United States Equal Employment Opportunity Commission Philadelphia District Office 21 S. Silt Street, Suite 400 Philadelphia, PA 19106 (215) 440-2642
Rachel M. Smith, Trial Attorney RMS-7452

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

EQUAL EMPLOYMENT OPPORTUNITY

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COMMISSION,

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Plaintiff,

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v.

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INTERNATIONAL LONGSHOREMAN'S

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ASSOCIATION, LOCAL 1694

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Defendant.

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Civil Action No.
COMPLAINT AND JURY TRIAL DEMAND

NATURE OF THE ACTION This is an action under the Age Discrimination in Employment Act to correct unlawful employment practices on the basis of age and to provide appropriate relief to Cecil Edwards who was adversely affected by such unlawful practices. As alleged with greater particularity in paragraph 7 below, the Commission alleges that Cecil Edwards, age 58, was treated less favorably in the terms and conditions of his employment as compared to similarly situated younger employees when Defendant Union denied Mr. Edwards an opportunity to participate in a training program for which he was qualified. Instead, Defendant offered the training to two younger, similarly situated employees. As a result of the discriminatory practices, Mr. Edwards suffered backpay losses.

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JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331,1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 7(b) of the Age Discrimination in Employment Act of 1967, as amended, 29 US.C. § 626 (b) (the "ADEA"), which incorporate by reference Sections 16(c) and 17 of the Fair Labor Standards Act of 1938 (the "FLSA"), as amended, 29 U.S.C. §§215 (a)(3), 216(c) and 217. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the District of Delaware.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (The "Commission"), is the agency of the United States of America charged with administration, interpretation and enforcement of the Age Discrimination in Employment Act, and is expressly authorized to bring this action by Section 7(b) of the ADEA, 29 US.c. § 626 (b), as amended by Section 2 of Reorganization Plan No.1 of 1978, 92 Stat. 3781, and by Public Law 98-532 (1984), 98 Stat. 2705. 4. At all relevant times, Defendant, International Longshoreman's Association, Local 1694, (the Union), has continuously been doing business in the State of Delaware and the City of Wilmington and has continuously had at least 15 employees. 5. At all relevant times, Defendant Union has continuously been a labor organization engaged in an industry affecting commerce within the meaning of Section 11 (c) of the ADEA, 29 US.C. § 630 (c).
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STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Cecil Edwards filed a charge with the Commission alleging violations of the Age Discrimination in Employment Act of 1967. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least September of2003, Defendant Union has engaged in unlawful employment practices at its Wilmington, Delaware facility, by unlawfully subjecting Cecil Edwards to disparate treatment based upon his age in violation of Section 7(b) of the Age Discrimination in Employment Act of 1967, as amended, 29 U.S.C. § 626 (b). These unlawful practices include, but are not limited to, the following: (a) Defendant, International Longshoreman's Association, Local 1694 ("Defendant", "Local 1694," or "union") is a labor union and a member of the AFL-CIO (American Federation of Labor). Local 1694 represents the interests of its members, including referring employee members to employers for jobs. Mr. Edwards joined Local 1694 in 1976 as a laborer and longshoreman, and has been a member in good standing at all relevant times. (b) As a longshoreman, Mr. Edwards's duties are to lift and unload the contents of ships when they are docked at the Port of Wilmington. Mr. Edwards hasbeen performing these duties for Wilmington Stevedore (now Murphy Marine Service or "MMS") on an "asneeded" basis since he joined Local 1694. (c) Workers use two types of cranes to perform these duties: a ship-based crane, which was operated from the ship itself, and a shore-based crane, which was operated directly from the port. Mr. Edwards was trained only on the ship-based crane.
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(d) In the mid-1980's, Respondent instituted a mandate that union members receive

training and certification in order to operate a shore based crane. Defendant Union was

responsible for recommending employees for this training which would increase the employee's

job availabilities and earning potential.

(e) Since the requirement came into effect, Mr. Edwards repeatedly expressed interest

in obtaining the necessary training from both Defendant and MMS officials.

(f) Each time training opportunities occurred, Defendant Union denied him the

opportunity.

(g)

On vanous occaSIOns, Mr. Edwards personally informed Mark Wilson,

Defendant's Business Agent, Wilson Downes, President of Local 1694, and current Vice

President, Todd Butler, that he wanted to train on the shore-based cranes. He was never given a

response.

