 19196 teiephft:le (2lj) 44(1·2814
- . -....
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 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

EQUAL EMPLOYMENT OPPORTUNlTY COMMISSION,
Plaintiff,
v.
AIG MARKETING, INC. (a subsidiary of American International Group, Inc.)
Defendant.

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CIVIL ACTION NO.: 05-cv- 5032

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(LFS)

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J .::..:" '_ :J

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CONSENT DECREE

Introduction

A. This action was instituted by the U.S. Equal Employment Opportunity

Commission ("the EEOC" or "the Commission") on behalf of Carolyn Dozier and Rhonda Smith

on or about September 21, 2005 against AIG Marketing, Inc. (a subsidiary of American

International Group, Inc.) ("AIGM" or "Defendant"), alleging race discrimination and

retaliation, to enforce provisions of Title VII of the Civil Rights Act of 1964, as amended, 42

U.S.c. § 2000 ~ seq. ("Title VII"). AIGM denies any and all liability and has asserted Separate

Defenses in its Answer, including that its actions were for non-discriminatory business reasons.

B. The Commission and AIGM agree to the entry of this Consent Decree, which

shall fully and finally resolve all claims the EEOC raised in its Complaint in Civil Action No.

05 -cv-5032 (LFS). This Consent Decree shall not constitute either an adjudication of or finding

on the merits ofthe complaint and shall not be construed as an admission by AIGM of any

liability or wrongdoing.

