WILLIAM TAMAYO, REGIONAL ATTORNEY 1 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 2 SAN FRANCISCO DISTRICT OFFICE
350 THE EMBARCADERO, SUITE 500 3 SAN FRANCISCO, CA 94105-1260

4 KATHRYN OLSON, SUPERVISORY TRIAL ATTORNEY
MOLLY KŰÇŰK, TRIAL ATTORNEY 5 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
6 909 FIRST AVENUE, SUITE 400 SEATTLE, WA 98104
7 TEL: (206) 220-6892

8 ATTORNEYS FOR PLAINTIFF
9

10

11

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ALASKA

12

13
EQUAL EMPLOYMENT OPPORTUNITY

14 COMMISSION,

CIVIL ACTION NO.

15
Plaintiff
16
v.
17

COMPLAINT JURY TRIAL DEMAND

18 ZALE CORPORATION,

19

Defendant.

20

21

NATURE OF THE ACTION

22
This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil
23
24 Rights Act of 1991 to correct unlawful employment practices on the basis of sex/pregnancy and
25 to provide appropriate relief to Christina Kantarzis (“Ms. Kantarzis”). The Equal Employment

COMPLAINT- Page 1 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (206) 220-6911
TDD: (206) 220-6882

Opportunity Commission alleges that defendant subjected Ms. Kantarzis to disparate treatment
1
2 when it failed to promote her to a management position on the basis of her sex/pregnancy. 3 Plaintiff seeks monetary relief, including pecuniary and nonpecuniary compensatory and

4 punitive damages and injunctive relief, on behalf of Ms. Kantarzis.

5

JURISDICTION AND VENUE

6
1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§451, 1331, 1337,
7
1343 and 1345. This action is authorized and instituted pursuant to sections 706(f)(1) and (3) of
8
Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. sections 2000e-5(f)(1) and (3)
9

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

11

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

12 jurisdiction of the United States District Court for the District of Alaska.

13

PARTIES

14
3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is
15
the agency of the United States of America charged with the administration, interpretation and
16

enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) of
17

18 Title VII, 42 U.S.C. §2000e-5(f)(1).

19

4. At all relevant times, defendant Zale Corporation (“Zale”) has been a corporation

20 continuously doing business in the State of Alaska and has continuously had at least 15

21
employees.
22
5. At all relevant times, defendant Zale has continuously been an employer engaged
23
in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title
24
25 VII, 42 U.S.C. §§2000e-(b), (g) and (h).

/ / /
COMPLAINT- Page 2 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (206) 220-6911
TDD: (206) 220-6882

STATEMENT OF CLAIMS
1

2

6. More than thirty days prior to the institution of this lawsuit, Ms. Kantarzis filed a

3 charge with the Commission alleging violations of Title VII by defendant Zale. All conditions

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

5

7. Since May 9, 2006, defendant Zale engaged in unlawful employment practices at

6
its Anchorage, Alaska facility in violation of §§ 703(a) of Title VII, 42 U.S.C. §§ 2000e-2(a).
7
The practices include the failure to promote Ms. Kantarzis to a management position because of
8
her sex/pregnancy.
9

10

8. The effect of the practices complained of in paragraph 7 above has been to

11 deprive Ms. Kantarzis of equal employment opportunities.

12

9. The unlawful employment practices complained of in paragraph 7 above were

13 intentional.
14
10. The unlawful employment practices complained of in paragraph 7 above were
15
done with malice or with reckless indifference to Ms. Kantarzis’ federally protected rights.
16
PRAYER FOR RELIEF
17

18

Wherefore, the Commission respectfully requests that this Court:

19

A. Grant a permanent injunction enjoining defendant, its officers, successors, agents,

20 assigns, and all persons in active concert or participation with it, from engaging in any
21
employment practices which discriminate on the basis of sex/pregnancy.
22
B. Order defendant to institute and carry out policies, practices, and programs which
23
provide equal employment opportunities for all employees, and which eradicate the effects of its
24
25 past and present unlawful employment practices.