(h) In 2003, when Mr. Edwards was approximately 57 years old, he advised an MMS

superintendent that he should be able to train "on the job" because Defendant Union had not

selected him for the training. The superintendent responded that the union was aware of his

request to receive the training, but that it was not "ready" to recommend him.

(i) In September of 2003, another training opportunity became available. Mr.

Edwards again went to Mark Wilson, Defendant's Business Agent, to express his interest in the

training. At that time, Wilson was responsible for recommending union members for the training.

Wilson's response to Mr. Edwards was that he and the employer, MMS, were "looking for

younger men to train to replace those workers nearing retirement."

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(j) Stunned by Wilson's response, Mr. Edwards filed a grievance against the union. At the grievance hearing, which was recorded on audiotape, Wilson restated his position that he was seeking younger men for the certification training.
(k) Wilson selected Antonio Bailey and Allen Woody for the September 2003 training, who were ages 45 and 46 respectively, and significantly younger than Mr. Edwards.
(1) Presently, Defendant's executive board is responsible for selecting union members for training. Despite Defendant's assurances to the contrary, to date, Mr. Edwards has not been selected for training.
8. The effect of the practices complained of in paragraphs 7(a) through (1) above has b,een to deprive Cecil Edwards of equal employment opportunities and otherwise adversely affect his status as an employee because of his age.
9. The unlawful employment practices complained of in paragraphs 7(a) through (1) above were intentional.
10. The unlawful employment practices complained of in paragraphs 7(a) through (1) were done with malice or with reckless indifference to the federally protected rights of Cecil Edwards.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Union, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in discrimination, harassment, and retaliation and any other employment practice which discriminates on the basis of age against individuals 40 years of age and older. ,
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B. Order Defendant Union to institute and carry out policies, practices and programs

which provide equal employment opportunities for individuals 40 years of age and older, and

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

C. Order Defendant Union to make whole Cecil Edwards by providing appropriate

back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative

relief necessary to eradicate the effects of its unlawful employment practices, including but not

limited to, rightful-placement into the next available training program, or front pay, in lieu

thereof, if placement is not feasible.

D. Order Defendant Union to make whole Cecil Edwards by providing compensation

for past and pecuniary losses resulting from the unlawful employment practices described in

paragraphs 7(a) through (I) above, including medical expenses and out of pocket costs, in

amounts to be determined at trial.

E.

Grant such further relief as the Court deems necessary and proper in the public

interest.

F. Award the Commission its costs of this action.

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JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted,
ERIC S. DRIEBAND General Counsel
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS
Associate General Counsel

~fJffNA; Q INE H. MCNAIR Regional Attorney

~a O/~~

D!THA.O'BOYLE·

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Supervisory Trial Attorney
~Jxdu

RACHEL • SMITH
Trial Attorney

EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION Philadelphia District Office 21 South 5th Street, Suite 400
Philadelphia, PA 19106 (215) 440-2642; (215) 440-2828 (FAX)

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UNITED STATES ATTORNEY DISTRICT OF DELAWARE COLM F. CONNOLLY
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 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
INTERNATIONAL LONGSHOREMAN'S ASSOCIATION, LOCAL 1694
Defendant.

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CIVIL ACTION NO. 05-00628

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CONSENT DECREE A. This action was instituted by the U.S. Equal Employment Opportunity Commission ("the EEOC" or "the Commission") on August 29, 2005, against International Longshoreman's Association, Local 1694 ("I LA, Local 1694") to enforce provisions of the Age Discrimination in Employment Act of 1967, as amended, 29 U.S.c. § 626 (b) (the "ADEA"). The EEOC filed this ADEA lawsuit on behalf of Cecil Edwards, alleging that ILA, Local 1694 discriminated against him on the basis of his age when it denied him the opportunity to participate in a training program for which he was qualified. B. This Consent Decree is entered into by and shall be final and binding between the EEOC and Defendant, ILA, Local 1694, its directors, officers, agents, employees, successors or assigns (hereinafter collectively referred to as "Defendant" or "ILA, Local 1694"). C. The EEOC and ILA, Local 1694 agree to the entry of this Consent Decree, which shall fully and finally resolve all claims the EEOC raiscd in its Complaint in Civil Action No. 05-00628. This Consent Decree shall not constitute either an adjudication of or finding on the merits of the complaint.

NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: NON-DISCRIMINATION AND NON-RETALIATION
I. This Court has jurisdiction over the parties and subject matter of this action. 2. ILA, Local 1694 agrees to comply fully with all the provisions of the ADEA and will avoid engaging in any employment practices which operates to discriminate against employees or deny equal opportunities to any employee or applicant for employment in violation of the ADEA. 3. ILA, Local 1694 agrees that it shall not engage in any employment practices which retaliate in any manner against any person because of that person's opposition to any practice made an unlawful employment practice under the ADEA or because that person has made a charge, testified, assisted or participated in any manner in an investigation, proceeding or hearing under the ADEA. 4. ILA, Local 1694 shall not divulge to any identifiable employer or potential employer of Cecil Edwards any of the facts or circumstances related to the claims of age discrimination against ILA, Local 1694 in this case or any of the events relating to his participation in the litigation of this action. 5. Nothing in this Consent Decree, either by inclusion or exclusion, shall be construed to limit the obligations of ILA, Local 1694 under the ADEA or the EEOC's authority to process or litigate any charge of discrimination now pending or filed in the future against ILA, Local 1694.
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MONETARY RELIEF 6. Defendant agrees to pay monetary relief in the total amount of $10,000.00 to Cecil Edwards, in full settlement of the claims against Defendant which were raised in the Commission's Complaint within 30 days of receiving the Release. The check shall be mailed to Cecil Edwards, at 38 March Drive, Ronoake Rapids, NC 27870 by certified mail, return receipt requested. Defendant will mail a photocopy of the check to the EEOC, to the attention of Rachel M. Smith, Trial Attorney, EEOC, The Bourse, 21 South Fifth Street, Suite 400, Philadelphia, PA 19106-2515, within five days of the date of mailing of the check to Me. Edwards.
POSTING OF NOTICE 7. Within 45 days after entry of this Decree, ILA, Local 1694 shull post at all its facility in Wilmington, Delaware, on all bulletin boards, used by ILA, Local 1694 for communicating with employees, same-sized copies of the Notice attached as Exhibit 1 to this Decree. The Notice shall remain posted for two (2) years from the date of entry of this Decree. ILA, Local 1694 shall provide to the attention of Rachel M. Smith, Trial Attorney, EEOC, 21 South Fifth Street Suite 400, Philadelphia, PA 19106-2515, a list ofthe locations and dates of posting in each location within 40 days after entry of this Decree. Ifposted copies become defaced, removed, marred or otherwise illegible, ILA, Local 1694 agrees to post a readable copy in the same manner as heretofore specified.
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NON-DISCRIMINATJON POUCIES AND COMPLAINT PROCEDURES
8. ILA, Local 1694's policy or policies against age discrimination and complaint procedures shall be drafted in plain and simple language. ILA, Local) 694 shaH ensure that its policy or policies against age discrimination and related complaint procedures meet the following minimum criteria:
(a) provide that the complaints of age discrimination, harassment and/or retaliation can be made either in writing or verbally; (ii) identify officers to whom an employee can make a complaint; and (iii) provide assurances that complainants shall not be subjected to retaliation; (c) provide for prompt investigation of complaints of discrimination; (d) provide for prompt communication to the complaining party of the results of the investigation and any remedial actions taken or proposed; and (e) ILA, Local 1694 will revise its existing age discrimination policies to advise employees of their right to file a charge with the EEOC and to provide the address and phone number of the EEOC. 9. ILA, Local 1694 shall distribute its non-discrimination policy to all ofits members in Wilmington, Delaware. 10. Within 120 days after entry of this Consent Decree, ILA, Local 1694 shall advise Rachel M. Smith, Trial Attorney, EEOC's Philadelphia District Office, that its policy or policies against age discrimination have been distributed to all current members at its facilities in Delaware and that new members in Delaware will receive these policies.
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TR41Nc~G
II. ILA, Local 1694 shall provide training on the requirements of the ADEA as follows:
(a) ILA, Local 1694 agrees to provide annual training sessions once annually in calendar years 2006, and 2007. This training will be for the Executive Board in ILA, Local 1694's Wilmington, Delaware location which will emphasize what constitutes age discrimination, how to keep Local 1694 free from such discrimination and will summarize how to conduct a prompt and effective investigation into allegations, complaints or charges of discrimination. The training sessions will be conducted by a representative designated by ILA, Local 1694 and approved by the EEOC. (b) ILA, Local 1694 shall first provide training in accordance with Paragraph l3(a) by no later than 120 calendar days after entry of this Consent Decree.
DISPUTE RESOLUTION 12. In the event either party to this Decree believes 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 non-compliance or 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.
MISCELLANEOUS PROVISIONS 13. Each party to this Decree shall bear its own expenses, costs and attorneys' fees.
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14. The tenns of this Decree are and shall be binding upon the present and future
representatives, agents, directors, officers, successors and assigns ofILA, Local 1694 in their
capacities as representatives, agents, directors and officers of ILA, Local 1694 and not in their
individual capacities. This paragraph shall not be construed as placing any limit on remedies
available to the Court in the event any individual is found in contempt for a violation of this
Decree.
IS. This Consent Decree shall fully and finally resolve all claims which were raised
by the EEOC in its Complaint in Civil Action No. 05-00628.
16. This Consent Decree shall be filed in the L:nited States District Court for the
District of Delaware and shall continue in effect for two (2) years. The Court shall retain
jurisdiction over this case in order to enforce the tenns of the Decree
19. The Clerk of the District Court is hereby directed to send a file-stamped copy of
this Consent Decree to counsel of record.
Ronald S. Cooper General Counsel
JamesL. Lee Deputy General Counsel
Gwendolyn Young Reams Associate General Counsel U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 L Street, NW Washington DC 20507

