Case 2:04-cv-00994-KJD-GWF Document 1 Filed 07/19/2004 Page 1 of 5
OHIGINAL

1 Anna Y. Park Peter F. Laura
2 U.S. EQUAL EMPLOYMENT OPPORTlN"ITY COMMISSION
3 255 E. Temple Street, 4th Floor Los Angeles, CA 90012
4 Telephone: (213) 894-1076 Fa~simile: (213) 894-1301
5 Attorneys for Plaintiff
6 u..s. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
7

m~ JUL I q A 10: 5]

- 1:-

_.j; "! C::JtJRT

J~'~'; .t<,:- :. r il~ VALiA

8

UNITED STATES DISTRICl

CV-S-04-0994-K.fD-PAL

9

DISTRICT OF NEVAJ

10

U.S. EQUAL EMPLOYMENT

) CASE NO

11 OPPORTUNITY COMMISSION,

)

) COMPLAINT -

12

Plaintiff,

) CIVIL RIGHTS EMPLOYMENT

) DISCRIMINATION

13

v.

)

) 29 U.S.c. § 621 et seq.

14 CAYALlER, INC d/bla CAV ALlER

)

RESTACRANT AND LOUNGE, and ) DEMAND FOR TRIAL BY JURY

15 •. DOES l-10, Inclusive.

)

)

16

Defendants.

)

17

18

NATURE OF THE ACTION

19

This is an employment discrimination action brought by the United States Equal

20· Employment Opportunity Commission (the "Commission") under the Age Discrimination in

21 Employment Act of 1967, as amended, 29 U.S.c. §§ 621 et seq., (the "ADEA"), to correct

22 unl awful employment practices on the basis of age and to provide appropriate relief to the

23 Charging Party, June Jones ("Ms. Jones" or "Charging Party") and a similarly situated person
i
24, who was over the age of forty (40), Eva Medley. The Commission alleges that the Defendant

25 i tenninated Ms. Jones, Ms. Medley, and similarly situated individuals because of their age, in

26 violation of the ADEA.
1
27! III
I
28 I III
1

Case 2:04-cv-00994-KJD-GWF Document 1 Filed 07/19/2004 Page 2 of 5

1

JURISDICTION AND VENUE

2

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. sections 451.. 1331,

3 1337, 1343 and 1345. This action is authorized and instituted pursuant to section 7(b) of the

4 ADEA, 29 U.S.c. § 626(b), which incorporates by reference sections 16(c) and 17 of the Fair

5 Labor Standards Act of 1938, as amended, 29 U.S.C. §§ 216(c) and 217.

6

The employment practices alleged herein to be unlawful were committe:dl within

7 tbe jurisdiction of the United States District Court for the District of Nevada.

8

PARTIES

9

Plaintiff Commission is an agency of the United States of America charged with

10 tYe administration, interpretation and enforcement of ADEA and is expressly authorized to bring

11 this action under § 7(b) of the ADEA, 29 U.S.C. § 626(b), as amended by section 2 of

12 Reorganization Plan No.1 of 1978, 92 Stat. 3781 and by Public Law 98-532 (1984) 98 Sta'.

13 2705.

14

4. Plaintiff is ignorant of the true names and capacities of Defendants sued as DOES

15 1 through 10, inclusive, herein and therefore Plaintiff sues said Defendants by such fictitious

16 names. Plaintiff reserves the right to amend the complaint to name the DOE defendants

17 individually or corporately as they become known. Plaintiff alleges that each of the Defendants

18· named as DOES was in some manner responsible for the acts and omissions alleged herein and

19 Plaintlff will amend the complaint to allege such responsibility when same shall have been

20 i ascertained by Plaintiff.

21

5. All of the acts and failures to act alleged herein were duly performed by anel

22 attributable to all Defendants, each acting as a successor, agent, employee or under the direction

23 and control of the others, except as otberwise specifically alleged. Said acts and failures tc act

24 were '.>"ithin the scope of such agency andlor employment, and each Defendant participatec in,

approved andlor ratified the unlawful acts and omissions by other Defendants compla:ined )f

berein. \Vhenever and where ever reference is made in this Complaint to any act by a Dekndant

27 cr Defendants, such allegations and reference shall also be deemed to mean the acts and fallures

28! to act of each Defendant acting individually, jointly, andlor severally.