COMPLAINT- Page 3 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (206) 220-6911
TDD: (206) 220-6882

C. Order defendant to make whole Ms. Kantarzis by providing appropriate back pay
1
2 with prejudgment interest, in amounts to be determined at trial, and other affirmative relief 3 necessary to eradicate the effects of its unlawful employment practices.

4

D. Order defendant to make whole Ms. Kantarzis by providing compensation for past

5 and future pecuniary losses resulting from the unlawful employment practices described in
6
paragraph 7 above, including past and future out-of-pocket expenses, in amounts to be
7
determined at trial.
8
E. Order defendant to make whole Ms. Kantarzis by providing compensation for past
9
10 and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph

11 7 above, including without limitation emotional pain, suffering, and loss of enjoyment of life, in

12 amounts to be determined at trial.

13

F. Order defendant to pay Ms. Kantarzis punitive damages for its malicious and

14
reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
15
G. Grant such further relief as the Court deems necessary and proper in the public
16

interest.
17

18

H. Award the Commission its costs of this action.

19 / / /

20 / / /
21
/ / /
22
/ / /
23
/ / /
24

25
/ / /
COMPLAINT- Page 4 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (206) 220-6911
TDD: (206) 220-6882

JURY TRIAL DEMAND
1

2

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

3

DATED this 15th day of March , 2007.

4

5 WILLIAM TAMAYO Regional Attorney
6
KATHRYN OLSON 7 Supervisory Trial Attorney

RONALD COOPER General Counsel
JAMES L. LEE Deputy General Counsel

8
MOLLY KŰÇŰK 9 Trial Attorney

GWENDOLYN Y. REAMS Associate General Counsel

10
BY: /s/ William Tamayo _________ 11 EQUAL EMPLOYMENT OPPORTUNITY 12 COMMISSION
13 San Francisco District Office 350 The Embarcadero, Suite 500
14 San Francisco, California 94105-1260

15 Seattle Field Office 16 909 First Avenue, Suite 400
Seattle, Washington 98104 17 Telephone (206) 220-6892

Office of the General Counsel 1801 “L” Street NW Washington, D.C. 20507

18

Attorneys for Plaintiff

19

20

21

22

23

24

25

COMPLAINT- Page 5 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (206) 220-6911
TDD: (206) 220-6882

 
 1 WILLIAM R TAMAYO, REGIONAL ATTORNEY EQUAL EMPLOYMENT OPPORTUNITY
2 COMMISSION SAN FRANCISO DISTRICT OFFICE
3 350 THE EMBARCADERO, SUITE 500 SAN FRANCISCO, CA 94105-1260
4 JOHN F. STANLEY, SUPERVISORY TRIAL ATTORNEY
5 MOLLY KUCUK, TRIAL ATTORNEY EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
6 909 FIRST AVE., SUITE 400 SEATTLE, WA 98104
7 TEL: (206) 220-6892

8

IN THE UNITED STATES DISTRICT COURT

9

FOR THE DISTRICT OF ALASKA

10 EQUAL EMPLOYMENT
11 OPPORTUNITY COMMISSION,

No. A07-cv-00033 (JWS)

12

Plaintiff,

CONSENT DECREE

13

v.

14 ZALE CORPORATION,

15

Defendant

16

I. INTRODUCTION

17 1. This action originated when Christina Kantarzis (“Charging Party”) filed a charge
18 (“Charge”) with the Equal Employm ent Opportunity Comm ission (“EEOC” or 19
“Commission”) on June 27, 2006. Kantarzis alleged that Za le Corporation (“Zale”) in 20
Anchorage, Alaska discriminated against her based upon her sex (pregnancy) in violation 21 22 of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, at seq. (“Title VII”) when
23 she was denied prom otion to the position of store m anager of the S ears Mall Zales

24 Jewelers (“Zales”) location.

25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 1 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

1

2. On January 3, 2007, the EEOC issued a letter of determ ination with a

2 finding of reasonable c ause that Zale violated Title VII when Ms. Kantarz is was not

3 promoted to the Sears Mall store manager position. Thereafter, the EEOC attempted to
4 conciliate the charge, but the parties could not reach agreement.
5 3. The Commission filed its Lawsuit on March 15, 2007, in the United States
6 7 District Court for the District of Alaska (T he “Lawsuit”). The Lawsuit alleges tha t Zale
8 violated Title VII by failing to promote Ms. Kantarzis because of her sex (pregnancy).