Is! Susan A. Murrav. Esq. Susan A. Murray, Esq. Freedman & Lorry, P.c. 160 I Market Street, 2nd Floor Philadelphia, PA 19103 Attorney for the Defendant
lsi Susan E. Kau(man. Esq. Susan E. Kau finan, Esq. Heiman Gouge & Kaufman, LLP 800 King Street Wilmington, DE 19801

lsi Jacqueline H. McNair Jacqueline H. McNair Regional Attorney
Is! Judith A. a 'Boyle
Judith A. O'Boyle Supervisory Trial Attorney
Is! Rachel M Smith Rachel M. Smith Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Philadelphia District Office 21 S. 5th Street, Suite 400 Philadelphia, PA 19106 (215) 440-2642

Cf-m By the Court: ;,J....... HON. SUE L. ROB SON, CHIEF JUDGE UNITED STATES DISTRICT COURT

Date: Ii Iis/ot, l

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EXHIBIT I
NOTICE TO ALL INTERl'ATIOl'AL LONGSHOREMAN'S ASSOCIATION. LOCAL 1694 MEMBERS AND OFFICERS
This Notice is posted pursuant to a Consent Decree entered by the federal court for the District of Delaware in EEOC v. ILA. Local 1694, Civil Action Number 05.00628, resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC) against International Longshoreman's Association. Local 1694, ("ILA, Local 1694.")
The Age Discrimination in Employment Act of 1967 (ADEA) protects individuals who are 40 years of age or older from employment discrimination based on age. The ADEA's protections apply to both employees and job applicants. Under the ADEA, it is unlawful to discriminate against a person because of his/her age with respeet to any term, condition, or privilege of employment, including hiring, firing, promotion, layoff, compensation, benefits, job assignments, and training. It is also unlawful to retaliate against an individual for opposing employment practices that discriminate based on age or for filing an age discrimination charge, testifying, or participating in any way in an investigation, proceeding, or litigatIOn under the ADEA.
In its lawsuit, the EEOC alleged that ILA, Local 1694 discriminated against an employee on the basis of age when it denied him the opportunity to participate in a training program in violation of the Age Discrimination Act of 1967 ("ADEN').
To resolve the case, ILA, Local 1694 and the EEOC have entered into a Consent Decree which provided, among other things, that: (I) ILA, Local 1694 shall not discriminate on the basis of age in the future; (2) ILA, Local 1694 shall not retaliate against any person because he or she opposed any practice made unlawful by the ADEA, filed an ADEA charge of discrimination, participated in any ADEA proceeding, or asserted any rights under the Consent Decree; and (3) ILA, Local 1694 will provide training regarding its policy prohibiting age discrimination to the Executive Board in its Wilmington, Delaware facility,
If you believe you have been discriminated against, you may 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 two (2) years 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 tenns may be directed to the: Regional Attorney, EEOC Philadelphia Distnct Office, 21 South 5th Street, Philadelphia, PA 19106.

