1 MARY JO O'NEILL AZ Bar No. 005924

SALLY C. SHANLEY AZ Bar No. 012251

2 P. DAVID LOPEZ DC Bar No. 426463

EQUAL EMPLOYMENT OPPORTUNITY

3 COMMISSION

Phoenix District Office

4 3300 North Central Avenue, Suite 690

Phoenix, Arizona 85012

5 Telephone: (602) 640-5016

e-mail: mary.oneill@eeoc.gov

6

sally.shanley@eeoc.gov

patrick.lopez@eeoc.gov

7 Attorneys for Plaintiff

8 IN THE UNITED STATES DISTRICT COURT
9 FOR THE DISTRICT OF ARIZONA
10

11 Equal Employment Opportunity

)

12 Commission,

) )

13

Plaintiff,

) )

14

vs.

) )

15

Target Stores, Inc. d/b/a Target Financial )

Services,

)

16

)

Defendant.

)

17

CIV COMPLAINT JURY TRIAL DEMANDED

18

NATURE OF THE ACTION

19

This is an action under Title VII of the Civil Rights Act of 1964 to correct

20 unlawful employment practices on the basis of race and to make whole Bridget Shores.

21 Plaintiff Equal Employment Opportunity Commission (“EEOC” or the “Commission”)

22 alleges that Defendant, Target Stores, Inc., d/b/a Target Financial Services (“Target

23 Financial”), failed and refused to promote Bridget Shores because of her race, African-

24 American. Ms. Shores was also constructively discharged because of Target Financial's

25 discriminatory employment practices. In addition, Defendant failed to retain materials

26 relevant to the employment actions at issue in this case, as required by federal law.

27

28

1

JURISDICTION AND VENUE

2

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

3 1337, 1343 and 1345. This action is authorized and instituted pursuant to Sections

4 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.

5 §2000e, et seq. ("Title VII").

6

2. The employment practices alleged below to be unlawful were and are now

7 being committed within the jurisdiction of the United States District Court for the District

8 of Arizona.

9

PARTIES

10

3. The EEOC is the agency of the United States of America charged with the

11 administration, interpretation, and enforcement of Title VII, and is expressly authorized to

12 bring this action by Section 706(f)(1) and (3)of Title VII, 42 U.S.C. §2000e-5(f)(1) and

13 (3).

14

4. At all relevant times to this action, Target Financial has continuously been a

15 Minnesota corporation doing business in the State of Arizona, and has continuously had

16 at least twenty employees.

17

5. At all relevant times to this action, Target Financial has continuously been

18 an employer engaged in an industry affecting commerce within the meaning of Sections

19 701(b), (g), and (h) of Title VII, 42 U.S.C. §§2000e(b), (g) and (h).

20

6. Prior to institution of this lawsuit, representatives of the Commission

21 attempted to eliminate the unlawful employment practices alleged below, and to effect

22 voluntary compliance with Title VII through informal methods of conciliation, conference

23 and persuasion within the meaning of Section 706(b) of Title VII, 42 U.S.C. §2000e-5(b).

24

25

STATEMENT OF CLAIMS

26

7. More than thirty days prior to the institution of this lawsuit, Bridget Shores

27 filed a charge with the Commission alleging violations of Title VII by Target Financial.

28 All conditions precedent to the institution of this lawsuit have been fulfilled.

2

1

8. Since at least October 2000, Target Financial has engaged in unlawful

2 employment practices at its Tempe, Arizona facility in violation of Title VII. These

3 unlawful employment practices include failing and refusing to promote Bridget Shores to

4 the position of Collections Credit Specialist, Collections Crediting Coordinator, VISA

5 Chargeback, and Guest Service Team Lead because of her race, African-American, in

6 violation of Section 703(a) of Title VII.

7

9. The effect of the practices complained of in Paragraph Eight (¶ 8) has been

8 to deprive Bridget Shores of equal employment opportunities and to otherwise adversely

9 affect her status as an employee because of her race, African-American.

10

10. The unlawful employment practices complained of in Paragraph Eight (¶8) ,

11 above were and are intentional.

12

11. The unlawful employment practices complained of in Paragraph Eight (¶ 8),

13 above were and are done with malice or with reckless indifference to the federally

14 protected rights of Bridget Shores.

