COURT
NORTHERN DISTRICT OF TEXAS .
FILED . :

IN THE UNITED STATES DISTRICT FOR THE NORTHERN DISTRICT OF

SEP 2 9 2003

DALLAS DIVISION

CLERK, U.S. DISTRICT COURT

EQUAL EMPLOYMENT OPPORTUNITY }

By ______~~---Deputy

COMMISSION,

Plaintiff,

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} COMPLAINT

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BLOCK'S LIGHTHOUSE SUPPER CLUB, }

INC., BLOCK'S LIGHTHOUSE INC.; BLOCK}

FAMILY INC.; THE LIGHTHOUSE

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CLUB, INC.; AND

}

V.F.B. FAMILY LIMITED PARTNERSHIP, } JURY TRIAL DEMANDED

}

}

}

Defendants.

}

------------------------------}

NATURE OF THE ACTION

This is an action under Title VII ofthe Civil Rights Act of 1964, as amended, and Title I of

the Civil Rights Act of 1991, to correct unlawful employment practices on the basis ofsex (female),

and to provide appropriate relief to Charging Party Allyson Bergstrom and other similarly situated

aggrieved individuals. The Equal Employment Opportunity Commission alleges that the Defendants

discriminated against Allyson Bergstrom because of her sex (female) in violation of Title VII, by

subjecting her to a sexually hostile work environment, resulting in her termination. The EEOC

further alleges that the Defendants violated Title VII when they subjected other similarly situated

aggrieved individuals to discrimination because of their sex (female), by subjecting them to a

sexually hostile work environment.

COMPLAINT

1

JURISDICTION AND VENUE 1. lurisdictionofthis Court is invokedpursuantto 28 U.S.C. §§451, 1331,1337,1343 and 1345. This action is authorized and instituted pursuant to Section 706(f) (3) of Title VII of the Civil Rights Act of 1964, as amended, ("Title VII"), 42 U.S.C. § 2000e-5 (f)(3), and Section 102 of the Civil Rights Act of 1991,42 U.S.C. § 1981A. 2. The employment practices alleged to be unlawful were and are now being committed within the jurisdiction of the United States District Court for the Northern District of Texas.
PARTIES 3. Plaintiff, Equal Employment Opportunity Commission ("the Commission"), is an agency of the United States of America charged with the administration, interpretation and enforcement of Title VII and is expressly authorized to bring this action by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. 2000e-5(f)(1) and (3). 4. At all relevant times, Defendants have continuously been and are now doing business in the State of Texas. 5. At all relevant times, Defendants have continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701 (b), (g) and (h) of Title VII, 42 U.S.C.§ 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, the Charging Party Allyson Bergstrom filed a charge of discrimination with the Commission, alleging violations of Title VII by the Defendants. All conditions precedent to the institution of this lawsuit have been fulfilled.

COMPLAINT

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7. Since at least January 2001, the Defendants have engaged in conduct in violation of Section 703(a)(1) ofTitle VII, 42 U.S.c. § 2000e-2(a)(1). Specifically, the Defendants discriminated against Charging Party Allyson Bergstrom and similarly situated aggrieved individuals based upon sex (female) by subjecting them to a sexually hostile work environment. The behavior complained of herein also resulted in the termination of Ms. Bergstrom. The Charging Party and aggrieved individuals were employed in Defendants' Lighthouse Supper Club. Throughout their employment, the Charging Party and other aggrieved individuals were subjected to sexual harassment, including but not limited to suggestive, lewd and offensive comments as well as unwelcome touching. The Defendants failed to have in place, and/or communicate to employees, a policy prohibiting such discriminatory treatment. Further, Defendants failed to take prompt, effective, remedial action to correct the conduct complained about by the Charging Party and other similarly situated aggrieved individuals.
8. The effect of the practices complained of in paragraph 7 above has been to deprive the Charging Party Allyson Bergstrom and other similarly situated aggrieved individuals of equal employment opportunities because of their sex.
9. The unlawful employment practices complained of in paragraph 7 were intentional. 10. The unlawful employment practices complained of in paragraph 7 above were committed with malice or with reckless indifference to the federally protected rights of Allyson Bergstrom and other similarly situated aggrieved individuals.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendants, their officers, successors,