U.S. Equal Employment Opponunity CommIssion
DATED:

ILA, LOCAL 1694 DATED: _____________________

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U.S. District Court District of Delaware (Wilmington) CIVIL DOCKET FOR CASE #: 1:05-cv-00628-SLR

CLOSED

Equal Employment Opportunity Commission v. International Longshoreman's Association Local 1694 Assigned to: Honorable Sue L. Robinson Cause: 29:626 Job Discrimination (Age)

Date Filed: 08/29/2005 Date Terminated: 09/19/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Douglas Edward McCann U.S. Attorney's Office The Nemours Building 1007 Orange Street, Suite 700 P.O. Box 2046 Wilmington, DE 19899-2046 (302) 573-6277 Fax: (302) 573-6220 Email: douglas.mccann@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Judith A. O'Boyle U.S. Equal Employment Opportunity Commission 21 South 5th Street Suite 400 Philadelphia, PA 19106 (215) 440-2669 Fax: (215) 440-2674 Email: judith.oboyle@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Rachel M. Smith U.S. Equal Employment Opportunity Commission 21 South 5th Street Suite 400 Philadelphia, PA 19106 (215) 440-2642 Fax: (215) 440-2848 Email: rachel.smith@eeoc.gov ATTORNEY TO BE NOTICED

Rudolph Contreras

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V.
Defendant International Longshoreman's Association Local 1694

U.S. Attorney's Office The Nemours Building 1007 Orange Street, Suite 700 P.O. Box 2046 Wilmington, DE 19899-2046 (302) 573-6277 ext. 154 Fax: (302) 573-6220 Email: rudolph.contreras@usdoj.gov TERMINATED: 04/26/2006 ATTORNEY TO BE NOTICED
represented by Susan E. Kaufman Heiman, Gouge & Kaufman, LLP 800 King Street, Suite 303 P.O. Box 1674 Wilmington, DE 19899 (302) 658-1800 Email: skaufman@hgkde.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
William H. Haller Pro Hac Vice Email: whaller@freedmanlorry.com ATTORNEY TO BE NOTICED

Date Filed 08/29/2005
08/29/2005 09/07/2005 09/26/2005 10/04/2005

#

Docket Text

1 COMPLAINT filed with Jury Demand against International Longshoreman's Association Local 1694 - Magistrate Consent Notice to Pltf. - filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet # 2 Acknowledgement of Consent Form)(dab, ) (Entered: 08/29/2005)
Summons Issued as to International Longshoreman's Association Local 1694 on 8/29/2005. (dab, ) (Entered: 08/29/2005)
Case assigned to Judge Sue L. Robinson. Please include the initials of the Judge (SLR) after the case number on all documents filed. (rjb, ) (Entered: 09/07/2005)
2 Return of Service Executed by Equal Employment Opportunity Commission. International Longshoreman's Association Local 1694 served on 9/14/2005, answer due 10/4/2005. (fmt, ) (Entered: 09/26/2005)
3 Letter to Clerk from William H. Haller, Esq. enclosing computer diskette containing the Union's answer to the complaint; appearing in this matter on behalf of the Union and filing initial pleading as permitted by D.Del. L.R.

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10/04/2005 10/10/2005 10/17/2005 10/17/2005 10/18/2005
10/20/2005 10/25/2005
10/25/2005 10/26/2005 11/15/2005 11/15/2005 11/28/2005 11/29/2005