2

Case 2:04-cv-00994-KJD-GWF Document 1 Filed 07/19/2004 Page 3 of 5

1

6. At all relevant times, Defendant Cavalier, Inc. d/bla Cavalier Restaurant and

2 Lounge, has continuously been doing business in Clark County in the State of Nevada.

3 Defendant has continuously employed twenty (20) or more employees.

4

7.

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

5 i industry affecting commerce within the meaning of §§ 2000e-1 (b), (g) and (h) and §§ 11 (b), (g),

6 and (h) of the ADEA, 29 US.C. §§ 630(b), (g) and (h).

7

8. If is further alleged on information and belief that the unnamed Defendants in the

8 complaint are mere alter egos ofDefendant. The remaining Defendants are properly named in this

9 complaint.

10

CONCILIATION

9. Prior to institution of this lawsuit, the Commission's representatives attempted to

12' eliminate the unlawful employment practices alleged below and to effect voluntary compliance

13 with ADEA through informal methods of conciliation, conference and persuasion within the

14 illI~anir.g of section 7(b) of the ADEA, 29 US.C. § 626(b). All conditions precedent to the

15: institution of this lawsuit have been fultilled.

16

STATEMENT OF CLAIMS

17 I

10. More than thirty (30) days prior to the institution of this lawsuit, Ms. Jones filed a

!
18; cf.arge of discrimination with the Commission alleging violations of the ADEA by Defendant.
I
19 The Commission issued a Letter of Determination finding that Ms. Jones and other similarly

20 I, si':uated persons were terminated because they were ages forty (40) or above in violation of the

21 ADEA.

22

11. Since at least in or about August 2000, Defendant has engaged in unlawful

23 employment practices at its facility in Las Vegas, Nevada in violation of the ADEA, 29 U5,.C.

24' § 623(a), The unlawful employment practices include Defendant's termination of Ms. Joms

25 becam,e of her age, then sixty-six (66) years of age and Ms. Medley because of her age, then

26 sixty-four (64) years of age. Reasons given for their termination were pretextual and improperly

27 based upon their age.
28:1 II.'

3

Case 2:04-cv-00994-KJD-GWF Document 1 Filed 07/19/2004 Page 4 of 5

1

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

2 to deprive Ms. Jones and Ms. Medley of equal employment opportunities and to otherwise

3 adversely affect their status as an employee because of their age.

4

13. The unlawful employment practices complained of above were and are wi llful

5 wiThin the meaning of section 7(b) of the ADEA, 29 U.S.C. § 626(b).

6

PRAYER FOR RELIEF

7

Wherefore, the Commission respectfully requests that this Court:

8.

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

9 I assigns and all persons in active concert or participation with them, from engaging in any

10 employment practices which discriminate on the basis of age;

11

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

12 provide equal employment opportunities for persons forty (40) years of age and older, and which

13 eradicate the effects of their past and present unlawful employment practices;

14

c.

Grant a judgment requiring Defendant to pay Ms. Jones and Ms. Medley

15 appropriate back pay, front pay, and benefits in an amount to be determined at trial,

16

D. Grant liquidated damages because of the willful nature of the actions alleged

17 herein, prejudgment and post judgment interest;

181

E. Order Defendant to make whole Ms. Jones and Ms. Medley by providing

19 affirmative relief necessary to eradicate the effects of its unlawful practices including, but nJt

20 limited to, payment of front pay to Ms. Jones and Ms. Medley and/or rightful place employment;

21 //1

22 //1

23 Iii
24 ./1'/

25 /1'"/

26 I' • ,1/

27

., '
/1/

28

./ I' "

4

Case 2:04-cv-00994-KJD-GWF Document 1 Filed 07/19/2004 Page 5 of 5

1

F. Grant such further relief as the Court deems necessary and proper in the publi,;

2 interest;

3

IJ~. Award the Commission its costs in this action.

