IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff, v. PRODESIGN, LLC

CIVIL ACTION NO.
3:04cv623 RM
COMPLAINT

JURY TRIAL DEMAND

Defendants.

NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and to provide appropriate relief to Robbie Caldwell, Janice Patrick, and a class of similarly situated employees who were adversely affected by such practices. The Commission alleges that Defendant subjected Robbie Caldwell, Janice Patrick, and a class of similarly situated females to sexual harassment by a male co~worker and allowed the hostile envirorunent to interfere with the work performance of other employees.
JURISDICTION AND YENUE I. 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 706 (f)(l) and (3) and 707 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000 e-5(!)(1) and (3) and 2000e-6 ("Title VII") and Section 102 of the Civil Rights Act of 1991,42 U.S.C. § 1981a.

2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States Court for the Northern District oflndiana, South Bend Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (th'e "Commission"), is the 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 Section 706 (f)( I) and (3) and 707 ofTitle VII, 42 U.S.C. § 2000e-S (f)(!) and (3) and 2000e-6. 4. At all relevant times, Defendant, Prodesign, LLC (the "Employer"), has continuously been an Indiana corporations, doing business in the State of Indiana and the City of Elkhart, and has continuously had at least IS employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 70l(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, Robbie Caldwell and Janice Patrick filed charges with the Commission alleging violations ofTitle VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least January 2000, Defendant Employer has engaged in unlawful employment practices at its Elkhart, Indiana facility, in violation of Section 703(a) (I) of Title VII, 42 U.S.C. §§ 2000e-2(a) (!). The unlawful practices include subjecting Robbie Caldwell and Janice Patrick, and a class of similarly situated females to hostile environment sexual

harassment by a male co-worker and allowing the hostile environment to interfere with the work performance of other employees.
8. The effect of the practices complained of in paragraph 7 above has been to deprive Robbie Caldwell, Janice Patrick, and a class of similarly situated females and other employees of equal employment opportunities and otherwise adversely affect their status as employees, because of their sex.
9. The unlawful employment practices complained of in paragraph 7 above were intentionaL
10. The unlawful employment practices complained of in paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Robbie Caldwell, Janice Patrick, and a class of similarly situated females and other employees.
PRAYER FQR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a pennanent injunction enjoining Defendant Employer, their officers, successors, assigns, and all persons in active concert or participation with them, from engaging in sexual harassment, and any other employment practice which discriminates on the basis of sex. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Robbie Caldwell, Janice Patrick, and a class of similarly situated females and other employees by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph

7 above, including but not limited to out of pocket expenses, and medical expenses, plus prejudgment interest, in amounts to be determined at trial.
D. Order Defendant Employer to make whole Robbie Caldwell, Janice Patrick, and a class of similarly situated females and other employees by providing compensation for past and future nonpecuniary losses resulting from the WJlawful practices complained of in paragraph 7 above, including but not limited to physical and emotional pain and suffering, mental anguish, and loss of enjoyment of life, in amounts to be determined at trial.
E. Order Defendant Employer to pay Robbie Caldwell, Janice Patrick, and a class of similarly situated females and other employees punitive damages for their malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Commission its costs of this action.

JURY TRIAL DEMAND
The Commission requests ajury trial on all questions of fact raised by its complaint.
Respectfully Submitted,
ERIC S. DREIBAND General Counsel
JAMESL.LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
'?IJ."f.ukk
Ml HELLE EISELE, #12070-49 Supervisory Trial Attorney
~du~wae-1 ANN FARN ORTH, #8364-49 Senior Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Indianapolis District Office 101 West Ohio Street, Suite 1900 Indianapolis, In 46204 Phone: (317) 226-7949 Fax: (317)226-5571 Email: joann.farnsworth@eeoc.gov

 
 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION and

)

ROBBIE L. CALDWELL,

)

)

Plaintiffs,

)

)

v.

)

)

PRODESIGN, LLC,

)

)

Defendant.