9

4. Defendant denies the allegations of discrimination in Kantarzis’ charge of

10 discrimination and in the Lawsuit, and asse rts there was no discrim ination against the

11 Charging Party.

12

5. The parties want to conclude fully and finally all claims arising out of the

13 EEOC’s Lawsuit and the Charge of discrimination filed with the EEOC by Christina

14 Kantarzis. The parties agree that it is in their mutual interest to resolve this matter fully

15 without the expense and delay of litigation. The parties agree that this Decree may be
16 entered into without Findings of Fact and Conclusions of Law being made and entered by
17
18 the Court.

19

II. JURISDICTION AND VENUE

20

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

21 1337, 1343 and 1345. This action is authorized pursu ant to Sections 706(f)(1) and (3) of

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

23 and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. The employment

24

25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 2 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

1 practices alleged to b e unlawful in the co mplaint filed herein occurred within in the 2 jurisdiction of the United States District Court for the District of Alaska.

3 III. SETTLEMENT SCOPE
4 7. This Consent Decree is the final and complete resolution of all allegations
5 of unlawful employment practices contained in Kantarzis’ discrimination Charge, in the
6 7 EEOC’s administrative determinations, and in the Lawsuit filed herein. The Decree,
8 including any requirements herein, is limited in scope to the Region as defined herein.

9 The Region as used in this Consent Decree is defined as all employees, including

10 managers, at Zales Jewelers stores in the State of Alaska (the “Region”).

11

8.

Zale’s voluntary agreem ent to entry of this Consent Decree shall not be

12 deemed as an adm ission of liability, and none of the parties to this Lawsuit shall be
13 deemed a prevailing party. There has been no judicial determination in the Lawsuit that
14

15 Zale has violated any law, or der, or regulation of the U nited States or of any state

16 regarding its employment practices or policie s. Nothing in th is Consent Decree sha ll be

17 construed to limit or reduce Zale’s obligation to fully comply with Title VII of the 1964

18 Civil Rights Act, as amended, the Equal Pay Act, the Age Discrimination in Employment

19 Act, and th e Americans with Disa bilities Act, or the regulations promulgated pursuant

20 thereto.
21

22

IV. MONETARY RELIEF

23 9. In settlement of this Lawsuit, Zale agrees to pay Christina Kantarzis $55,000.00
24

25 less deductions required by law. Paym ent will be made directly to Ms. Kantarzis a t an

EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 3 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400

Seattle, Washington 98104-1061

Telephone: (206) 220-6883

Facsimile: (206) 220-6911

TDD: (206) 220-6882

1 address to be provided by the EEOC. Payment will be made within twenty (20) days after

2 this Consent Decree is entered by the Court.

3

V. INJUNCTIVE AND OTHER RELIEF

4

A. General Provisions

5

10. Zale, its officers, agents, and employ ees in the Region shall not engage in

6 practices which unlawfully discriminate against applicants and/or employees on the basis
7 of sex (pregnancy). In recogn ition of its obligation und er Title VII, Zale agrees to
8
9 evaluate its policies and practices set forth below.

10

B. Anti-Discrimination Policies and Procedures

11

11. Zale shall carry out anti-discrim ination policies, procedures and training for

12 employees, supervisors and management personnel in the R egion and will prov ide equal

13 employment opportunities for all employees consistent with its obligations under the law.
14 Zale shall evaluate and, where appropriate, modify the practices of its m anagers and 15
supervisors in the Region in order to preven t discrimination in em ployment. Zale shall 16
communicate its Equal Em ployment Opportunity (“EEO) policies to its m anagers and 17 18 supervisors in the Region, and provide a certif ication to ensure that these m anagement
19 and supervisory employees have received the policies.