15

12. Since at least October 2000, Defendant has failed, in violation

16 of Section 709(c) of Title VII, 42 U.S.C. §2000e-8(c) and 29 C.F.R. §1602.14 (2001), to

17 make and preserve records relevant to the determination of whether unlawful employment

18 practices have been or are being committed, including interview notes for the VISA

19 Chargeback Specialist position.

20

PRAYER FOR RELIEF

21

WHEREFORE, the Commission respectfully requests that this Court:

22

A. Grant a permanent injunction enjoining Defendant Target Financial, its

23 officers, successors, assigns and all persons in active concert or participation with it, from

24 engaging in any employment practice which discriminates on the basis of race;

25

B. Order defendant Target Financial to institute and carry out policies,

26 practices and programs which provide equal employment opportunities for African-

27 American individuals, and which eradicate the effects of its past and present unlawful

28 employment practices;

3

1

C. Grant a judgment requiring Defendant Target Financial to pay appropriate

2 back wages in an amount to be determined at trial, and an equal sum as liquidated

3 damages, and prejudgment interest to Bridget Shores, whose wages are being unlawfully

4 withheld as a result of the acts complained of above;

5

D. Order defendant Target Financial to make whole Bridget Shores, whose

6 wages are being unlawfully withheld as a result of the acts complained of above, by

7 restraining the continued withholding of amounts owing as back wages with prejudgment

8 interest, in amounts to be determined at trial;

9

E. Order defendant Target Financial to make whole all individuals adversely

10 affected by the unlawful practices described above, by providing the affirmative relief

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

12 limited to, rightful place promotion and reinstatement of Bridget Shores;

13

F. Order defendant Target Financial to make whole Bridget Shores by

14 providing compensation for past and future pecuniary losses resulting from the unlawful

15 employment practices described above, in amounts to be determined at trial;

16

G. Order defendant Target Financial to make whole Bridget Shores by

17 providing compensation for past and future non-pecuniary losses resulting from the

18 unlawful practices complained of above, including emotional pain, suffering,

19 inconvenience, loss of enjoyment of life and humiliation;

20

H. Order defendant Target Financial to pay Bridget Shores punitive damages

21 for its malicious and reckless conduct described above, in amounts to be determined at

22 trial;

23

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

24 public interest; and

25

J. Award the Commission its costs in this action.

26

JURY TRIAL DEMAND

27

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

28 Complaint.

4

1

DATED this 29th day of September, 2006.

2

Respectfully submitted,

3

RONALD S. COOPER

General Counsel

4

GWENDOLYN YOUNG REAMS

5

Associate General Counsel

6

EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

7

1801 L Street, N.W.

8

Washington, D.C. 20507

9

s/ Mary Jo O’Neill

MARY JO O’NEILL

10

Regional Attorney

11

s/ Sally C. Shanley

SALLY C. SHANLEY

12

Supervisory Trial Attorney

13

s/ P. David Lopez

P. DAVID LOPEZ

14

Trial Attorney

15

EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

16

3300 North Central Ave., Suite 690

Phoenix, Arizona 85012-2504

17

Attorneys for Plaintiff

18

19

20

21

22

23

24

25

26

27

28

5

 
 1 MARY JO O'NEILL AZ Bar No. 005924

SALLY C. SHANLEY AZ Bar No. 012251

2 P. DAVID LOPEZ DC Bar No. 426463

EQUAL EMPLOYMENT OPPORTUNITY

3 COMMISSION

Phoenix District Office

4 3300 North Central Avenue, Suite 690

Phoenix, Arizona 85012

5 Telephone: (602) 640-5016

e-mail: mary.oneill@eeoc.gov

6

sally.shanley@eeoc.gov

patrick.lopez@eeoc.gov

7 Attorneys for Plaintiff

8 IN THE UNITED STATES DISTRICT COURT
9 FOR THE DISTRICT OF ARIZONA
10

11 Equal Employment Opportunity

)

12 Commission,

) )

13

Plaintiff,

) )

14

vs.

) )

15

Target Stores, Inc. d/b/a Target Financial )

Services,

)

16

)

Defendant.