)

Case No. 3:04CV 623RM

CALDWELL’S COMPLAINT
NATURE OF THE ACTION
This is an action by Robbie L. Caldwell (“Caldwell”) under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and to provide appropriate relief to Caldwell, who was adversely affected by such practices. Caldwell alleges that Defendant subjected her to sexual harassment by a male co-worker and allowed the hostile environment to interfere with the performance of other employees.
JURISDICTION AND VENUE
1. Jurisdiction in this action is based on the existence of federal questions and upon the rights of action created under federal statute. 28 U.S.C. §§ 451, 1331, 1337, and 1343. This action is arises under Title 42, United States Code, §§ 2000e-5 (“Title VII”), et seq. and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.
2. Venue for this action lies within the United States District Court for the Northern

District of Indiana, South Bend Division because the employment practices alleged to be unlawful were committed within the jurisdiction of the Northern District of Indiana, South Bend Division.
PARTIES
3. Plaintiff Caldwell is, at all relevant times, a citizen of the United States of America, and a resident of the State of Indiana, living in the Northern District. She is a resident of Elkhart County, Indiana.
4. At all relevant times, Defendant, Prodesign, LLC (“Employer”), has continuously been an Indiana corporation, doing business in the State of Indiana and the City of Elkhart, and has continuously had at least fifteen (15) employees.
5. At all relevant times, Defendant Employer has 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. On November 4, 2003, more than thirty (30) days prior to the institution of this lawsuit, Caldwell filed a charge with the Equal Employment Opportunity Commission (“Commission”) alleging violations of Title VII by Defendant Employer.
7. Since at least January, 2000, Defendant Employer has engaged in unlawful employment practices at its Elkhart, Indiana facility, in violation of Section 703(a)(1) of Title VII, 42 U.S.C. §§ 2000e-2(a)(1). The unlawful practices include subjecting Caldwell to a hostile environment, sexual harassment by a male co-worker and allowing the hostile environment to interfere with the work performance of other employees.
8. The effect of the practices complained of in paragraph 7 above has been to deprive
2

Caldwell of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex.
9. The unlawful employment practices complained of in paragraph 7 above were intentional.
10. The unlawful employment practices complained of in paragraph 7 above were done with reckless indifference to the federally protected rights of Caldwell.
PRAYER FOR RELIEF
WHEREFORE, Caldwell respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, their officers, successors, assigns and all persons in active concert or participation with them, from engaging in sexual harassment, and any other employment practice which discriminates on the basis of sex. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities to women and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Caldwell by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including but not limited to physical and emotional pain and suffering, mental anguish, and loss of enjoyment of life, in amounts to be determined at trial. D. Order Defendant Employer to make whole Caldwell by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including but not limited to out of pocket expenses and medical expenses, plus prejudgment interest, in amounts to be determined at trial.
3

E. Order Defendant Employer to pay Caldwell punitive damages for their malicious and reckless conducted described in paragraph 7 above in amounts to be determined at trial.
F. Award Caldwell her costs of this action, including attorney’s fees, and such relief as the Court deems necessary and proper in the public interest.
REQUEST FOR TRIAL BY JURY
Caldwell requests a jury trial on all issues properly tried by jury. Respectfully submitted this December 2, 2004.
CHESTER LAW OFFICE

s/ Edward J. Chester Edward J. Chester, #3749-20 Laura L. Ezzell, #24174-20 Attorneys for Intervening Plaintiff, Robbie L. Caldwell

230 N. Main St., Suite 2 P.O. Box 1768 Elkhart, IN 46515-1768 (574)296-1515

CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of December, 2004, a copy of the foregoing pleading was filed electronically. Notice of this filing will be sent to the following parties by operation of the Court’s electronic filing system. Parties may access this filing through the Court’s system.

Jo Ann Farnsworth EQUAL EMPLOYMENT OPPORTUNITY COMMISSION joann.farnsworth@eeoc.gov
Michelle Eisele EQUAL EMPLOYMENT OPPORTUNITY COMMISSION michelle.eisele@eeoc.gov
Laurie Young EQUAL EMPLOYMENT OPPORTUNITY COMMISSION laurie.young@eeoc.gov

David J. Carr ICE MILLER david.carr@icemiller.com
Julie M. Conrad ICE MILLER julie.conrad@icemiller.com

4

I certify that on the 2nd day of December, 2004, a copy of the foregoing pleading was mailed, by first class United States mail, postage prepaid and properly addressed to:
Jo Ann Farnsworth Michelle Eisele Laurie Young
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 101 W. Ohio St., Suite 1900 Indianapolis, IN 46204 and David J. Carr Julie M. Conrad ICE MILLER
One American Square, Box 82001 Indianapolis, IN 46282-0200
CHESTER LAW OFFICE
s/ Edward J. Chester Edward J. Chester
5

 
 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION and MRS. ROBBIE L. CALDWELL,
Plaintiff,
v.
PRODESIGN LLC.,
Defendant.