C. This Consent Decree is entered into by the EEOC and AIGM shall apply to AIGM's Quality Assurance Department in Wilmington, Delaware (hereafter "Wilmington") and be final and binding between the EEOC and AIGM, its directors, officers, agents, successors and assigns.
Findings D. Having carefully examined the terms and provisions of this Consent Decree, and based on the pleadings, record and stipulations of the parties, the Court finds: (I) it has jurisdiction of the parties and subject matter jurisdiction of this action; and (2) the terms of this Decree are fair, reasonable, equitable and Just, and adequately protect the rights of the parties, and the public interest. NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:
Non-Discrimination and Non-Retaliation 1. This Court has jurisdiction over the parties and subject matter of this action. 2. AIGM is and will be committed to a workplace that provides equal opportunity to all of its employees and has in place EEO policies to provide such opportunities in all aspects of employment. AIGM has not and will not harass or discriminate against any Wilmington employee on the basis of race in violation of Title VII. 3. AlGM has not and will not engage in any employment practices which retaliate in any manner against any Wilmington employee, including but not limited to Carolyn Dozier and Rhonda Smith, because of that person's opposition to any practice made an unlawful employment practice under Title VII or because that person has made a charge, testified, assisted or participated in allY manner in any investigation, proceeding or hearing in this matter.
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4. AIGM shall provide Ms. Dozier and Ms . Smith with an original reference letter that only indicates Ms. Dozier's and/or Ms. Smith's start date, final title and end date and indicates that such limited disclosure is part of its business practice.
5. Nothing in this Consent Decree, either by inclusion or exclusion, shall be construed to limit the obligations of AIGM under Title VII or the EEOC's authority to process or litigate any charge of discrimination now pending or filed in the future by a Wilmington employee against AIGM.
Non-Injunctive Relief 6. In full settlement of the claims raised on their behalfby the EEOC against AIGM, AIGM agrees to pay Ms. Dozier a lump sum equivalent to twelve months of base salary, at $3,488.33 per month, less all lawful withholdings and Ms. Smith a lump sum equivalent to eleven and a half months of base salary, at $3,192.50 per month, less all lawful withholdings and Ms. Dozier and Ms. Smith will be executing releases between themselves and AlGM under which they have elected to leave AIGM's employ. The payments set forth above will be made within fourteen (14) days after the later of: (i) AIGM's receipt of the releases executed by Ms. Dozier and Ms. Smith and (ii) the entry of this Consent Decree by the Court. Ms. Dozier's and Ms. Smith's respective checks will be mailed to their private attorney, Michele Rovinsky, Esquire, and copies of each check within five (5) business days thereafter shall be sent to Stephanie Marino, Trial Attorney, EEOC Philadelphia District Office, 21 S. 5th Street, The Bourse, Suite 400, Philadelphia, Pa. 19106. Late payment of the check to Ms. Dozier or Ms. Smith shall be subject to accrual of interest on the unpaid amount calculated pursuant to 28 U.S.c. § 1961.
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Posting of Notice 7. Within 20 business days after entry of this Decree, AIGM shall post at Wilmington a copy of the Notice attached as Exhibit A to this Decree. The Notice shall remain posted for one year from the date of entry of this Decree. AIGM shall forward a certification that the Notice has been posted and dates of posting within 30 days after entry of this Decree to Stephanie Marino, Trial Attorney, EEOC, 21 South Fifth Street, Suite 400, Philadelphia, PA 19106-2515. If posted copies become defaced, removed, marred or otherwise illegible, AIGM agrees to post a readable copy in the same manner as heretofore specified. Non-Discrimination and Anti-Harassment Policies and Complaint Procedures 8. AIGM agrees to disseminate to all Wilmington employees another copy of its policy against race discrimination, harassment, retaliation and describing its complaint procedures within 60 days within the date of the Consent Decree.
Training 9. AIGM shall provide traini ng on the requirements of Title VII as follows :
a. AIGM agrees to provide a training session by Morgan, Lewis & Bockius LLP, on or before November 30, 2007, for any employee or employees responsible for responding to Title VII complaints made by any Wilmington employee. The training will cover emp loyer obligations under both Title VII and relevant state or local anti-discrimination laws.
b. AIGM shall provide training in accordance with Paragraph 9(a) in acco rdance with its reh'Ular training cycle for the duration of this Decree.
10. AIGM agrees to provide the EEOC with copies of its pamphlets, brochures, outlines or other written materials to be provided to attendees of training sessions.
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II . AIGM agrees to provide written confirmation to the EEOC in writing within 30 business days after the training session required by Paragraph 9 has occurred indicating that the training has taken place.
Dispute Resolution 12. In the event either party to this Decree beli eves the other party has failed to comply with any provision(s) of the decree, the complaining party shall notify the other party of the alleged non-compliance within 20 days of the alleged non-compliance and afford the alleged non-complying party 20 business days to remedy the alleged non-compliance or to satisfy the complaining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged non-compliance or satisfied the complaining party that it has complied within 20 business days, the complaining party may apply to the Court for appropriate relief. In such instance, the prevailing party shall be entitled to recover its reasonable attorneys' fees and costs.
Miscellaneous Provisions 13 . Each party to this Decree shall bear its own expenses, costs and attorney's fees . 14. The terms of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, successors and assigns of AIGM in their capacities as representatives, agents, directors and officers of AIGM and not in their individual capacities. This paragraph shall not be construed as placing any limit or remedies available to the Court in the event any individual is found in contempt for a violation of this Decree.
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15 . The Consent Decree shall fully and finally resolve all claims which were raised by the EEOC in its Complaint in Civil Action No. 05-cv-5032 (LFS), and upon expiration of this Consent Decree, this matter shall be dismissed by the Court with prejudice.
16. The Consent Decree shall be filed in the United States District Court for the Eastern District of Pennsylvania and shall continue in effect for eighteen (18) months. During this time, this Court shall retain jurisdiction over this matter and the parties for purposes of enforcing compliance with the Decree, including issuing such orders as may be required to effectuate its purposes. Any application by any party to modify or vacate this Consent Decree during such period shall be made by motion to the Court on no less than 30 days' notice to the other party.
17 . The Clerk of the District Court is hereby directed to send a file-stamped copy of this Consent Decree to counsel of record.
[SIGNATURE PAGE FOLLOWSI
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For Plaintiff EEOC :
Ronald S. Cooper General Counsel
James L. Lee Deputy General Counsel
Gwendolyn Young Reams Associate General Counsel Washington, D.C.