4

JURY DEMAND

51

The Commission requests a jury trial on all questions of fact raised by its Complaint.

61 71 Date:

Respectfully Submitted By:

8

ERIC DREIBAND

9

General Counsel

10

JAMES LEE

Deputy General Counsel

11

GWENDOLYN REAMS,

12

Associate General Counsel

l3

U.S. EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

14

1801 "L" Street, N.W.

Washington, D.C. 20507

15 i 16

~i3

_.--"'/

ANNA Y. PARK,

17

Regional Attorney

19 20 21 22 23
1
24 25
26
I tp
27 28

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 255 East Temple Street, 4th Floor Los Angeles, CA 90012
5

 
 Case 2:04-cv-00994-KJD-GWF Document 20-1 Filed 02/03/2006 Page 1 of 8

1 UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
2 ANNA Y. PARK PETER LAURA
3 255 East Temple Street, 4th Floor Los Angeles, CA 90012
4 (213) 894-1076

5 Attorneys for Plaintiff

6 FISHER & PHILLIPS LLP CRAIG ANNUNZIATA, ESQ.
7 Admitted Pro Hac Vice 420 Marquette Building
8 140 South Dearborn Street Chicago, IL 60603
9 (312) 346-8061

10 FISHER & PHILLIPS LLP 3993 Howard Hughes Parkway
11 Suite 650 Las Vegas, NV 89109
12 (702) 252-3131

13 Attorneys for Defendant

CAVALIER, INC.

14

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

15

16 U.S. EQUAL EMPLOYMENT )

OPPORTUNITY COMMISSION, )

17

)

)

18

Plaintiff,

)

)

19 v.

)

)

20 CAVALIER, INC. d/b/a CAVALIER)

RESTAURANT AND LOUNGE, )

21

)

)

22

Defendant.

)

23

CASE NO.: CV S-04-0994 KJD (PAL) PROPOSED CONSENT DECREE
I.

24

INTRODUCTION

25

Plaintiff U.S. Equal Employment Opportunity Commission (hereafter, the "EEOC" or

26 "Commission") and Defendant Cavalier, Inc. d/b/a Cavalier Restaurant and Lounge (hereafter,

27 "Cavalier") hereby stipulate and agree to entry of this Consent Decree to resolve the Commission's

28

-1-

Case 2:04-cv-00994-KJD-GWF Document 20-1 Filed 02/03/2006 Page 2 of 8

1 Complaint filed in the United States District Court, District of Nevada on July 19, 2004, captioned

2 U.S. Equal Employment Opportunity Commission v. Cavalier, Inc. d/b/a Cavalier Company, Case

3 No. CV S-04-994 KJD (PAL) (the "Complaint") pursuant to the Age Discrimination in

4 Employment Act of 1967, as amended, 29 U.S.C. 621 et seq. ("ADEA"). This Consent Decree

5 resolves all issues raised by the EEOC in the present lawsuit with regard to the Charging Party,

6 June Jones ("Jones") and Claimant, Eva Medley ("Medley").

7

II.

8

PURPOSES AND SCOPE OF THE CONSENT DECREE

9

A. The parties to this Consent Decree ("Decree") are the EEOC and Cavalier. The

10 scope of this Decree includes Cavalier's operations at all of its restaurants which it owns or operates

11 in the state of Nevada. This Decree shall be binding on and enforceable against Cavalier and its

12 officers, directors, agents, successors and assigns.

13

B. The parties have entered into this Decree to avoid the inconvenience, uncertainty

14 and costs associated with further litigation. It is understood that this Consent Decree does not

15 constitute any admission by Cavalier that it engaged in any discrimination or wrongful conduct

16 with respect to Jones or Medley at any time.

17

III.

18

RELEASE OF CLAIMS

19

A. This Decree fully and completely resolves all issues, claims and allegations by the

20 EEOC against Cavalier that are raised in the Complaint.

21

B. Nothing in this Decree shall be construed to preclude the Commission from bringing

22 suit to enforce this Decree in the event that Cavalier fails to perform the promises and

23 representations contained herein.