COMPLAINT

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".

assIgns, and all persons in active concert or participation with them, from engaging in any employment practice which discriminates on the basis of sex.
B. Order the Defendants to institute and carry out policies, practices and programs that provide equal employment opportunities for Allyson Bergstrom and other similarly situated aggrieved individuals and other employees and which eradicate the effects of the Defendants' past unlawful employment practices.
C. Order the Defendants to make whole Allyson Bergstrom and other aggrieved individuals, by providing appropriate back pay with prejudgment interest, in amounts to be proved at trial, pecuniary damages, out-of-pocket losses and other affirmative relief necessary to eradicate the effects ofthe Defendants' unlawful employment practices, including but not limited to front pay in lieu of reinstatement.
D. Order the Defendants to make whole Allyson Bergstrom and other similarly situated aggrieved individuals by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 7 and 10, above, including but not limited to, emotional pain, suffering, inconvenience, loss of enjoyment oflife and humiliation, in amounts to be determined at trial.
E. Order the Defendants to make whole Allyson Bergstrom and other similarly situated aggrieved individuals by providing compensation for past and future pecuniary losses resulting from the unlawful practices complained of in paragraphs 7 and 10, above, in amounts to be determined at trial.
F. Order the Defendants to pay Allyson Bergstrom and other similarly situated aggrieved individuals punitive damages for its malicious conduct or reckless indifference described in

COMPLAINT

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paragraphs 7 and 10 above, in an amount to be determined at trial. G. Grant such further relief as the Court deems necessary and proper in the public
interest. H. Award the Commission its costs in this action. JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.
Respectfully submitted,
ERIC S. DREIBAND General Counsel ROBERT CANINO, Oklahoma Bar No. 11782 Regional Attorney
SUZANNE ANDERSON Texas Bar No. 14009470 Supervisory Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 S. Houston Street, 3rd Floor Dallas Texas 75202

COMPLAINT

5

 
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IN THE UNITED STATES DISTRICT COU FOR THE NORTHERN DISTRICT OF TE
DALLAS DIVISION

EQUAL EMPLOYMENT OPPORTUNITY }

COMMISSION,

}

}

Plaintiff,

}

}

v.

}

}

}

BLOCK'S LIGHTHOUSE SUPPER CLUB, }

INC., BLOCK'S LIGHTHOUSE INC.; BLOCK}

FAMILY INC.; THE LIGHTHOUSE

}

CLUB, INC.; AND

}

V.F.B. FAMILY LIMITED PARTNERSIDP, }

}

Defendants.

}

}

3-03-CV-2229-N

CONSENT DECREE

THIS CONSENT DECREE is made and entered into by and between the Equal Employment

Opportunity Commission ("EEOC"), and the Defendants in the United States District Court for the

Northern District of Texas, Dallas Division, with regard to the EEOC's Complaint filed on

September 29,2003 ("EEOC Complaint"), in Civil Action No. 3-03-CV-2229-N. The Complaint

was based upon Charge of Discrimination Number 310-A2-00719 filed by Allyson Bergstrom

against the Defendants.

The above-referenced Complaint alleges that the Defendants violated Title VII of the Civil

Rights Act of 1964 and Title I ofthe Civil Rights Act of 1991, by subjecting Allyson Bergstrom and

similarly situated female employees to a sexually hostile work environment. The Defendants deny

all of the EEOC's allegations.