20

12. Within one hundred twenty (120) days of the effective date of this Consent

21 Decree, Zale shall: (a) evalua te its EEO polic y to ensure that it ade quately prohibits

22 unlawful discrimination against employees in the Region on the basi s of sex (pregnancy)

23 and addresses Zale’s obligation to provide a discrimination-free work environment for its
24

employees; and (b) distribute this written EEO policy to all present employees and future 25

EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 4 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400

Seattle, Washington 98104-1061

Telephone: (206) 220-6883

Facsimile: (206) 220-6911

TDD: (206) 220-6882

1 employees in the Region both m anagement and non-m anagement. Zale shall provide

2 EEOC with a written copy of its EEO policy.

3

C. Training

4

13. Within one hundred twenty (120) da ys of the execution of this Consent

5 Decree, Zale shall p resent all management and supervisory employees in the Regio n at

6 least 2 hours of training on em ployment discrimination issues, including discrim ination

7 against employees based on sex (pregnancy).

8

14. Zale shall notify the EEOC of the completion of the training and shall specify

9 the names and job titles of all m anagers and supervisory employees in the Region who

10 participated in and completed the training as part of its annual reporting to the EEOC.

11

D. Expungement of Records

12

15. Zale shall expunge from its files all copies of Ms. Kantarzis’ charge of

13 discrimination or this lawsuit from her personnel files, the Regional Manager file, and the

14 Director of Stores Manager file.

15

E. Policies Designed to Promote Supervisory Accountability

16

16. Zale shall im pose appropriate discipline up to and including term ination,

17 suspension without pay or de motion, upon any supervisor or m anager in the Region who
18 discriminates against any em ployee on the basis of sex (pregnancy). Zale shall state this
19

20 policy in a communication to all of its supervisors and managers in the Region.

21

17. An indi vidual’s handling of EEO m atters shall be tak en into accou nt when

22 Zale evaluates the performance of managers and supervisors and in any consideration of

23 their promotions in the Region. 24

25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 5 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

1

18. Zale shall include compliance with the equal employment opportunity laws as

2 a consideration for qualification for supervisory positions in the Region.

3

F.

Reporting

4

19. Zale shall repo rt in writing and in affidavit form to the EEOC, for the

5 duration of this Consent Decree, the following information.

6

a. Certification of the com pletion of 2 hour s of training to m anagers and

supervisory employees in the Region, as refe renced in paragraph 14 hereof, and a list of 7 attendees;

8

b. Certification that its EEO policy has b een distributed to all current employees

and new employees in the Region; 9

c. Certification of the Expungem ent of all copies of the lawsuit brought by the 10 EEOC and the complaint of discrimination made by Ms. Kantarzis from files as described

11 in paragraph 16;

12

d. A copy of its EEO policies and procedures which concern or affect the subject

of discrimination or retaliation;

13

e. A copy of the anti-discrim ination training materials presented to m anagement 14 and supervisory employees in the Region;

15

f. For the duration of this Consent Decr ee, Zale shall annually submit a summary

16

of sex and pregnancy discrimination complaints, if any, by applicants or employees in the Region against Zale that are reported to Hu man Resources or to the Shared Serv ices

17 Center and the resolution of each complaint; and

18

g. Following the expiration of the term of this Decree, a statement certifying that

Zale has complied with Paragraph 17 & 18 of the Decree. If Zale has not compiled with 19 Paragraph 17 & 18 of the Decree, th e statement will specify the areas of noncom pliance,

20 the reason for the noncompliance, and the steps taken to bring Zale into compliance.