24

C. Nothing in this Decree shall be construed to limit or reduce Cavalier's obligation to

25 comply fully with the ADEA or any other federal employment statute.

26

D. This Decree in no way affects the EEOC's right to bring, process, investigate or

27

28 -2-

Case 2:04-cv-00994-KJD-GWF Document 20-1 Filed 02/03/2006 Page 3 of 8

1 litigate other charges that may be in existence or may later arise against Cavalier in accordance with

2 standard EEOC procedures.

3

IV.

4

JURISDICTION

5

A. The Court has jurisdiction over the parties and the subject matter of this lawsuit.

6 The Complaint asserts claims that, if proven, would authorize the Court to grant the equitable

7 relief set forth in this Decree. The terms and provisions of this Decree are fair, reasonable and

8 just. This Decree conforms with the Federal Rules of Civil Procedure and ADEA and is not in

9 derogation of the rights or privileges of any person.

10

B. The Court shall retain jurisdiction of this action during the duration of the Decree

11 for the purposes of entering all orders, judgments and decrees that may be necessary to

12 implement the relief provided herein.

13

V.

14

EFFECTIVE DATE AND DURATION OF DECREE

15

A. The provisions and agreements contained herein are effective immediately upon

16 the date which this Decree is entered by the Court ("the Effective Date").

17

B. The duration of this Consent Decree shall be two years from the date of the Effective

18 Date. This Court shall retain jurisdiction of this action during the duration of this Consent Decree.

19

VI.

20

MODIFICATION AND SEVERABILITY

21

A. This Decree constitutes the complete understanding of the parties with respect to the

22 matters contained herein. No waiver, modification or amendment of any provision of this Decree

23 will be effective unless made in writing and signed by an authorized representative of each of the

24 parties.

25

B. If one or more provisions of the Decree are rendered unlawful or unenforceable, the

26 parties shall make good faith efforts to agree upon appropriate amendments to this Decree in order

27

28 -3-

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1 to effectuate the purposes of the Decree. In any event, the remaining provisions will remain in full

2 force and effect unless the purposes of the Decree cannot, despite the parties' best efforts, be

3 achieved.

4

VII.

5

COMPLIANCE AND DISPUTE RESOLUTION

6

A. The parties expressly agree that if the Commission has reason to believe that

7 Cavalier has failed to comply with any provision of this Consent Decree, the Commission may file

8 a motion before this Court to enforce the Decree. Prior to initiating such action, the Commission

9 will notify Cavalier and its legal counsel of record, in writing, of the nature of the dispute. This

10 notice shall specify the particular provision(s) that the Commission believes has/have been

11 breached. Absent a showing by either party that the delay will cause irreparable harm, Cavalier

12 shall have thirty (30) days to attempt to resolve or cure the breach.

13

B. The parties agree to cooperate with each other and use their best efforts to resolve

14 any dispute referenced in the EEOC notice.

15

C. After thirty days have passed with no resolution or agreement to extend the time

16 further, the Commission may petition this Court for resolution of the dispute, seeking all available

17 relief, including an extension of the term of the Decree for such period of time as Cavalier is shown

18 to be in breach of the Decree and the Commission's costs and attorneys’ fees incurred in securing

19 compliance with the Decree.

20

VIII.

21

MONETARY RELIEF

22

Within ten (10) business days of the Effective Date of this Decree, Cavalier shall pay to

23 Jones and Medley the gross amount of Fifty Thousand Dollars ($50,000) to be paid as follows:

24

(A) to Jones the sum of $47,000 (forty-seven thousand dollars); and

25

(B) to Medley the sum of $3,000 (three thousand dollars).

26

(C) The parties agree that Cavalier is not required to make any employer

27

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1

contributions, and will issue 1099 forms or the equivalent as required by law for the

2

payment made to each claimant.

3

A copy of the checks and accompanying transmittal papers shall be contemporaneously

4 forwarded to the EEOC.

5

IX.

6

GENERAL INJUNCTIVE RELIEF

7

A. Cavalier shall be enjoined at any of its locations from engaging in discrimination in

8 violation of the ADEA.