The EEOC and the Defendants agree to compromise and settle the differences embodied in

Consent Decree

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the Complaint and intend that the terms and conditions ofthe compromise and settlement be set forth in this Consent Decree ("Consent Decree").
NOW, THEREFORE, in consideration of the mutual promises and agreements set forth herein, the sufficiency ofwhich is hereby acknowledged, the parties agree as follows, the Court finds appropriate and therefore, it is ORDERED, ADJUDGED AND DECREED that:
1. This Consent Decree resolves all issues raised in EEOC Charge No. 31 O-A2-00719. This Decree further resolves all issues in the Complaint filed by the EEOC in this civil action. The EEOC waives further claims and/or litigation on all issues raised in the above-referenced Charge and Complaint. The EEOC does not waive processing or litigating charges other than the abovereferenced Charge.
2. Pursuant to Fed.R.Civ.P. 65(d), this Consent Decree is binding on the Defendants and or any restaurant facility owned or controlled either directly or indirectly by the Defendants Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., whether through ownership ofthe stock ofa restaurant, interest in a partnership, L.L.C., Limited Partnership or other means of ownership, whether held directly, indirectly or in trust by these Defendants.
3. Defendants Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree that during the term ofthis Consent Decree, they will notify the EEOC within 10 days of acquiring any ownership interest in a restaurant facility. Along with the notification required by this paragraph, these Defendants will provide the EEOC with a copy ofthe documents forming the entity and specify the ownership interest, whether held directly, indirectly or in trust by these Defendants and specify the title and job duties of Virgil Block at the entity.
4. The parties agree that this Consent Decree does not constitute an admission by the

Consent Decree

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Defendants of any liability or wrongdoing. The Defendants expressly deny any violation of local, state or federal law, common or statutory, including but not limited to, Title VII of the Civil Rights Act of 1964, as amended or Title I of the Civil Rights Act of 1991.
5. Nothing in this Decree shall be construed to expand, limit or reduce Defendants' obligation to comply with Title VII of the Civil Rights Act of 1964, as amended.
6. Defendants, Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree that if they acquire any ownership interest in a restaurant during the term ofthis Consent Decree, Defendants, Block's Lighthouse Supper Club, Inc, Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree that all duty assignments, disciplinary actions and other terms and conditions ofemployment shall be maintained and conducted in a manner which does not discriminate on the basis of sex in violation of Title VII of the Civil Rights Act of 1964, as amended, and Title I ofthe Civil Rights Act of 1991. These Defendants will maintain a workplace environment free from sexual harassment.
7. Defendants, Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree that ifthey acquire any ownership interest in a restaurant facility during the terms of this Consent Decree, these Defendants agree to post the Notice appended hereto as Attachment "A" in conspicuous places upon the premises of the effected restaurant facility where notices to employees, applicants for employment, members and trainees are customarily posted within ten (10) days after the entry of this Consent Decree. Defendants Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., will report to the EEOC that they have complied with this requirement within (fourteen) 14 days after posting the notice(s). The posting of the notice(s) is to inform applicants and employees about sexual harassment. New

Consent Decree

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• •

employees will be given a copy of the notice, Attachment "A." The notice(s) will remain posted during the two-year term of this Consent Decree.
8. Defendants Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc. agree that ifthey acquire any ownership interest in a restaurant facility during the term ofthis Consent Decree, these Defendants shall implement Equal Employment Opportunity training for all personnel at the effected facility, including management and supervisory personnel, regarding policies and procedures related to sexual harassment in the workplace. In addition, all officers of these Defendants' corporations shall receive such training. The training will advise employees of the requirements and prohibitions of Title VII of the Civil Rights Act of 1964. The training will inform the employees ofthe complaint procedure for individuals who believe they have experienced sexual harassment. The training will advise employees, including supervisors and managers, of the consequences of violating Title VII. The training will also include a specific discussion or instruction relating to the issue of sexual harassment and gender discrimination. The training shall be at least two hours in duration. Within ten (l0) days after the training is conducted, these Defendants agree to give written notice to the EEOC as to the date and location ofthe training, the name of the person providing the training and the substance of the training.
8. Defendants agree that, to the extent they are subject to Title VII, there shall be no discrimination of any kind against any person because of opposition to any practice declared unlawful under Title VII or because of the filing of a charge, giving testimony or assistance or participating in any manner in any investigation, proceeding or hearing under Title VII.
10. Defendants Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc. agree to pay Allyson Bergstrom the amount of$87,500 to resolve all claims