For Defendant AlG Marketing, Inc., a subsidiary of American International Group, Inc.}:

a

egional Attorney
~~ Q CI(J ~

Judith A. O' Boyle

;;

Supervisory Trial Attorney

Jud' hE. Harris, Esquire rgan, Lewis & Bockius LLP
1701 Market Street Philadelphia, PA 19103 (215) 963-5028

Steph ie Marino Trial Attorney Equal Employment Opportunity Commission Philadelphia District Office 21 S. 5th Street, Suite 400 Philadelphia, PA 19106 (215) 440-2828
r;;Jr- ~ By"'" eo," ~ENCEF.~L
UNITED STATES DISTRICT JUDGE
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Date:_ _J~-F(J-f,-.!:.t-,-6_ _ _
I
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<; _ Ko"..:V\()
;:J- 0 l'gpf (e
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A . I-\-o.r..... ()II)
c.:r _Me.- J0o.. .y-

EXHIBIT A

NOTICE TO ALL AIG MARKETING. INC. EMPLOYEES

Tbis Notice is posted pursuant to a Consent Decree entered by tbe federal court for the Eastern District of Pennsylvania resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against AIG Marketing, Inc. ("AIGM"). AIGM denied all of the EEOC's allegations and nothing in the Consent Decree constitutes any finding of any wrongdoing by AIGM.
Title vn of the Civil Rights Act of 1964,42 U.S.c. § 2000e et seq., as amended ("Title
Vn"), prohibits discrimination against employees and applicants for employment based upon
national origin, sex, race, color or religion. Title vn further prohibits retaliation against
employees or applicants who avail themselves of their rights under Title VII by engaging in protected activities, such as filing a charge of discrimination and/or testifying or participating in a Commission investigation. The EEOC is the federal agency which investigates charges of unlawful employment discrimination. The EEOC has the authority to bring lawsuits in federal court to enforce Title VII.

AIGM is committed to a workplace that provides equal opportunity to all of its employees and has in place EEO policies to provide such opportunities in all aspects of employment. AIGM reaffirms these policies and will not discriminate on the basis of race or retaliate against any person because he or she opposed any practice made unlawful by Title VII, filed a Title VII charge of discrimination, participated in any Title VII proceeding, or asserted any rights under the Consent Decree. AIGM has, and will continue to, provide training to assure that its EEO policies are fully implemented.

Any inquiries regarding this notice should be directed to the HR Department. If you beli eve you have been discriminated against, you continue to have the right to contact the EEOC at (215) 440-2600. The EEOC charges no fees and has employees who speak languages other than English.

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE

This Notice must remain posted for one (1) year from the date below and must not be

altered , defaced or covered by any other material. Any questions about this Notice or

compliance with its terms may be directed to the Regional Attorney, EEOC Philadelphia District

ce, 21 South 5t\Stre;t: Philadelphia. PA 19106.

. . ~9);tJ

_ _ _ _ _ _ __

. .S. Equal Employment Opportunity Commission
DATED: II/raO'/06

AIG Marketing, Inc. DATED: ____________________

 
 Case: 2:05-cv-5032 As of: 05/27/2017 04:16 PM EDT 1 of 4
CLOSED,CASREF,STANDARD
United States District Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:05−cv−05032−LS

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. Date Filed: 09/21/2005

AIG MARKETING, INC.

Date Terminated: 07/26/2010

Assigned to: HONORABLE LAWRENCE F. STENGEL

Jury Demand: Plaintiff

Referred to: MAGISTRATE JUDGE LINDA K. CARACAPPA Nature of Suit: 442 Civil Rights:

(Settlement)

Employment

Cause: 42:2000e Job Discrimination (Employment)

Jurisdiction: U.S. Government Plaintiff

Plaintiff

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

represented by JACQUELINE H. MCNAIR U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 801 MARKET ST. PENTHOUSE, SUITE 1300 PHILADELPHIA, PA 19107 215−440−2666 Email: jacqueline.mcnair@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

JUDITH A. O'BOYLE EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 21 S. 5TH ST STE 400 PHILADELPHIA, PA 19106 215−440−2687 Email: judith.oboyle@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

STEPHANIE MARINO U.S. E.E.O.C. 801 MARKET ST. PENTHOUSE, SUITE 1300 PHILADELPHIA, PA 19107 215−440−2841 Email: stephanie.marino@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Defendant
AMERICAN INTERNATIONAL GROUP, INC. TERMINATED: 04/06/2006

represented by ALTON A.J. HARMON MORGAN LEWIS & BOCKIUS LLP 1701 MARKET STREET PHILADELPHIA, PA 19103 215−963−5493 TERMINATED: 04/06/2006 LEAD ATTORNEY
JUDITH E. HARRIS MORGAN LEWIS & BOCKIUS LLP 1701 MARKET ST PHILADELPHIA, PA 19103 215−963−5000 Fax: 215−963−5299