9

B. Cavalier shall revise its written policy on discrimination, and provide a copy to the

10 EEOC within sixty days after the Effective Date. The revised policy shall include a

11 clear objective anti-discrimination procedures which expressly prohibit discrimination on the basis

12 of race, color, national origin, sex, age, disability, creed/religion, or any other protected category.

13 This revised policy shall immediately be distributed to all of Cavalier's employees, including

14 management and/or supervisory staff, and shall be included in any relevant policy or employee

15 manuals distributed to employees by Cavalier. Cavalier shall collect acknowledgments from each

16 employee who receives the revised policy. In the event that it revises its anti-discrimination

17 procedures, Cavalier shall provide the EEOC with written notice within ten days after

18 implementation of any such revision by Cavalier. Throughout the term of this Decree, Cavalier

19 shall also post the revised policy in a place that is conspicuous and accessible to all employees at

20 each of its locations covered by this Decree in a legible font that is a minimum of 15 points in size.

21

C. Training

22

Within sixty days after the Effective Date all of Cavalier’s managerial/supervisory

23 employees shall be required to attend a training program of at least four hours with regard to

24 compliance under the ADEA. All those who did not attend this training shall have completed the

25 training within an additional thirty days. The training shall be mandatory. A roster containing the

26 names of all participants will be maintained by Cavalier and subject to inspection of the EEOC upon

27

28 -5-

Case 2:04-cv-00994-KJD-GWF Document 20-1 Filed 02/03/2006 Page 6 of 8

1 request.

2

1. All employees’ training shall include coverage of the subjects of equal employment

3

opportunity rights and responsibilities, including but not limited to ADEA’s prohibitions

4

against discrimination on the basis of age.

5

2. For the remainder of the term of this Decree, all new employees and all employees

6

recently promoted from a staff/hourly to a managerial position shall receive the managerial

7

or staff/hourly employee training, as appropriate, within thirty days of hire or promotion.

8

3. After the initial training as specified above, all employees shall receive the training

9

at least annually thereafter for the remainder of the term of this Decree.

10

4. Within forty-five days after the Effective Date, Cavalier shall submit to the EEOC a

11

description of the training to be provided and an outline of the curriculum developed for the

12

trainees. Cavalier shall give the EEOC a minimum of ten business days’ advance written

13

notice to the EEOC of the date, time and location of each training program provided

14

pursuant to this Decree, and agrees that a EEOC representative may attend any such training

15

program.

16

X.

17

RECORD KEEPING AND REPORTING

18

A. Record-Keeping

19

Cavalier shall submit annual EEO-1 reports as required by applicable law. Cavalier shall

20 maintain supporting documentation as required by applicable law. Cavalier shall maintain

21 employment applications and resumes as required by applicable law.

22

23

B. Reporting

24

1. Within ninety days after the Effective Date, Cavalier shall submit to the EEOC an

25 initial report which contains:

26

(a) A copy of the revised anti-discrimination policy;

27

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Case 2:04-cv-00994-KJD-GWF Document 20-1 Filed 02/03/2006 Page 7 of 8

1

(b) A statement confirming that the required notices pertaining to this Decree

2

have been posted; and

3

(c) Copies of all employee acknowledgment forms indicating receipt of the

4

revised anti-discrimination procedures;

5

(d) Copies of all materials used in the training sessions.

6

2. If Cavalier lays off any employees during the time period the Decree is in effect,

7 Cavalier will provide a list of employees laid off, their ages, and reasons for the lay-off.

8

XI.

9

COSTS OF ADMINISTRATION AND IMPLEMENTATION

10

OF CONSENT DECREE

11

Cavalier shall bear all costs associated with its administration and implementation of its

12 obligations under this Consent Decree.

13

XII.

14

COSTS AND ATTORNEYS' FEES

15

Each party shall bear its own costs of suit and attorneys' fees.

16

XIII.

17

MISCELLANEOUS PROVISIONS

18

A. During the term of this Consent Decree, Cavalier will comply with all applicable

19 laws regarding providing notice of this Decree to potential successors in interest.