Consent Decree

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for damages arising out ofthe underlying charge of discrimination made the subject of this action. Said payment shall be in one lump sum. Allyson Bergstrom will assume full responsibility to all state and federal taxing authorities for any tax consequences including interest, sanctions or penalties regarding income or other taxes, arising out of the payment, and further agrees to hold the Defendants harmless for any such tax consequences.
Defendants, Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree to pay Stacy Murphy the amount of $5,000 to resolve all claims for damages arising out ofthe underlying charge ofdiscrimination made the subject ofthis action. Said payment shall be in one lump sum. Stacy Murphy will assume full responsibility to all state and federal taxing authorities for any tax consequences including interest, sanctions or penalties regarding income or other taxes, arising out of the payment, and further agrees to hold the Defendants harmless for any such tax consequences.
Defendants, Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree to pay Jodi Brannon the amount of $2,500 to resolve all claims for damages arising out ofthe underlying charge ofdiscrimination made the subject ofthis action. Said payment shall be in one lump sum. Jodi Brannon will assume full responsibility to all state and federal taxing authorities for any tax consequences including interest, sanctions or penalties regarding income or other taxes, arising out of the payment, and further agrees to hold the Defendants harmless for any such tax consequences.
Defendants, Block's Lighthouse Supper Club, Inc., Block's Lighthouse, Inc. and the Lighthouse Club, Inc., agree to pay Emily Owen the amount of $3,000 to resolve all claims for damages arising out ofthe underlying charge of discrimination made the subject ofthis action. Said

Consent Decree

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payment shall be in one lump sum. Emily Owen will assume full responsibility to all state and federal taxing authorities for any tax consequences including interest, sanctions or penalties regarding income or other taxes, arising out of the payment, and further agrees to hold the Defendants harmless for any such tax consequences.
11. The payments referenced in paragraph 10, above, shall be made within twenty (20) days after the date of entry of this Consent Decree by check made payable to Allyson Bergstrom, Jodi Brannon, Stacy Murphy and Emily Owen as agreed by EEOC and the Defendants. The payment to Allyson Bergstrom shall be sent to Jon A. Haslett, Legal Arts Center, 304 S. Record Street, Suite 200, Dallas, Texas 75202. The three additional checks shall be sent by certified mail, return receipt requested, to the EEOC, Attn: Keri L. Mallon, Sr. Trial Attorney, 207 S. Houston, third floor, Dallas, Texas 75202.
12. All reports to the EEOC required by this Decree shall be sent to Keri L. Mallon, Sr. Trial Attorney, EEOC, third floor, 207 S. Houston, Dallas, Texas 75202.
13. IfDefendants fail to tender payment or otherwise fail to timely comply with the terms of paragraphs 11-12, above, Defendants shall:
a. Pay interest at the rate calculated pursuant to 26 U.S.C. Section 6621(b) on any untimely or unpaid amounts; and
b. Bear any additional costs incurred by the EEOC caused by the noncompliance or delay of the Defendants.
14. Neither the EEOC, Allyson Bergstrom, Stacy Murphy, Jodi Brannon, Emily Owen nor Defendants shall contest the validity of this Consent Decree nor the jurisdiction of the federal district court to enforce this Consent Decree and its terms or the right of any party to the Consent Decree to bring an enforcement action upon breach of any term ofthis Consent Decree by any such

Consent Decree

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party. Nothing in this Decree shall be construed to preclude the EEOC from enforcing this Decree

in the event that Defendants fail to perform the promises and representations contained herein. The

EEOC shall determine whether Defendants have complied with the terms ofthis Consent Decree and

shall be authorized to seek compliance with the Consent Decree through civil action in the United

States District Court. The EEOC also reserves the right to seek contempt sanctions for non-payment

and non-compliance with this Court Order.

15. The EEOC shall not bring further suit or intervene in any suit against Defendants

based upon the above-referenced discrimination charge, any ofthe allegations contained therein, the

EEOC's investigation of the charge or the underlying facts.