)

17

CIV 06-2331 PHX FJM FIRST AMENDED COMPLAINT JURY TRIAL DEMANDED

18

NATURE OF THE ACTION

19

This is an action under Title VII of the Civil Rights Act of 1964 to correct

20 unlawful employment practices on the basis of race and to make whole Bridget Shores.

21 Plaintiff Equal Employment Opportunity Commission (“EEOC” or the “Commission”)

22 alleges that Defendant, Target Stores, Inc., d/b/a Target Financial Services (“Target

23 Financial”), failed and refused to promote Bridget Shores because of her race, African-

24 American. In addition, Defendant failed to retain materials relevant to the employment

25 actions at issue in this case, as required by federal law.

26

JURISDICTION AND VENUE

27

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

28 1337, 1343 and 1345. This action is authorized and instituted pursuant to Sections

706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.

§2000e, et seq. ("Title VII").

Case 2:06-cv-02331-FJM Document 4 Filed 10/04/2006 Page 1 of 5

1

2. The employment practices alleged below to be unlawful were and are now

2 being committed within the jurisdiction of the United States District Court for the District

3 of Arizona.

4

PARTIES

5

3. The EEOC is the agency of the United States of America charged with the

6 administration, interpretation, and enforcement of Title VII, and is expressly authorized to

7 bring this action by Section 706(f)(1) and (3)of Title VII, 42 U.S.C. §2000e-5(f)(1) and

8 (3).

9

4. At all relevant times to this action, Target Financial has continuously been a

10 Minnesota corporation doing business in the State of Arizona, and has continuously had

11 at least twenty employees.

12

5. At all relevant times to this action, Target Financial has continuously been

13 an employer engaged in an industry affecting commerce within the meaning of Sections

14 701(b), (g), and (h) of Title VII, 42 U.S.C. §§2000e(b), (g) and (h).

15

6. Prior to institution of this lawsuit, representatives of the Commission

16 attempted to eliminate the unlawful employment practices alleged below, and to effect

17 voluntary compliance with Title VII through informal methods of conciliation, conference

18 and persuasion within the meaning of Section 706(b) of Title VII, 42 U.S.C. §2000e-5(b).

19

20

STATEMENT OF CLAIMS

21

7. More than thirty days prior to the institution of this lawsuit, Bridget Shores

22 filed a charge with the Commission alleging violations of Title VII by Target Financial.

23 All conditions precedent to the institution of this lawsuit have been fulfilled.

24

8. Since at least October 2002, Target Financial has engaged in unlawful

25 employment practices at its Tempe, Arizona facility in violation of Title VII. These

26 unlawful employment practices include failing and refusing to promote Bridget Shores to

27 the position of Collections Credit Specialist, Collections Crediting Coordinator, VISA

28 Chargeback, and Guest Service Team Lead because of her race, African-American, in

violation of Section 703(a) of Title VII.

2 Case 2:06-cv-02331-FJM Document 4 Filed 10/04/2006 Page 2 of 5

1

9. The effect of the practices complained of in Paragraph Eight (¶ 8) has been

2 to deprive Bridget Shores of equal employment opportunities and to otherwise adversely

3 affect her status as an employee because of her race, African-American.

4

10. The unlawful employment practices complained of in Paragraph Eight (¶8) ,

5 above were and are intentional.

6

11. The unlawful employment practices complained of in Paragraph Eight (¶ 8),

7 above were and are done with malice or with reckless indifference to the federally

8 protected rights of Bridget Shores.

9

12. Since at least October 2002, Defendant has failed, in violation

10 of Section 709(c) of Title VII, 42 U.S.C. §2000e-8(c) and 29 C.F.R. §1602.14 (2001), to

11 make and preserve records relevant to the determination of whether unlawful employment

12 practices have been or are being committed, including interview notes for the VISA

13 Chargeback Specialist position.

14

PRAYER FOR RELIEF

15

WHEREFORE, the Commission respectfully requests that this Court:

16

A. Grant a permanent injunction enjoining Defendant Target Financial, its

17 officers, successors, assigns and all persons in active concert or participation with it, from

18 engaging in any employment practice which discriminates on the basis of race;

19

B. Order defendant Target Financial to institute and carry out policies,

20 practices and programs which provide equal employment opportunities for African-