20

B. The law of successorship liability shall apply to any ongoing obligations under this

21 Consent Decree if there is a change of ownership of Cavalier.

22

The parties agree to entry of this Decree and judgment subject to final approval by the

23 Court.

24

25

26

27

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1

EQUAL EMPLOYMENT

2

OPPORTUNITY COMMISSION

Anna Y. Park

3

Peter F. Laura

4

5 Date: __________________ 6

By: ___________/s/__________________ Anna Y. Park Attorneys for Plaintiff

7

8

9

10

FISHER & PHILLIPS LLP

Craig R. Annunziata

11

12 Date: __________________
13
14

By: _____________________________ Attorney for Defendant

15

16

[PROPOSED] ORDER

17

The provisions of the foregoing Consent Decree are hereby approved and compliance with

18 all provisions thereof is HEREBY ORDERED.

19

IT IS SO ORDERED.

20

21 Date: __________________

___________________________

22

The Honorable _______________

23

United States District Judge

24

25

26

27

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United States District Court District of Nevada (Las Vegas) CIVIL DOCKET FOR CASE #: 2:04-cv-00994-KJD-GWF

CLOSED

U.S. Equal Employment Opportunity Commission VS Cavalier, Inc,. etal Assigned to: Judge Kent J. Dawson Referred to: Magistrate Judge George W Foley, Jr
Magistrate Judge Lawrence R. Leavitt (Settlement)

Date Filed: 07/19/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
U.S. Equal Employment Opportunity Commission

represented by Anna Park U.S. Equal Employment Opportunity Commission 255 East Temple Street 4th Floor Los Angeles, CA 90012213-894-1083 Email: anna.park@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Peter F. Laura United States Equal Employment Opportunity Commission Legal Unit 255 East Temple Street 4th Floor Los Angeles, CA 90012(213) 894-1000 Fax: 213-894-1118 Email: peter.laura@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Cavalier, Inc.

represented by Craig Annunziata Fisher & Phillips LLP 420 Marquette Building 140 S. Dearborn St. Chicago, IL 60603 (312) 346-8061 Fax: (312) 346-3179 LEAD ATTORNEY

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ATTORNEY TO BE NOTICED
Cynthia A. Freeland Baker & McKenzie Wells Fargo Plaza, 12th Flr 101 W. Broadway San Diego, CA 92101(619) 236-1441 TERMINATED: 12/13/2004 LEAD ATTORNEY ATTORNEY TO BE NOTICED
David B. Dornak Lewis & Roca, LLP 3993 Howard Hughes Pkwy. Suite 600 Las Vegas, NV 89169 Email: ddornak@lrlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Lynn M. Hansen Jimmerson Hansen, P.C. 415 So. 6th Street Suite 100 Las Vegas, NV 89101 702-388-7171 Fax: 702-380-6406 Email: df@jimmersonhansen.com TERMINATED: 12/13/2004 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed
07/19/2004 07/19/2004 08/24/2004 09/10/2004 09/14/2004 09/14/2004

#

Docket Text

MISCELLANEOUS DOCUMENT (1) summs iss'd to P (Entered: 07/19/2004)
1 COMPLAINT Cmplt w/jury demand obo P. (Entered: 07/19/2004)
2 WAIVER OF SERVICE EXECUTED Notc of waiver of svc of summs by D obo P. (m) (Entered: 08/25/2004)
MISCELLANEOUS DOCUMENT 2 VPs/Desigs obo D. to KJD (Entered: 09/13/2004)
3 VERIFIED PETITION FOR PERMISSION TO PRACTICE PRO HAC VICE as to Craig Annunziata as pro hac cnsl for D. cps dis (Entered: 09/16/2004)
5 VERIFIED PETITION FOR PERMISSION TO PRACTICE PRO HAC VICE as to Cynthia Freeland as pro hac cnsl for D. cps dis (Entered: 09/16/2004)