16. The parties to this Consent Decree agree to bear their own costs and attorney's fees

associated with the above-referenced Complaint.

17. The term of this Decree shall be for two (2) years.

----'/_~ ORDERED, ADJUDGED AND DECREED this

_ _ day of

_--'-""----""'.J'--,---..,..._ _ _, 2004.

Consent Decree

7

• •
AGREED AS TO FORM AND SUBSTANCE:
ATTORNEYS FOR THE PLAINTIFF EQUAL EMPLOYMENT OPPORTUNITY COMMISSION:
~~ ROBER A. CANINO, Regional Attorney Oklahoma State Bar No. 11782
SUZANNE ANDERSON Supervisory Trial Attorney Texas Bar No. 14009470
KERI L. MALLON Sr. Trial Attorney Colorado State Bar No. 27392 Dallas District Office 207 South Houston Street, Third Floor Dallas, Texas 75202 Tel. No. 214-655-3328; Fax No. 214-655-3328
ATTORNEYS FOR ALLYSON BERGSTROM:

MARC H. RICHMAN ~ ~

C Texas Bar No. 16878000

t.u--~.

.\ "ui
"f.l

j-

JON A. HASLETT

b-3o-o. 1

Texas Bar No. 00795141

.,.

Legal Arts Center

304 South Record Street, Suite 200

Dallas, Texas 75202-4712

(214) 742-3133

(214) 939-3759 fax

Consent Decree

8

•
ATTORNEYS FOR DEFENDANTS:

MATTW.HOLLEY

\\

Texas Bar No. 09875540

-)

HELEN THIGPEN Texas Bar No. 0079756 HAYNES AND BOONE, LLP 2502 N. Plano Road, Suite 4000 Richardson, Texas 75082-41-1 (972) 739-6900

•

Consent Decree

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• •
u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Dallas District Office

207 S. Houston Street, 3mFloor

Dallas, TX 75202-4726 (214) 253-2700
TTY (214) 253-2710 FAX (214) 253-2720 EEOC Website. www.eeoc.gov

NOTICE TO ALL EMPLOYEES
This NOTICE is being posted pursuantto a Consent Decree with the U. S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (EEOC). This NOTICE will be conspicuously posted for a period of two (2) years at this facility and in all places where employment notices are posted. It must not be altered, defaced, or covered by any other material.
POLICY: Discrimination ofany kind can and often will detract from employees' job performance, discourage employees from remaining on the job, keep employees from advancing in their careers and lowers overall employee morale and productivity. It is the policy of this restaurant that sexual harassment, sex-based discrimination is unacceptable conduct and will not be condoned.
PURPOSE: It is the purpose of this policy to reaffirm and amplify the position of Title VII of the Civil Rights Act of 1964, as amended, and the Equal Employment Opportunity Commission's guidelines on sexual harassment, sex-based discrimination and retaliation, and to reiterate this restaurant's policy against discrimination and harassment.
SCOPE: This policy extends to all employees of this restaurant including management, nonmanagement, temporary and/or probationary.
DEFINITION: Sexual harassment has been defined as follows: Unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature constitute sexual harassment when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect ofunreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment. Sexual harassment is a form of misconduct that undermines the integrity of the employment relationship. No employee, either male or female, should be subjected to unsolicited and unwelcome sexual conduct, either verbal or physical.

Page 1 of 3

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Examples of behavior that may constitute sexual harassment include but are not limited to the following:

*

Hugging, grabbing or any type of unnecessary touching of another person.

*

Making unwelcome sexual advances.

*

Foul or obscene language of a sexual nature, including jokes.

*

Requests for sexual favors whether in exchange for benefits or otherwise.

RESPONSIBILITY: Each level of management is responsible for ensuring that all personnel policies, procedure, and activities are in full compliance with applicable federal, state, and local equal employment laws, statutes, rules, and regulations regarding sexual discrimination and harassment. Employees are expected to read, understand, and follow the policies that this restaurant has established to prevent discrimination and harassment.