21

G. Posting

22

20. Zale will post a Notice, attached as Exhibit 1 to this Consent Decree. The

23 Notice shall be posted at all stores in the Region for the duration of this Consent Decree. 24

25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 6 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

1

VI. ENFORCEMENT

2

21. If the EEOC determ ines that Zale ha s not com plied with the term s of thi s

3 Decree, the EEOC will provide written notification, v ia certified mail, of the alleged
4 breach to th e office of t he General Counsel of Zale at 901 W. Walnut Hill Lane, 6A,
5 Irving, TX 75038, and to Ralph C. Pond, Be nedict Garratt Pond, PLLC, 1000 Second
6 7 Ave. 30th Floor, Seattle, W A 98104 . The EEO C will not petition the court for
8 enforcement of the decree for at least thirty (30) days after providing written notification

9 of the alleged breach, and only in the event Za le does not substantially cure the alleged

10 breach. The thirty (30)-day period following the written notice shall be used b y the

11 parties for good faith efforts to resolve the dispute. 12

13

VII. RETENTION OF JURISDICTION

14

22. The United States District Court of the District of Alaska shall retain

15 jurisdiction over this matter for the duration of the decree.

16

VIII. DURATION AND TERMINATION

17 23. This Decree shall be in effect for two (2) years beginning the date this Court
18 enters this Consent Decree. If the EEOC petitions the Court for breach of the Decree,
19

20 and the Court finds Zale to be in violation of the terms of the Decree, the Court may

21 extend the duration of the Decree.

22

IX.ATTORNEYS’ FEES, EXPENSES AND COSTS

23

24. Each party shall bear its own attorney s’ fees, expenses and costs incurred

24 in this case.
25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 7 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

1

X. CONCLUSION

2 25. The parties are not bound by any provision of this decree until it is signed by
3 authorized representatives of each party and entered by the Court.
4

5

DATED this 3d day of July, 2007

6

WILLIAM R. TAMAYO Regional Attorney

7

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

8

San Francisco District Office 350 Embarcadero, Suite 500

San Francisco, CA 94105-1260 9 JOHN F. STANLEY

10

Supervisory Trial Attorney Molly P. Kucuk

11 Trial Attorney

RONALD S. COOPER GENERAL COUNSEL
JAMES E. LEE Deputy General Counsel Gwendolyn Young Reams Associate General Counsel

12 By:___/s/ Bill Tamayo__________

13

_________________

EQUAL EMPLOYMENT

14 OPPORTUNITY COMMISSION

15 Seattle Field Office 909 First Avenue, Suite 400
16 Seattle, WA 98104 (206) 220-6916
17 Facsimile (206) 220-6911

Office of the General Counsel 1801 “L” Street, N.W. Washington, D.C. 20507

18

19

Attorneys for Plaintiff

20 Dated this 3rd day of July, 2007

21 Robertson, Monagle & Eastaugh

22
By___/s/ Robert Blasco_____________________ 23 Robert P. Blasco, AK Bar No. 7710098
Counsel for Defendant Zale Corporation 24

25
EEOC v. Zale Corporation
26 Proposed Consent Decree and Order
Page 8 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

 
 U.S. District Court District of Alaska (Anchorage) CIVIL DOCKET FOR CASE #: 3:07−cv−00033−JWS

CLOSED

Equal Employment Opportunity Commission v. Zale Corporation Assigned to: John W. Sedwick Cause: 28:451 Employment Discrimination
Plaintiff

Date Filed: 03/15/2007 Date Terminated: 07/09/2007 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Defendant

Equal Employment Opportunity Commission

represented by Kathryn B. Olson Equal Employment Opportunity Commission 909 First Avenue, Suite 400 Seattle , WA 98104−1061 206−220−6895 Fax: 206−220−6911 Email: kathryn.olson@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Molly P. Kucuk Equal Employment Opportunity Commission 909 First Avenue, Suite 400 Seattle , WA 98104−1061 206−220−6892 Fax: 206−220−6911 Email: molly.kucuk@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