)

)

)

)

)

)

)

CAUSE NO. 3:04-CV-623 RM

)

)

)

)

ORDER

On September 30, 2004, Plaintiff Equal Employment Opportunity Commission

(“EEOC”) filed their complaint against Defendant on behalf of Robbie Caldwell, Janice Patrick,

and a class of similarly-situated female employees. On December 2, 2004, Plaintiff Mrs. Robbie

Caldwell filed a Motion to Intervene, which this Court granted on December 16, 2004. Pursuant

to Fed. R. Civ. P. 24(c) which requires that a motion to intervene be accompanied by “a pleading

setting forth the claim or defense for which intervention is sought,” Plaintiff Caldwell filed a

complaint contemporaneously with the Motion to Intervene. Plaintiff Caldwell’s complaint

alleges substantially the same information as the EEOC’s complaint. Defendant filed a motion

to consolidate cases under Fed. R. Civ. P. 42(a) on December 22, 2004.

Defendant appears to have misconstrued the purpose of Rule 42. Rule 42 typically

applies when the same parties are involved in two separate actions. In the present situation,

there is only one case, which happens to include two complaints. Therefore, there is no parallel

case to consolidate with the present matter.

Liberally reading Defendant’s motion, it appears that Defendant is actually attempting to consolidate the two complaints. Under Rule 24(c), Plaintiff Caldwell was required to file her own pleading. Defendant cites to no authority which would suggest that the two Plaintiffs may only have one complaint, especially when it is possible that parties may eventually seek alternative forms of relief. While Fed. R. Civ. P. 7 contemplates the filing of “a complaint,” Rule 7 has not been violated because there are two separate Plaintiffs in this action who have individual interests. Thus, Defendant’s Motion to Consolidate [Doc. No. 29] is DENIED.
SO ORDERED. Dated this 21st day of January, 2005.

cc: Chief Judge Miller; Counsel of Record

s/Christopher A. Nuechterlein Christopher A. Nuechterlein United States Magistrate Judge

2

 
 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION, et al.

)

)

Plaintiffs

)

)

v.

)

)

PRODESIGN, LLC

)

)

Defendant

)

)

CIVIL ACTION NO. 3:04-CV-623RM

CONSENT DECREE

This action was instituted by the Equal Employment Opportunity Commission

("Commission") under the authority granted to it under Section 706(f)(1) of Title VII of the Civil

Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(1). The Commission's action was brought

to correct alleged unlawful employment practices on the basis of sex. Specifically, the Commission

alleged in its Complaint that Prodesign, LLC subjected Robbie Caldwell and a class of similarly

situated employees to sexual harassment.

The Commission, Plaintiff-Intervenor Robbie Caldwell, and Prodesign hereby stipulate to

the jurisdiction of the Court over the parties and the subject matter of this action.

The parties have advised the Court that they desire to resolve the remaining allegations in

the Complaint without the burden, expense, and delay of further litigation. The parties acknowledge

that this is a disputed claim, and that by agreeing to this Consent Decree, Prodesign makes no

admission of wrongdoing.

It is therefore the finding of this Court, made on the pleadings and the record as a whole,

that: (1) the Court has jurisdiction over the parties and the subject matter of this action; (2) the

purpose and provisions of Title VII will be promoted and effectuated by the entry of this Consent Decree; and (3) this Consent Decree resolves all the matters in controversy between the parties as provided in paragraphs 1 through 12 below.
It is therefore ORDERED, ADJUDGED AND DECREED as follows: 1. Prodesign, LLC agrees that it will not discriminate against employees on the basis of sex and will abide by the requirements of the law as to its obligation to maintain a work environment for all employees that is free from sexual harassment. 2. Defendant agrees that it will not discriminate or retaliate in any way against any person because of opposition to a practice made unlawful under Title VII or because of the filing of a charge, or the giving of testimony, assistance, or participation in any manner in an investigation, proceeding, or hearing under Title VII. 3. Prodesign agrees to pay $3,000.00 in damages to Janice Patrick in settlement of all claims raised in this lawsuit. Defendant agrees not to deduct from the settlement amount of $3,000.00 the amount of the employer’s share of any costs, taxes, or social security required by law to be paid by Defendant. Defendant further agrees to issue a form 1099 to Ms. Patrick. A check in the amount of $3,000.00 shall be made payable to Janice Patrick and sent to her by certified mail at 310 Railroad Street, Wolcottville, IN 46795. Fifteen days from the entry of this Consent Decree by the Court, the Commission will forward a release (see Appendix A) to Janice Patrick for her execution. The Commission will notify counsel for Defendant on receipt of the release executed by Janice Patrick. Then, within thirty days from the entry of this Consent Decree by the Court, Defendant shall mail the check, by certified mail, to Ms. Patrick. Defendant shall mail a copy of Ms. Patrick’s check and proof of its delivery to Ms. Patrick (a signed certified mail receipt) to the
2