Case: 2:05-cv-5032 As of: 05/27/2017 04:16 PM EDT 2 of 4

Email: jeharris@morganlewis.com TERMINATED: 04/06/2006 LEAD ATTORNEY

SARAH ELISE PONTOSKI MORGAN LEWIS & BOCKIUS LLP 1701 MARKET STREET PHILADELPHIA, PA 19103−2921 215−963−5000 Email: spontoski@morganlewis.com ATTORNEY TO BE NOTICED

Defendant
AIG MARKETING, INC. (A SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, INC.)

represented by ALTON A.J. HARMON (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

JUDITH E. HARRIS (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

SARAH ELISE PONTOSKI (See above for address) ATTORNEY TO BE NOTICED

Date Filed 09/21/2005 09/21/2005 09/21/2005 11/02/2005
11/18/2005 11/25/2005 12/20/2005 12/20/2005

# Docket Text
1 COMPLAINT against AMERICAN INTERNATIONAL GROUP, INC. , filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.(ti, ) (Entered: 09/22/2005)
One Original Summons Issued as to AMERICAN INTERNATIONAL GROUP, INC.. Forwarded To: Counsel on 9/22/05 (ti, ) (Entered: 09/22/2005)
DEMAND for Trial by Jury by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. (ti, ) (Entered: 09/22/2005)
2 WAIVER OF SERVICE Returned Executed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. AMERICAN INTERNATIONAL GROUP, INC. waiver sent on 10/4/2005, answer due 12/5/2005. (cdd, ) (kmk, ). (Entered: 11/02/2005)
3 ANSWER to Complaint and Separate Defenses by AMERICAN INTERNATIONAL GROUP, INC., Certificate of Service. (HARRIS, JUDITH) Modified on 11/21/2005 (np). (Entered: 11/18/2005)
4 NOTICE of Hearing: RULE 16 CONFERENCE SET FOR 12/20/2005 AT 1:30 PM IN JUDGE'S CHAMBERS BEFORE HONORABLE LAWRENCE F. STENGEL. (pac,) (Entered: 11/25/2005)
5 Minute Entry for proceedings held before Judge LAWRENCE F. STENGEL : Pretrial Conference held on 12/20/05, Total time: 20 minutes. (mac, ) (Entered: 12/20/2005)
6 SCHEDULING ORDER: TELEPHONE STATUS CONFERENCE SET FOR 4/17/2006 10:00 AM BEFORE HONORABLE LAWRENCE F. STENGEL. DISCOVERY DUE BY 6/30/2006. MOTIONS DUE BY 7/31/2006. RESPONSES TO MOTIONS DUE 8/14/06. PLAINTIFF'S EXPERT REPORTS SHALL BE PROVIDED TO DEFENDANTS BY 8/31/06. ANY RESPONSES THERETO SHALL BE FILED BY 9/29/06. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 12/20/05. 12/20/05 ENTERED AND COPIES MAILED AND E−MAILED.(mac, ) (Entered: 12/20/2005)

Case: 2:05-cv-5032 As of: 05/27/2017 04:16 PM EDT 3 of 4

01/20/2006 01/24/2006 01/25/2006
04/06/2006
04/17/2006 04/18/2006 04/19/2006
05/09/2006 05/11/2006 05/16/2006 06/22/2006 08/10/2006 08/10/2006
08/14/2006