William R. Tamayo Equal Employment Opportunity Commission (SanFrancisco) 350 The Embarcadero, Suite 500 San Francisco , CA 94105−1260 415−625−5645 Fax: 415−625−5657 Email: william.tamayo@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Zale Corporation

represented by Robert Blasco Hoffman Silver Gilman &Blasco (Juneau) 9360 Glacier Hwy, Suite 202 Juneau , AK 99801 907−586−3340 Fax: 907−586−6818 Email: rpblasco@hsgblaw.com ATTORNEY TO BE NOTICED

Date Filed 03/15/2007

#

Docket Text

1 COMPLAINT against Zale Corporation , filed by Equal Employment Opportunity Commission.(PXS, COURT STAFF)

03/16/2007 04/18/2007 04/18/2007 04/18/2007 04/19/2007
05/07/2007 05/07/2007 05/10/2007 05/10/2007
06/07/2007 06/11/2007
06/14/2007 07/03/2007 07/03/2007
07/03/2007

(Entered: 03/16/2007)
Summons Issued as to Zale Corporation. (PXS, COURT STAFF) (Entered: 03/16/2007)
3 NOTICE of Appearance by Robert Blasco on behalf of Zale Corporation (Blasco, Robert) (Entered: 04/18/2007)
4 First MOTION for Extension of Time to File Answer unopposed by Zale Corporation.(Blasco, Robert) (Entered: 04/18/2007)
5 MEMORANDUM by Zale Corporation 4 First MOTION for Extension of Time to File Answer unopposed filed by Zale Corporation,. (Blasco, Robert) (Entered: 04/18/2007)
6 TEXT ORDER re: 4 Motion for Extension of Time to Answer: Defendant's motion at docket 4 to extend the time to file an answer is GRANTED. The answer shall be filed no later than May 7, 2007. Defendant is warned that the court is unlikely to grant a further extension. [THIS IS A TEXT ONLY ORDER. THERE IS NO PDF DOCUMENT ATTACHED.] (GMM, COURT STAFF) (Entered: 04/19/2007)
7 ANSWER to Complaint of EEOC by Zale Corporation.(Blasco, Robert) (Entered: 05/07/2007)
8 CERTIFICATE OF SERVICE by Zale Corporation re 7 Answer to Complaint (Blasco, Robert) (Entered: 05/07/2007)
9 STATUS REPORT ORDER (16b) Status Report due by 6/7/2007. (RMC, COURT STAFF) (Entered: 05/10/2007)
Docket Annotation: The parties are advised that a review of the service on this case has revealed that counsel for plaintiff was not being electronically served. The error has been corrected and an electronic copy of docket has been e−mailed to the following addresses: molly.kucuk@eeoc.gov, mary.hammock@eeoc.gov,kathryn.olson@eeoc.gov, william.tamayo@eeoc.gov (NKD, COURT STAFF) (Entered: 05/10/2007)
10 STATUS REPORT JOINTLY SUBMITTED by Equal Employment Opportunity Commission. (Kucuk, Molly) (Entered: 06/07/2007)
11 JWS TEXT ORDER re 10 Status Report: The court has reviewed the status report at docket 10. Unless closing papers are sooner filed, an updated status report shall be filed on July 13, 2007. [THIS IS A TEXT ONLY ORDER. THERE IS NO PDF DOCUMENT ATTACHED.(GMM, COURT STAFF) (Entered: 06/11/2007)
12 NOTICE by Equal Employment Opportunity Commission NOTICE OF UNAVAILABILITY OF COUNSEL (Kucuk, Molly) (Entered: 06/14/2007)
13 STIPULATION CONSENT DECREE by Equal Employment Opportunity Commission. (Attachments: # 1 Proposed Order # 2 Notice to Employees)(Kucuk, Molly) (Entered: 07/03/2007)
14 [DUPLICATE FILING] STIPULATION CONSENT DECREE by Equal Employment Opportunity Commission. (Attachments: # 1 Proposed Order # 2 Notice to Employees)(Kucuk, Molly) Modified on 7/9/2007 to indicate duplicative filing.(RMC, COURT STAFF). (Entered: 07/03/2007)
Docket Annotation: The parties are advised that the Stipulation Consent Decree at dkt 14 is a duplicative filing to dkt 13 and should disregard as duplicative. (RMC, COURT STAFF)