Commission. Upon receipt of proof of delivery of a check to Ms. Patrick, the Commission shall forward the release to counsel for Defendant.
4. Prodesign agrees to post the Notice of Non-Discrimination Policy attached as Appendix B to this Decree in a conspicuous place on its premises. Said notice shall remain posted throughout the term of this Decree.
5. Prodesign agrees to eliminate from the records of Robbie Caldwell and Janice Patrick all references to their charges of discrimination and to eliminate from the records of Robbie Caldwell and Janice Patrick all references to participation in this suit and shall make no reference to such charges or participation in the event that it is contacted for references. This provision survives the expiration of the Consent Decree.
6. Defendant agrees to conduct a training seminar for all employees, including all its managers and supervisors, regarding the policies prohibiting sexual harassment. Said employees must attend a seminar within six (6) months from the date of entry of this Decree. Thirty (30) days prior to the date of the seminar, the Defendant shall provide notice to the Commission regarding the date, time, and place of the seminar and shall send to the Commission a copy of the agenda, subject matter to be covered and an outline of the written materials to be used. The Commission may at its option send its own representative to attend the training to observe or to speak at the training. Upon completion of the training program, Prodesign shall certify to the Commission the specific training given and shall provide the Commission with a roster of all employees in attendance.
7. Prodesign agrees to submit reports to EEOC detailing its compliance with this decree. Within six (6) months of the date of this Decree, Prodesign will certify to the EEOC Regional Attorney that the training referenced in paragraph 6 of this Decree has occurred. In addition, two (2)
3

annual reports shall be submitted during the term of this decree. The first report shall be due on June 30, 2006, and the subsequent reports shall be mailed to the Commission no later than June 30th of each year covered by the decree. The report shall include the following information for the twelve (12) month period preceding the report: a description of any and all verbal or written complaints of sexual harassment or sex discrimination received by the company or any of its managers or supervisors from any employee, the name and position of the complainant, and the disposition of the complaint, including any discipline administered as a result of the complaint. Reports shall be sent to the attention of Laurie A. Young, Regional Attorney, or her successor, Equal Employment Opportunity Commission, 101 W. Ohio Street, Suite 1900, Indianapolis, Indiana, 46204.
8. Prodesign agrees that the EEOC may review compliance with this Decree. As part of such review, the EEOC may inspect the premises, interview employees, and examine and copy documents.
9. In the event that the EEOC alleges that a violation of this Decree has occurred, prior to exercising any remedy provided by law, EEOC will give notice in writing thereof, specifically identifying the alleged violation to Prodesign. Prodesign will have thirty (30) days in which to investigate and respond to the allegation. Thereafter, the parties will have a period of thirty (30) days, or such additional period as may be agreed upon by them, in which to negotiate and confer regarding such allegation before Plaintiff exercises any remedy provided by law.
10. The Commission and Prodesign shall each bear their own costs and attorney fees. 11. The term of this Decree shall be for two (2) years following the date of the entry of this Decree.
4

12. RETENTION OF JURISDICTION BY COURT. The Court will retain jurisdiction of this cause throughout the duration of this Decree for purposes of monitoring compliance with this Decree and entry of such further orders as may be necessary or appropriate.