7 Application of Alton A.J. Harmon, Esquire, to be admitted to practice in this Court pro hac vice filed by AMERICAN INTERNATIONAL GROUP, INC., statement, certificate of service. (mac, ) Modified on 1/23/2006 (mac, ). (Entered: 01/23/2006)
8 Disclosure with Certificate of Service by AMERICAN INTERNATIONAL GROUP, INC..(HARRIS, JUDITH) (Entered: 01/24/2006)
9 ORDER THAT THE APPLICATION OF ALTON A.J. HARMON, ESQUIRE, TO PRACTICE IN THIS COURT PURSUANT TO LOCAL RULE OF CIVIL PROCEDURE 83.5.2(b) IS GRANTED . SIGNED BY JUDGE LAWRENCE F. STENGEL ON 1/25/06. 1/26/06 ENTERED AND COPIES MAILED AND FAXED.(mac, ) (kmk, ). (Entered: 01/26/2006)
10 STIPULATION AND ORDER THAT THE CAPTION IN THIS CASE SHALL BE AMENDED TO REMOVE "AMERICAN INTERNATIONAL GROUP, INC." AS DEFENDANT AND TO SUBSTITUTE IN ITS PLACE "AIG MARKETING, INC. (A SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, INC., ETC.. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 04/06/06. 04/06/06 ENTERED AND COPIES MAILED AND FAXED.(ac, ) (kmk, ). (Entered: 04/06/2006)
11 NOTICE of Appearance by SARAH ELISE PONTOSKI on behalf of AMERICAN INTERNATIONAL GROUP, INC. with Certificate of Service (PONTOSKI, SARAH) (Entered: 04/17/2006)
12 Minute Entry for proceedings held before Judge LAWRENCE F. STENGEL : Telephone Conference held on 4/18/06, total time: 10 minutes. (mac, ) (Entered: 04/18/2006)
13 ORDER THAT THE ABOVE MATTER IS REFERRED TO MAGISTRATE JUDGE LINDA K. CARACAPPA FOR A SETTLEMENT CONFERENCE. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 4/19/06. 4/20/06 ENTERED AND COPIES MAILED, FAXED AND E−MAILED.(mac, ) Modified on 4/20/2006 (mac, ). (Entered: 04/20/2006)
14 Minute Entry for proceedings held before Judge LAWRENCE F. STENGEL : Telephone Conference held on 5/5/06, Total time: 10 minutes. (mac, ) (Entered: 05/09/2006)
15 ORDER THAT A SETTLEMENT CONFERENCE IS SET FOR 7/25/2006 AT 10:00 AM IN JUDGE'S CHAMBERS BEFORE MAGISTRATE JUDGE LINDA K. CARACAPPA. SIGNED BY JUDGE LINDA K. CARACAPPA ON 5/11/06. 5/11/06 ENTERED AND COPIES MAILED AND E−MAILED.(mac, ) (Entered: 05/11/2006)
16 First MOTION for Discovery Responses filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.Certificate of Counsel and Certificate of Service.(MARINO, STEPHANIE) (Entered: 05/16/2006)
17 ORDER THAT BY CONSENT OF THE PARTIES, PLAINTIFF EEOC'S MOTION TO COMPEL IS HEREBY WITHDRAWN. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 6/22/06.6/22/06 ENTERED AND COPIES MAILED AND E−MAILED. (mac, ) (Entered: 06/22/2006)
18 STIPULATION to Dismiss Claims Brought on Behalf of Terry Morre by AIG MARKETING, INC.. (PONTOSKI, SARAH) (Entered: 08/10/2006)
19 MOTION for Summary Judgment filed by AIG MARKETING, INC..Memorandum of Law, Statement of Material Facts, Proposed Order and Certificate of Service. (Attachments: # 1 Memorandum of Law# 2 Statement of Material Facts# 3 Appendix Index, Exs. A − K# 4 Appendix Exs. L − U# 5 Appendix Exs V − DD# 6 Appendix Excerpts − Deposition of T. Clark# 7 Appendix Excerpts − Deposition of C. Dozier# 8 Appendix Excerpts − Deposition of R. Helfter# 9 Appendix Excerpts − Deposition of L. Martindale# 10 Appendix Excerpts − Deposition of T. Raval# 11 Appendix Excerpts − Deposition of R. Smith# 12 Appendix Excerpts − Deposition of S. Smith)(PONTOSKI, SARAH) (Entered: 08/10/2006)
20 STIPULATION AND ORDER THAT PLAINTIFF EEOC IS GRANTED AN EXTENSION UNTIL SEPTEMBER 19, 2006 TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT, DEFENDANT IS GRANTED UNTIL

Case: 2:05-cv-5032 As of: 05/27/2017 04:16 PM EDT 4 of 4

08/18/2006 09/14/2006 09/14/2006 09/26/2006 10/10/2006 10/23/2006 11/02/2006 12/05/2006
12/13/2006 07/26/2010