83.5(e); will be associating with a DE atty and seeking admission pro hac vice within the next 30 days. (fmt, ) (Entered: 10/04/2005)
4 ANSWER to Complaint by International Longshoreman's Association Local 1694.(fmt, ) (Entered: 10/04/2005)
5 NOTICE of Appearance by Susan E. Kaufman on behalf of International Longshoreman's Association Local 1694 (Kaufman, Susan) (Entered: 10/10/2005)
6 MOTION for Pro Hac Vice Appearance of Attorney Judith A. O'Boyle & Rachel M. Smith - filed by Equal Employment Opportunity Commission. (Contreras, Rudolph) (Entered: 10/17/2005)
7 MOTION for Pro Hac Vice Appearance of Attorney William H. Haller - filed by International Longshoreman's Association Local 1694. (Kaufman, Susan) (Entered: 10/17/2005)
SO ORDERED, re 7 MOTION for Pro Hac Vice Appearance of Attorney William H. Haller filed by International Longshoreman's Association Local 1694,, 6 MOTION for Pro Hac Vice Appearance of Attorney Judith A. O'Boyle & Rachel M. Smith filed by Equal Employment Opportunity Commission, . Signed by Judge Sue L. Robinson on 10/18/05. (rld, ) (Entered: 10/18/2005)
8 MOTION to Allow EEOC Attorneys to Appear Without Local Counsel - filed by Equal Employment Opportunity Commission. (Contreras, Rudolph) (Entered: 10/20/2005)
9 ORDER granting 8 Motion to appear without local cnsl.; Clerk of Court to provide EEOC attys. Judith A. O'Boyle and Rachel M. Smith with electronic log-in and password for filing pleadings IN THIS CASE ONLY. Signed by Judge Sue L. Robinson on 10/25/05. (rld, ) (Entered: 10/25/2005)
10 ORDER Setting Hearings Scheduling TeleConference set for 11/29/2005 08:30 AM before Honorable Sue L. Robinson. Signed by Judge Sue L. Robinson on 10/25/05. (rld, ) (Entered: 10/25/2005)
Remark: Attorneys Judith A. O'Boyle and Rachel M. Smith for Equal Employment Opportunity Commission, added per order of the Court dated 10/25/05. (rbe, ) (Entered: 10/26/2005)
11 NOTICE of Service of Initial Disclosures. Notice filed by Rachel M. Smith on behalf of Equal Employment Opportunity Commission (Smith, Rachel) Modified on 11/15/2005 (fmt, ). (Entered: 11/15/2005)
CORRECTING ENTRY: The text of D.I. 11 has been changed to reflect that it is a Notice of Service not a Notice of Filing of Paper Documents with the Clerk's Office (fmt, ) (Entered: 11/15/2005)
12 Proposed Discovery Plan by Equal Employment Opportunity Commission.(Smith, Rachel) (Entered: 11/28/2005)
Minute Entry for proceedings held before Judge Sue L. Robinson : Scheduling TeleConference held on 11/29/2005. (Court Reporter n/a.) (rld, ) (Entered: 11/29/2005)

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11/29/2005
11/29/2005 11/29/2005 01/03/2006 01/10/2006 01/11/2006 01/23/2006 02/06/2006 02/17/2006
03/03/2006 03/03/2006 03/08/2006 03/08/2006 03/10/2006

13 SCHEDULING ORDER: Case referred to the Magistrate Judge for the purpose of exploring ADR. Joinder of Parties due by 2/1/2006. Amended Pleadings due by 2/1/2006. Discovery due by 5/15/2006. Status TeleConference set for 3/29/2006 04:30 PM before Honorable Sue L. Robinson. Counsel for deft. to initiate this call. Signed by Judge Sue L. Robinson on 11/29/05. (rld, ) (Entered: 11/29/2005)
CASE REFERRED to Mediation. (cab, ) (Entered: 11/29/2005)
14 Order Setting Teleconference: Telephone Conference set for 1/23/2006 09:00 AM before Honorable Mary Pat Thynge to discuss ADR. Signed by Judge Mary Pat Thynge on 11/29/2005. (cab, ) (Entered: 11/29/2005)
15 NOTICE OF SERVICE of Request for Production of Documents Directed to the Plaintiff by International Longshoreman's Association Local 1694.(Kaufman, Susan) (Entered: 01/03/2006)
16 NOTICE OF SERVICE of First Set of Interrogatories and First Requests for Production of Documents by Equal Employment Opportunity Commission.(Smith, Rachel) (Entered: 01/10/2006)
17 NOTICE to Take Deposition of Cecil Edwards on February 2, 2006 @ 10:00 a.m. by International Longshoreman's Association Local 1694.(Kaufman, Susan) (Entered: 01/11/2006)
18 ORDER Setting Mediation Conferences: Mediation Conference set for 8/30/2006 10:00 AM in Courtroom 6C before Honorable Mary Pat Thynge. Signed by Judge Mary Pat Thynge on 1/23/2006. (cab, ) (Entered: 01/23/2006)
19 NOTICE OF SERVICE of Notices of Deposition by Equal Employment Opportunity Commission.(Smith, Rachel) (Entered: 02/06/2006)
20 NOTICE OF SERVICE of Second Notice of Deposition re 19 Notice of Service by Equal Employment Opportunity Commission. Related document: 19 Notice of Service filed by Equal Employment Opportunity Commission,.(Smith, Rachel) (Entered: 02/17/2006)
21 MOTION to Compel Discovery Responses - filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Interrogatories# 2 Exhibit Requests for Production of Documents)(Smith, Rachel) (Entered: 03/03/2006)
22 NOTICE OF SERVICE of Motion to Compel Discovery Responses by Equal Employment Opportunity Commission.(Smith, Rachel) (Entered: 03/03/2006)
23 NOTICE of Withdrawal by Equal Employment Opportunity Commission re 21 MOTION to Compel Discovery Responses (Smith, Rachel) (Entered: 03/08/2006)
24 Joint MOTION for Extension of Time to Complete Discovery - filed by Equal Employment Opportunity Commission. (Smith, Rachel) (Entered: 03/08/2006)
SO ORDERED, re 24 Joint MOTION for Extension of Time to Complete Discovery to 3/29/06, filed by Equal Employment Opportunity Commission, . Signed by Judge Sue L. Robinson on 3/10/06. (rld, ) (Entered: 03/10/2006)