2 of 4

5/21/2007 10:42 AM

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09/16/2004 09/21/2004 09/23/2004 09/24/2004 10/28/2004 11/03/2004
12/02/2004
12/10/2004 12/13/2004 01/14/2005 02/23/2005 02/25/2005 05/05/2005 05/06/2005 08/03/2005 08/23/2005 12/27/2005
01/05/2006 02/02/2006

4 DESIGNATION OF LOCAL COUNSEL Lynn Hansen named lcl cnsl for pro hac atty Annunziata #3 obo D. cps dis (Entered: 09/16/2004)
6 ANSWER TO COMPLAINT Answr to cmplt obo D. (m) (Entered: 09/22/2004)
7 NOTICE (OTHER) Notc of referral to ENE session before LRL. (Spec Ord #102 attch'd). cps dis (Entered: 09/23/2004)
8 ORDER ORD: An ENE session has been sched for 12-1-04 @ 9:30am before LRL. cps dis (Entered: 09/27/2004)
MISCELLANEOUS DOCUMENT disc plan. to PAL (Entered: 10/28/2004)
9 ORDER ON STIPULATION ORD: Disc exp 3-21-05, jnt stat rept due 1-20-05, dispo mtns due 4-20-05, jnt PTO due 5-20-05. cps dis (mag docs snt) (Entered: 11/05/2004)
10 MISCELLANEOUS HEARING re: ENE Session - ORD: Sttlmnt discussions underway. Ptys will engage in limited informal disc by 12-10-04. Cnsl will then report to Ct the status of the sttlmnt. cps dis (Entered: 12/03/2004)
MISCELLANEOUS DOCUMENT sub of attys. to KJD (Entered: 12/13/2004)
11 ORDER ON STIPULATION ORD: Ds subbs Fisher & Phillips in place and stead of Baker & McKenzie & Jimmerson Hansen. cps dis (Entered: 12/14/2004)
12 STATUS REPORT Interim stat rept obo D. (cpy to KJD & PAL) (Entered: 01/21/2005)
MISCELLANEOUS DOCUMENT stip to extnd disc. to PAL (Entered: 02/24/2005)
13 ORDER ON STIPULATION ORDER DISC ext: Disc due 7/19/05; mtns due 8/19/05; jt pto due 9/19/05. cpys dist. (Entered: 02/28/2005)
MISCELLANEOUS DOCUMENT Stip ext discv date, etc -- to KJD (Entered: 05/05/2005)
14 ORDER ON STIPULATION ORD: Disc cut-off 10/17/05; dispo mtns 11/17/05; jnt pto 12/18/05. (cps dist) (Entered: 05/11/2005)
15 NOTICE (OTHER) Ntc of settlement. (Entered: 08/03/2005)
16 ORDER ORD: mag judge GWF to be assigned. cps dist (Entered: 08/24/2005)
17 MINUTE ORDER IN CHAMBERS of the Honorable Kent J. Dawson, U.S. District Judge on 12/27/2005. By Deputy Clerk: Peggie Vannozzi. Counsel notified the Court on August 3, 2005 (#15) that this matter was settled and that they were workin out a consent decree. IT IS THE ORDER OF THE COURT that a Status Report OR the consent decree is due by 1/13/2006.(no image attached) (PAV, ) Modified on 12/27/2005 (PAV, ). (Entered: 12/27/2005)
18 STATUS REPORT Interim Status Report by Plaintiff U.S. Equal Employment Opportunity Commission. (Laura, Peter) (Entered: 01/05/2006)
19 SETTLEMENT AGREEMENT [Proposed] Consent Decree by Plaintiff U.S. Equal Employment Opportunity Commission. (Park, Anna) (Entered:

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02/03/2006 02/08/2006

02/02/2006)
20 SETTLEMENT AGREEMENT [Proposed] Consent Decree by Plaintiff U.S. Equal Employment Opportunity Commission. (Attachments: # 1 Signature Page)(Park, Anna) (Entered: 02/03/2006)
21 ORDER re 20 Settlement Agreement filed by U.S. Equal Employment Opportunity Commission,. Signed by Judge Kent J. Dawson on 2/6/06. (AXM, ) (Entered: 02/08/2006)

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