APPROVED:
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
By:
s/Jo Ann Farnsworth Jo Ann Farnsworth, #8364-49
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 101 W. Ohio St. Indianapolis, IN 46204
Attorney for Plaintiff

PRODESIGN, LLC
By:
s/David Carr David Carr, #4241-49 ICE MILLER One American Square Box 82001 Indianapolis, IN 46282 Attorney for Defendant

ROBBIE CALDWELL
By:
s/Laura L. Ezzell Edward J. Chester, #3749-20 Laura L. Ezzell, #24174-20 230 N. Main Street Suite 2 P.O. Box 1768 Elkhart, IN 46515-1768
Attorney for Plaintiff-Intervenor

5

ENTERED:
October 12, 2005 Dated

/s/ Robert L. Miller, Jr. Chief Judge United States District Court

Copies to:
Jo Ann Farnsworth, Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 101 W. Ohio Street, Suite 1900 Indianapolis, IN 46204
Edward J. Chester Laura L. Ezzell 230 N. Main Street Suite 2 P.O. Box 1768 Elkhart, IN 46515-1768
David J. Carr Julie M. Conrad Beth Hatfield ICE MILLER One American Square Box 82001 Indianapolis, IN 46282-0002

6

APPENDIX A RELEASE
In consideration of the payment to me by Prodesign, LLC of $3,000.00, and in consideration of the Consent Decree agreed to by the Equal Employment Opportunity Commission and Prodesign, LLC in Civil Action 3:04-CV-623 RLM, entered by the Court on the__ day of ___________, 2005, of which this Release is a part, I, Janice Patrick, hereby fully and forever release and discharge Prodesign, LLC, its affiliated companies, and any affiliated or parent corporations, and their successors and assigns, including their present and former directors, officers, shareholders, employees, and agents, from any claim or obligation based on unlawful employment discrimination under Title VII of the Civil Rights Act of 1964, as amended, raised in Civil Action No. 3:04-CV-623 RLM.
I agree that I will be solely and individually responsible for paying any applicable income taxes which may be due and owing, if any, as a result of Defendant’s payment of the sum set forth above. I acknowledge that I have not relied on any representations made by Defendant or the EEOC relating in any way to the tax treatment of the payments pursuant to this agreement.
I have read this Release and I execute it voluntarily, without coercion or threat of reprisal.

IN WITNESS WHEREOF, this Release is signed and executed by me on the _______ day of _______________, 2005.

______________________________ Name

County of

)

) SS

State of

)

Subscribed and sworn to before me this ______ day of ____________, 2005.

_____________________________ Notary Public

County of Residence__________________ My Commission Expires:_______________

8

APPENDIX B
EMPLOYEE NOTICE
Posted Pursuant to an Agreement with the U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Indianapolis District Office
NOTICE OF NON-DISCRIMINATION POLICY
Federal law requires that there be no discrimination against any employee or applicant for employment because of the employee's race, color, religion, sex, national origin, age (40 and over), or disability.
Federal law also prohibits sexual harassment in the workplace. Sexual harassment in the workplace occurs when the employer allows its employees to be subjected to verbal or physical conduct of a sexual nature and this conduct interferes with the employee's work or creates an intimidating or offensive work environment.
Prodesign employees are expected to personally ensure that their own conduct does not sexually harass other employees.
Prodesign will take disciplinary measures against those employees guilty of sexual harassment.
Prodesign supports and will comply with such Federal law in all respects and will not take any actions against employees because they have exercised their rights, reported an alleged violation under the law or have given testimony, assistance, or participation in any investigation, proceeding or hearing conducted by the U. S. Equal Employment Opportunity Commission.
An employee has the right, and is encouraged to exercise that right, to report allegations of employment discrimination in the workplace. An employee may contact the U. S. Equal Employment Opportunity Commission for the purpose of filing a charge of employment discrimination.
Questions concerning this notice may be addressed to:
Equal Employment Opportunity Commission 101 W. Ohio St., Suite 1900
Indianapolis, Indiana 46204-4203 Telephone: (317) 226-7212 EEOC 800 # 1-800-669-4000 TDD (317) 226-4162

 
 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, et al.,
Plaintiffs,
v.
PRODESIGN, LLC,
Defendant.

)

)

)

)

)

)

)

CAUSE NO. 3:04-cv-623 RM

)

)

)

)

ORDER

Plaintiff Equal Employment Opportunity Commission, Plaintiff-Intervenor Robbie

Caldwell, and Defendant, Prodesign LLC, filed a Motion for Entry of a Stipulated Protective

Order on March 1, 2005, requesting that this Court issue a protective order covering various

information in the underlying litigation. For the following reasons, this Court DENIES parties’

motion [Doc. No. 31]. The parties may resubmit a proposed protective order which comports

with Seventh Circuit precedent for this Court’s consideration.