REPORTING PROCEDURES: Any employee who believes that he or she has been subjected to

sexual harassment, sex-based discrimination and/or retaliation is expected to report the alleged act

as soon as possible to that person's immediate supervisor, any supervisor or manager with this

restaurant, or to the Human Resources Department. The Human Resources Department may be

contacted at

or by telephone at _

_ _ _ _ _ _ _ _ _ _ _ _ _ _. Supervisors and mangers who are informed of an alleged

incident of sexual harassment, sex-based discrimination or retaliation must immediately notify the

Human Resources Department.

In addition to reporting a complaint of sexual harassment, sex-based discrimination and/or retaliation to company officials, a person may also contact the U.S. Equal Employment Opportunity Commission, and file a charge of employment discrimination. The address and telephone number of the EEOC office is 207 S. Houston Street, Dallas, Texas 75202; (214) 253-2700. Information about employment rights and the procedures dealing with how to file a charge is available on the Internet at www.eeoc.gov.

INVESTIGATION OF COMPLAINTS: A complete investigation of each complaint will be undertaken immediately by the Human Resources Department. The investigation may include interview of all employees and supervisors at the facility, the inspection of documents, including personnel records, and full inspection of the premises.

PUNISHMENT FOR VIOLATION: Employees engaged in sexual harassment, sex-based discrimination or retaliation can expect serious disciplinary action. After appropriate investigation, any employee, whether management or non-management, who has been found to have engaged in sexual harassment, sex-based discrimination or retaliation against another employee will be subject to appropriate sanctions, depending on the circumstances, from a written warning in his or her personnel file up to and including termination of employment.

RETALIATION: There shall be no retaliation against any employee because that person has

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opposed what they believe to be unlawful employment practices; or has filed a charge of discrimination, or has given testimony, assistance, or has participated in any manner in any investigation, proceeding or hearing under Title VII of the Civil Rights Act of 1964. Whataburger will not punish you for reporting sexual harassment or sex-based discrimination simply because you have made a complaint under the above guidelines.

PROTECTION OF PRIVACY: The question ofwhether a particular action or incident constitutes sexual harassment, sex-based discrimination or retaliation requires a determination based on all available facts. This restaurant will therefore make a concerted effort to protect the privacy of all personnel. Confidential information will be shared on a need-to-know basis to complete the investigation and to deal appropriately with the situation.

EXCEPTIONS: There are no exceptions to this policy.

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE REMOVED OR DEFACED BY

* ' ANYONE. THIS NOTICE WILL BE POSTED FOR A PERIOD OF TWO YEARS.

Signed this _---.I,....:..AA"=-_ day of

Zoo l/ .

"1&~

~ /} It' OJ

~£ IA--e;;;sRobert A. Canino Regional Attorney Equal Employment Opportunity Commission

•

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 District Version 3.0.3 - Docket Report

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CLOSED, JURY, STICKNEY
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:03-cv-02229

Equal Employment Opportunity Commission v. Block's Lighthouse Supper Club, Inc et al Assigned to: Judge David C Godbey Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/29/2003 Date Terminated: 07/13/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Sidney B Chesnin Law Office of Sidney Chesnin 4841 Tremont Street #9 Dallas, TX 75246 972/503-6338 Email: schesnin@hotmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Suzanne M Anderson Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2740 Fax: 214/253-2749 FAX Email: suzanne.anderson@eeoc.gov

V. Defendant Block's Lighthouse Supper Club, Inc
Defendant

represented by Matt W Holley Haynes & Boone - Richardson 2505 N Plano Rd Suite 4000 Richardson, TX 75082-4101 972/739-6900 Fax: 972/680-7551 FAX Email: matt.holley@haynesboone.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Block's Lighthouse, Inc
Defendant Block Family Inc
Defendant The Lighthouse Club, Inc
Defendant V.F.B. Family Limited Partnership

represented by Matt W Holley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Matt W Holley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Matt W Holley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Matt W Holley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/29/2003
09/29/2003 09/29/2003 09/29/2003 09/30/2003 11/14/2003
11/14/2003