21 American individuals, and which eradicate the effects of its past and present unlawful

22 employment practices;

23

C. Grant a judgment requiring Defendant Target Financial to pay appropriate

24 back wages in an amount to be determined at trial, and prejudgment interest to Bridget

25 Shores, whose wages are being unlawfully withheld as a result of the acts complained of

26 above;

27

D. Order defendant Target Financial to make whole Bridget Shores, whose

28 wages are being unlawfully withheld as a result of the acts complained of above, by

restraining the continued withholding of amounts owing as back wages with prejudgment

3 Case 2:06-cv-02331-FJM Document 4 Filed 10/04/2006 Page 3 of 5

1 interest, in amounts to be determined at trial;

2

E. Order defendant Target Financial to make whole all individuals adversely

3 affected by the unlawful practices described above, by providing the affirmative relief

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

5 limited to, rightful place promotion and reinstatement of Bridget Shores;

6

F. Order defendant Target Financial to make whole Bridget Shores by

7 providing compensation for past and future pecuniary losses resulting from the unlawful

8 employment practices described above, in amounts to be determined at trial;

9

G. Order defendant Target Financial to make whole Bridget Shores by

10 providing compensation for past and future non-pecuniary losses resulting from the

11 unlawful practices complained of above, including emotional pain, suffering,

12 inconvenience, loss of enjoyment of life and humiliation;

13

H. Order defendant Target Financial to pay Bridget Shores punitive damages

14 for its malicious and reckless conduct described above, in amounts to be determined at

15 trial;

16

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

17 public interest; and

18

J. Award the Commission its costs in this action.

19

JURY TRIAL DEMAND

20

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

21 Complaint.

22

DATED this 4th day of October, 2006.

23

Respectfully submitted,

24

RONALD S. COOPER

General Counsel

25

GWENDOLYN YOUNG REAMS

26

Associate General Counsel

27

EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

28

1801 L Street, N.W.

Washington, D.C. 20507

4 Case 2:06-cv-02331-FJM Document 4 Filed 10/04/2006 Page 4 of 5

1

s/ Mary Jo O’Neill

MARY JO O’NEILL

2

Regional Attorney

3

s/ Sally C. Shanley

SALLY C. SHANLEY

4

Supervisory Trial Attorney

5

s/ P. David Lopez

P. DAVID LOPEZ

6

Trial Attorney

7

EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

8

3300 North Central Ave., Suite 690

Phoenix, Arizona 85012-2504

9

Attorneys for Plaintiff

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

5 Case 2:06-cv-02331-FJM Document 4 Filed 10/04/2006 Page 5 of 5

 
 1

2

3

4

5

6

7

IN THE UNITED STATES DISTRICT COURT

8

FOR THE DISTRICT OF ARIZONA

9

10 Equal Employment Opportunity

) No. CV 06-02331-PHX-FJM

11 Commission,

) )

12

Plaintiff,

) ORDER

13 v.

) )

14

)

15

Target Stores, Inc., d/b/a/ Target Financial )

Services,

)

16

)

17

Defendant.

) )

18

19

The court has before it a “Stipulation to Approval of Settlement Agreement”

20

21 (doc. 27). Court approval is sought because, upon breach, the parties may seek court

22 enforcement of the agreement. Court approval of the stipulation would be akin to a

23 consent decree. Because Target consents to the terms of the agreement and because 24 25 there is nothing in the agreement that is obviously in conflict with the public interest, the

26 court grants the parties’ joint request and approves of the stipulated settlement agreement.

27

28

1

1

Pursuant to that agreement and the parties’ notice of settlement (doc. 26), IT IS

2 FURTHER ORDERED dismissing this action with prejudice and on the merits with each

3 party to bear its own costs and fees.

4

5

Dated this 9th day of January, 2008.