07/09/2007 07/17/2007 07/17/2007 07/17/2007 07/25/2007

(Entered: 07/09/2007)
15 ORDER granting 13 Stipulation Consent Decree; this lawsuit is hereby dismissed with prejudice and without costs or attorneys fees to any party. Signed by Judge John W. Sedwick on 7/9/07. (RMC, COURT STAFF) (Entered: 07/09/2007)
16 Joint MOTION to Amend/Correct Unopposed Stipulated Motion and Order to Substitute Exhibit A to Consent Decree by Zale Corporation.(Blasco, Robert) Modified on 7/17/2007 to reflect Error: the proposed order and Exhibit A should have been filed as Attachments to the motion; Correction: Attorney to refile the document and attach the proposed order and Exhibit A.(RMC, COURT STAFF). (Entered: 07/17/2007)
Docket Annotation: Error: re 16 Joint MOTION to Amend/Correct; The proposed order and Exhibit A should have been filed as Attachments to the motion at dkt 16; Correction: Motion terminated; Attorney to refile the document and attach the proposed order and Exhibit A. (RMC, COURT STAFF) (Entered: 07/17/2007)
17 Joint MOTION to Amend/Correct Unopposed Stipulated Motion and Order to Substitute Exhibit A to consent Decree by Zale Corporation. (Attachments: # 1 Exhibit Exh. A# 2 Proposed Order Order)(Blasco, Robert) Modified on 7/18/2007 to create relationship to document #13 (RMC, COURT STAFF). (Entered: 07/17/2007)
18 JWS TEXT ORDER re: 17 Motion to Amend/Correct: The joint motion at docket 17 is GRANTED as follows: The Notice to Employees filed as exhibit 1 to the motion at docket 17 is hereby substituted for the Notice to Employees attached to the consent decree. [THIS IS A TEXT ONLY ORDER. THERE IS NO PDF DOCUMENT ATTACHED.] (GMM, COURT STAFF) (Entered: 07/25/2007)

 
 NOTICE TO EMPLOYEES
This notice has been posted pursuant to a Consent Decree, entered on _____, approving the resolution of a lawsuit brought by the U.S. Equal Employment Opportunity Commission (“EEOC”) against Zale Corporation (“Zale” or “The Company”), in the United States District Court for the District of Alaska, Case No. 3:07-cv-00033-JWS. The Consent Decree resolves EEOC’s claims of pregnancy discrimination brought against the Company, and enjoins it from certain conduct prohibited by law. Zale denies the allegations in the EEOC’s lawsuit. Federal law and the Consent Decree prohibit discrimination against any individual because of sex or pregnancy.
In accordance with the Consent Decree, Zale will provide anti-discrimination training to all management and supervisory employees in Alaska; distribute its EEO policy to all employees in Alaska; evaluate and where appropriate modify its policies to encourage supervisor accountability with regard to anti-discrimination practices; and report to the EEOC all complaints of pregnancy and/or sex discrimination it receives for the next 2 years.
Federal law also prohibits retaliation against any individual by an employer because the individual complains of discrimination, cooperates with any Investigation of a charge of discrimination, participates as a witness or potential witness in any investigation or legal proceeding, or otherwise exercises his or her rights under the law.
Should you have any complaints of discrimination, you should contact Employee Relations or Shared Services immediately at ________.
Employees also have the right to bring complaints of discrimination or harassment to the U.S. Equal Employment Opportunity Commission, Seattle Field Office at:
909 1st Avenue, Suite 400 Seattle, WA 98104-1061 (206) 220-6883 or 1 (800) 669-4000
This notice shall remain prominently posted at Zale Corporation stores in Alaska for the duration of the Consent Decree referred to above, until ______. This Official Notice shall not be altered, defaced, covered or obstructed by any other material.
EXHIBIT A