#

Docket Text

1 COMPLAINT against Block Family Inc, Block's Lighthouse Supper Club, Inc, Block's Lighthouse, Inc, The Lighthouse Club, Inc, V.F.B. Family Limited Partnership , filed by Equal Employment Opportunity Commission.(aat, ) (Entered: 10/01/2003)
JURY DEMAND by Equal Employment Opportunity Commission. (aat, ) (Entered: 10/01/2003)
2 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Equal Employment Opportunity Commission. (aat, ) (Entered: 10/01/2003)
***Magistrate Judge Stickney chosen by random selection to handle matters that may be referred in this case. (aat, ) (Entered: 10/01/2003)
3 Summons issued as to Block's Lighthouse, Inc. (aat, ) (Entered: 10/01/2003)
4 ANSWER to complaint by Block Family Inc, Block's Lighthouse Supper Club, Inc, Block's Lighthouse, Inc, The Lighthouse Club, Inc, V.F.B. Family Limited Partnership.(aat, ) (Entered: 11/18/2003)
5 DISCLOSURE STATEMENT by Block Family Inc, Block's Lighthouse Supper Club, Inc, Block's Lighthouse, Inc, The Lighthouse Club, Inc, V.F.B. Family Limited Partnership. (aat, ) (Entered: 11/18/2003)

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District Version 3.0.3 - Docket Report

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11/25/2003 12/16/2003 12/16/2003 01/21/2004 07/13/2004

6 ORDER REQUIRING STATUS AND SCHEDULING CONFERENCE. The parties are directed to confer within 14 days of the date of this order and to report to the court within 14 days of the conference. (Signed by Judge David C Godbey on 11/25/03) (aat, ) (Entered: 11/26/2003)
7 NOTICE of attorney appearance and designation of lead counsel by Sidney Chesnin and Toby Costas on behalf of Equal Employment Opportunity Commission (aat, ) (Entered: 12/17/2003)
8 JOINT REPORT by Block Family Inc, Block's Lighthouse Supper Club, Inc, Block's Lighthouse, Inc, Equal Employment Opportunity Commission, The Lighthouse Club, Inc, V.F.B. Family Limited Partnership. (aat, ) (Entered: 12/17/2003)
9 SCHEDULING ORDER: Docket call set for 2/14/2005 before Judge David C Godbey. (Signed by Judge David C Godbey on 1/21/04) (aat, ) (Entered: 01/22/2004)
10 CONSENT DECREE. Defendants agree to pay Allyson Bergstrom $87,500; Stacy Murphy $5,000; Jodi Brannon $2,500; and Emily Owen $3,000. Each party is to bear its own costs and attorneys' fees. (Signed by Judge David C Godbey on 7/13/04) (aat, ) (Entered: 07/14/2004)

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 EEOC LITIGATION SETTLEMENT REPORT - July 2004

http://www.eeoc.gov/litigation/settlements/settlement07-04.html

EEOC v. Block's Lighthouse Supper Club, Inc. No. 3:03-2229-N (N.D. Tex. July 13, 2004)
The Dallas District Office filed this Title VII suit, alleging that a high-end restaurant and its corporate affiliates, through the conduct of the entities' owner, subjected charging party, a cocktail waitress/part-time hostess, and other waitresses to a sexually hostile work environment. Dallas also alleged that defendants terminated CP because of her sex after she repeatedly rebuffed the owner's advances. The owner's harassment was primarily verbal and included calling CP "Tushy" or "Boobsy"; on other occasions, the owner made sexual gestures and grabbed or slapped CP's buttocks. The owner discharged CP when she misplaced a customer's credit card, shouting and cursing at her in front of other people in the restaurant. CP filed a criminal assault complaint and the owner was found guilty following a jury trial and fined $552. The case was resolved through a two-year consent decree that requires defendants to pay CP $87,500 and three other claimants a total of $10,500. Defendants are no longer in business, but the decree contains affirmative relief applicable if they acquire an ownership interest in a restaurant during the term of the decree.

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