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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U.S. District Court DISTRICT OF ARIZONA (Phoenix Division) CIVIL DOCKET FOR CASE #: 2:06-cv-02331-FJM

CLOSED, STD

Equal Employment Opportunity Commission v. Target Stores, Inc. Assigned to: Judge Frederick J Martone Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/29/2006 Date Terminated: 01/09/2008 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Mary Joleen O'Neill EEOC 3300 N Central Ave Ste 690 Phoenix, Az 85012-1848 602-640-5044 Fax: 602-640-5009 Email: mary.oneill@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

P David Lopez EEOC 3300 N Central Ave Ste 600 Phoenix, AZ 85012-1848 602-640-5016 Fax: 602-640-5009 Email: patrick.lopez@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sally Clifford Shanley EEOC 3300 N Central Ave Suite 690 Phoenix, AZ 85012-1848 602-640-5007 Fax: 602-640-5009 Email: sally.shanley@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

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V.
Defendant
Target Stores, Inc. doing business as Target Financial Services

represented by Michelle Ray Matheson Gallagher & Kennedy PA 2575 E Camelback Rd Phoenix, AZ 85016-9225 602-530-8409 Fax: 602-530-8500 Email: mrm@gknet.com TERMINATED: 04/06/2007 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Donald Peder Johnsen Gallagher & Kennedy PA 2575 E Camelback Rd Ste 1100 Phoenix, AZ 85016-9225 602-530-8000 Fax: 602-530-8500 Email: DPJ@gknet.com ATTORNEY TO BE NOTICED

Date Filed 09/29/2006 09/29/2006
09/29/2006 10/04/2006 12/21/2006
01/19/2007 01/19/2007 02/12/2007

# Docket Text
1 COMPLAINT, filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(Lopez, P) (Entered: 09/29/2006)
2 This case has been assigned to the Honorable Frederick J Martone. All future pleadings or documents should bear the correct case number: CV06-2331-PHX-FJM. Notice of Availability of Magistrate Judge to Exercise Jurisdiction form attached. (PEM) (Entered: 09/29/2006)
3 Summons Issued as to Target Stores, Inc. (PEM) (Entered: 09/29/2006)
4 AMENDED COMPLAINT against Target Stores, Inc.; Jury Demand, filed by Equal Employment Opportunity Commission.(Lopez, P) (Entered: 10/04/2006)
5 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Target Stores, Inc. waiver sent on 11/22/2006, answer due 1/22/2007. (Lopez, P) (Entered: 12/21/2006)
6 ANSWER to Amended Complaint by Target Stores, Inc..(Johnsen, Donald) (Entered: 01/19/2007)
7 Corporate Disclosure Statement by Target Stores, Inc.. (Johnsen, Donald) (Entered: 01/19/2007)
8 ORDER SETTING RULE 16 SCHEDULING CONFERENCE - IT IS HEREBY ORDERED: Pursuant to Rule 16, Federal Rules of Civil Procedure, a Pretrial

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02/22/2007 03/26/2007 04/06/2007 04/06/2007
04/06/2007
04/23/2007 04/23/2007 05/07/2007 08/10/2007