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03/27/2006 03/28/2006 03/29/2006 03/30/2006
04/12/2006 04/26/2006 07/05/2006 07/12/2006 08/01/2006 09/14/2006 09/19/2006

25 Second STIPULATION TO EXTEND TIME Extend Discovery Cut-Off to April 12, 2006 - filed by Equal Employment Opportunity Commission. (Smith, Rachel) (Entered: 03/27/2006)
SO ORDERED, re 25 Second STIPULATION TO EXTEND TIME Extend Discovery Cut-Off to April 12, 2006 filed by Equal Employment Opportunity Commission, . Signed by Judge Sue L. Robinson on 3/28/06. (rld, ) (Entered: 03/28/2006)
Minute Entry for proceedings held before Judge Sue L. Robinson : Telephone Conference held on 3/29/2006. (Court Reporter V. Gunning.) (rld, ) (Entered: 03/30/2006)
26 SCHEDULING ORDER: parties shall inform the court on or before 9/19/06 if they intend to proceed with a jury or bench trial in this case. Pretrial Conference set for 10/5/2006 04:30 PM in Courtroom 6B before Honorable Sue L. Robinson. Trial set for 10/19/2006 09:30 AM in Courtroom 6B before Honorable Sue L. Robinson. Signed by Judge Sue L. Robinson on 3/30/06. (rld, ) (Entered: 03/30/2006)
27 Joint STIPULATION As to Defendant's Liability by Equal Employment Opportunity Commission. (Smith, Rachel) (Entered: 04/12/2006)
28 NOTICE OF SUBSTITUTION OF COUNSEL re Equal Employment Opportunity Commission: Entry of appearance of attorney Douglas Edward McCann. Attorney Rudolph Contreras terminated. (McCann, Douglas) (Entered: 04/26/2006)
29 MOTION for Pro Hac Vice Appearance of Attorney Susan A. Murray, Esquire filed by International Longshoreman's Association Local 1694. (Kaufman, Susan) (Entered: 07/05/2006)
SO ORDERED, re 29 MOTION for Pro Hac Vice Appearance of Attorney Susan A. Murray, Esquire filed by International Longshoreman's Association Local 1694, . Signed by Judge Sue L. Robinson on 7/11/06. (rld, ) (Entered: 07/12/2006)
30 ORDER Mediation tentatively scheduled for August 30, 2006 at 10:00 AM is canceled. Signed by Judge Mary Pat Thynge on 8/1/2006. (cab, ) (Entered: 08/01/2006)
31 PROPOSED CONSENT JUDGMENT Proposed Consent Decree by Equal Employment Opportunity Commission. (Smith, Rachel) (Entered: 09/14/2006)
32 CONSENT JUDGMENT in favor of pltf. EEOC and against deft. ILA, Local 1694 in the amount of $10,000.00. Signed by Judge Sue L. Robinson on 9/18/06. (rld, ) (Entered: 09/19/2006)

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1:05-cv-00628-SLR Start date: 1/1/1970 End date: 5/16/2007
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