OCTOBER 3,2006 TO FILE AREPLYBRIEF. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 8/11/06. 8/14/06 ENTERED AND COPIES FAXED BY CHAMBERS.(mac, ) (kmk, ). (Entered: 08/14/2006)
21 ORDER THAT THE CLAIMS OF THE PLAINTIFF BROUGHT ON BEHALF OF TERRY MOORE SHALL BE DISMISSED WITH PREJUDICE. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 8/18/06. 8/21/06 ENTERED AND COPIES MAILED AND FAXED.(mac, ) (kmk, ). (Entered: 08/21/2006)
22 Second Stipulation for Extension of Time to File Response/Reply by Stipulation filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.Stipulation.(MARINO, STEPHANIE) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED TO JUDGE FOR APPROVAL) Modified on 9/18/2006 (np). (Entered: 09/14/2006)
23 STIPULATION AND ORDER THAT PLAINTIFF EEOC IS GRANTED AN EXTENSION UNTIL SEPTEMBER 26, 2006 TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT. DEFENDANT IS GRANTED AN EXTENSION UNTIL OCTOBER 10, 2006 TO FILE A REPLY BRIEF . SIGNED BY JUDGE LAWRENCE F. STENGEL ON 9/14/06. 9/15/06 ENTERED AND COPIES MAILED AND FAXED.(mac, ) (kmk, ). (Entered: 09/15/2006)
24 RESPONSE in Opposition re 19 MOTION for Summary Judgment filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. (Attachments: # 1 Proposed Order, MSJ Response & Certificate of Service# 2 Statement of Disputed Material Facts# 3 Appendix with Exhibits A − U# 4 Exhibits V−GG# 5 Exhibits − Depo Transcripts)(MARINO, STEPHANIE) (Entered: 09/26/2006)
25 REPLY to Response to Motion re 19 MOTION for Summary Judgment filed by AIG MARKETING, INC.. (PONTOSKI, SARAH) (Entered: 10/10/2006)
26 ORDER THAT ORAL ARGUMENT ON THE MOTION FOR SUMMARY JUDGMENT IS SET FOR 11/2/2006 AT 2:00 PM IN COURTROOM 3B BEFORE HONORABLE LAWRENCE F. STENGEL. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 10/23/06. 10/23/06 ENTERED AND COPIES MAILED, E−MAILED.(mac, ) (Entered: 10/23/2006)
27 ORDER THAT ORAL ARGUMENT ON THE MOTION FOR SUMMARY JUDGMENT PREVIOUSLY SCHEDULED FOR NOVEMBER 2, 2006 HAS BEEN RESCHEDULED FOR FOR 1/11/2007 AT 10:00 AM IN COURTROOM 3B BEFORE HONORABLE LAWRENCE F. STENGEL. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 11/1/06. 11/2/06 ENTERED AND COPIES MAILED, E−MAILED.(mac, ) (Entered: 11/02/2006)
28 CONSENT ORDER THAT HAVING CAREFULLY EXAMINED THE TERMS AND PROVISIONS OF THIS CONSENT DECREE, AND BASED ON THE PLEADINGS, RECORD AND STIPULATIONS OF THE PARTIES, THE COURT FINDS: (1) IT HAS JURISDICTION OF THE PARTIES AND SUBJECT MATTER JURISDICTION OF THIS ACTION; AND (2) THE TERMS OF THIS DECREE ARE FAIR, REASONABLE, EQUITABLE AND JUST, AND ADEQUATELY PROTECT THE RIGHTS OF THE PARTIES, AND THE PUBLIC INTEREST. NOW THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED AS OUTLINED HEREIN. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 12/5/06. 12/6/06 ENTERED AND COPIES MAILED.(mac, ) (kmk, ). (Entered: 12/06/2006)
29 ORDER THAT THE CLERK OF COURT MARK THIS ACTION CLOSED FOR STATISTICAL PURPOSES AND PLACE THE MATTER IN THE CIVIL SUSPENSE FILE.. SIGNED BY JUDGE LAWRENCE F. STENGEL ON 12/13/06. 12/13/06 ENTERED AND COPIES MAILED, E−MAILED.(mac, ) (Entered: 12/13/2006)
30 ORDER DISMISSING ACTION WITH PREJUDICE PURSUANT TO LOCAL RULE 41.1(b). SIGNED BY HONORABLE LAWRENCE F. STENGEL ON 07/26/2010. 07/26/2010 ENTERED AND COPIES MAILED, E−MAILED AND FAXED.(pac,) (Entered: 07/26/2010)