Scheduling Conference is set for April 6, 2007 at 2:00 p.m. Scheduling Conference set for 4/6/2007 02:00 PM in Courtroom 506, 401 West Washington Street, Phoenix, AZ 85003 before Judge Frederick J Martone. FURTHER ORDERED that all parties are directed to meet at least 21 days before the scheduling conference, in accordance with Rule 26(f), Federal Rules of Civil Procedure. FURTHER ORDERED that at the Rule 26(f) CaseManagement Meeting, the parties shall develop a PROPOSED CASE MANAGEMENT PLAN. FURTHER ORDERED that counsel shall jointly file their Proposed Case Management Plan with the Clerk of the Court not less than five (5) days before the Pretrial Scheduling Conference. FURTHER ORDERED that it is the responsibility of counsel for the Plaintiff(s) to initiate the communications necessary to prepare the joint Proposed Case Management Plan. FURTHER ORDERED that the Court, after consultation with counsel and the parties, will enter a Rule 16(b) Scheduling Order. Signed by Judge Frederick J Martone on 2/9/07. (SAT) Modified on 2/22/2007 (SAT). DOCKET TEXT MODIFIED TO CORRECT DATE FOR PRETRIAL SCHEDULING CONFERENCE FROM 4/9/07 TO 4/6/07. (Entered: 02/12/2007)
9 NOTICE OF CORRECTION BY THE CLERK re 8 Order, Set Hearings. Description of deficiency: Incorrect hearing date set for Scheduling Conference. Follow up by Clerks Office: The deficiency indicated above has been addressed by the Clerk. Court use only: SAT. (SAT) (Entered: 02/22/2007)
10 REPORT re: Rule 26(f) Planning Meeting by Target Stores, Inc.. (Johnsen, Donald) (Entered: 03/26/2007)
11 Notice re of Withdrawal of Attorney (Michelle R. Matheson) by Target Stores, Inc. (Matheson, Michelle) (Entered: 04/06/2007)
12 Minute Entry for proceedings held before Judge Frederick J Martone: Scheduling Conference held on 4/6/2007. Appearances: P. David Lopez for Plaintiff; and Donald Johnsen for Defendant. Case Management plan is as stated on the record. Rule 16 Scheduling Order to follow.(Court Reporter Linda Schroeder.)(This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry.) (KAR) (Entered: 04/09/2007)
13 RULE 16 SCHEDULING ORDER: Discovery due by 2/1/2008. Dispositive motions due by 4/1/2008. Proposed Pretrial Order due by 8/22/2008. Final Pretrial Conference set for 8/29/2008 at 3:00 PM in Courtroom 506, 401 West Washington Street, Phoenix, AZ 85003 before Judge Frederick J Martone. Jury Trial set for 9/8/2008 at 9:00 AM (5 days) in Courtroom 506, 401 West Washington Street, Phoenix, AZ 85003 before Judge Frederick J Martone. Signed by Judge Frederick J Martone on 4/6/2007. (KAR) (Entered: 04/09/2007)
14 Notice re Service (April 20, 2007) of Defendant's Initial Rule 26(a)(1) Disclosure Statement by Target Stores, Inc. (Johnsen, Donald) (Entered: 04/23/2007)
15 Notice re Service of Initial Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 04/23/2007)
16 Notice re Service of First Supplemental Disclosure by Equal Employment Opportunity Commission (Lopez, P) (Entered: 05/07/2007)
17 Notice re Service of Second Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 08/10/2007)

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09/20/2007 09/20/2007 09/26/2007
10/31/2007
10/31/2007 11/01/2007
11/09/2007 11/13/2007 01/02/2008 01/07/2008
01/09/2008

18 STIPULATION re Confidentiality Order by Target Stores, Inc.. (Attachments: # 1 Text of Proposed Order)(Johnsen, Donald) (Entered: 09/20/2007)
19 Notice re Service of Third Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 09/20/2007)
20 ORDER re 18 Confidentiality Stipulation filed by the parties on 9/20/2007. Order Signed by Judge Frederick J Martone on 9/26/2007. (Order amended by the Court at paragraph 3(a) and the former paragraph 8 was deleted and a new paragraph 8 was added, see attached.pdf document)(KAR) (Entered: 09/27/2007)
21 Notice re EEOC's Notice of Service of First Set of Non-Uniform Interrogatories, First Request for Production of Documents and First Request for Admissions by Equal Employment Opportunity Commission (Lopez, P) (Entered: 10/31/2007)
22 Notice re Service of Defendant's First Set of Interrogatories to Plaintiff by Target Stores, Inc. (Johnsen, Donald) (Entered: 10/31/2007)
23 AMENDED DOCUMENT by Equal Employment Opportunity Commission. Amendment to 21 Other Notice re Service of First Discovery Requests. (Lopez, P) (Entered: 11/01/2007)
24 Notice re 30(b)(6) Deposition by Equal Employment Opportunity Commission (Lopez, P) (Entered: 11/09/2007)
25 Notice re of Service of Production of Documents Pursuant to Fed. R. Civ. P. 30(b)(5) by Equal Employment Opportunity Commission (Lopez, P) (Entered: 11/13/2007)
26 NOTICE of Settlement by Target Stores, Inc. (Johnsen, Donald) (Entered: 01/02/2008)
27 STIPULATION to Approval of Settlement Agreement by Target Stores, Inc.. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Johnsen, Donald) (Entered: 01/07/2008)
28 ORDER - Pursuant to the 27 Stipulation to Approval of Settlement Agreement and the parties' 26 notice of settlement, IT IS FURTHER ORDERED dismissing this action with prejudice and on the merits with each party to bear its own costs and fees. Signed by Judge Frederick J Martone on 1/9/08. (SAT) (Entered: 01/09/2008)

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