I.

APPLICABLE STANDARDS

When granting a proposed protective order, this Court must independently determine

whether "good cause" exists to seal the requested information from the public record.

Fed.R.Civ.P. 26(c); Citizens First National Bank of Princeton v. Cincinnati Insurance Co., 178 F.3d 943, 944 (7th Cir.1999). In doing so, this Court must not grant parties carte blanche to seal or protect whatever they desire. Citizens, 178 F.3d at 944; See also Pierson v. Indianapolis

Power & Light Co., 205 F.R.D. 646, 647 (S.D. Ind. 2002) (“Independent and careful evaluations

of protective orders are especially important because ‘[t]he judge is the primary representative of

the public interest in the judicial process....’”) (quoting Citizens, 178 F.3d at 945). In other words, this Court cannot serve as a rubber stamp whenever parties wish to seal public records, but must review all requests to seal documents in light of the public interest in the judicial process. Citizens, 178 F.3d at 945 (citing In re Krynicki, 983 F.2d 74 (7th Cir.1992); Miller, Arthur M., Confidentiality, Protective Orders, and Public Access to the Courts, 105 Harv. L.Rev. 427, 492 (1991)).
When reviewing an agreed protective order seeking to seal documents produced in discovery, this Court must ensure that “(1) the information sought to be protected falls within a legitimate category of confidential information, (2) the information or category sought to be protected is properly described or demarcated, (3) the parties know the defining elements of the applicable category of confidentiality and will act in good faith in deciding which information qualifies thereunder, and (4) the protective order explicitly allows any party and any interested member of the public to challenge the sealing of particular documents.” Pierson, 205 F.R.D. at 647 (citing Citizens, 178 F.3d at 946). This Court may issue a protective order in this case pursuant to its referral order and 28 U.S.C. § 636(b)(1)(A). II. ANALYSIS
The parties’ proposed order fails to satisfy the last prong of the above standard because it fails to explicitly state that any party and any interested member of the public may challenge the sealing of a particular document. Parties motion simply states that:
All transcripts, exhibits, discovery responses, and any other documents filed with the Court which have been designated as CONFIDENTIAL INFORMATION shall be filed in a sealed envelope bearing the title of this action with an indication of the general nature of its contents and a statement substantially in the following form...This provision shall not be deemed to prevent additional copies of any pleading or paper from being hand-delivered to the Court’s chambers,
2

provided, however, such copies comply with the requirements set forth herein. (Stip. Prot. Order ¶ 8). The parties’ proposed order fails to mention that the parties and members of the public have a right to challenge the sealing of a document. As court proceedings contain public information, and because this Court serves as the primary representative of the public interest in the judicial process, it must comply with the Seventh Circuit’s strict requirements for granting protective orders. See Pierson, 205 F.R.D. at 647. Therefore, for the proposed order to comply with Seventh Circuit standards, it must contain explicit language that allows a party or any interested member of the public to challenge the sealing of particular documents. III . CONCLUSION Because the parties’ Motion for Entry of a Stipulated Protective Order does not contain a provision which allows a party or a member of the public to challenge the sealing of particular documents, this Court DENIES parties’ motion [Doc. No. 31]. The parties may resubmit their proposed order in light of the standards set forth in this order and the citations herein. SO ORDERED. Dated this 10th Day of March, 2005.
s/Christopher A. Nuechterlein Christopher A. Nuechterlein United States Magistrate Judge
3

 
 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION, et al.

)

)

Plaintiffs,

)

)

v.

)

)

PRODESIGN, LLC

)

)

)

)

Defendant.

)

)

CIVIL ACTION NO. 3:04-CV-623

STIPULATED PROTECTIVE ORDER

Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the Plaintiff, Equal

Employment Opportunity Commission, Plaintiff-Intervenor Robbie Caldwell, and Defendant,

Prodesign, LLC, through their respective counsel, hereby stipulate to the entry of this Order for

the protection of certain confidential and proprietary information which may be produced or

otherwise disclosed during the course of this action.

THEREFORE, the parties having so stipulated, this Court having determined that a

Protective Order is necessary and appropriate pursuant to the terms of Fed. R. Civ. P. 26(c), and

the Court otherwise being fully advised in the premises;

IT IS HEREBY ORDERED that:

1. For the purposes of this Order, the following definitions shall govern:

(a) “CONFIDENTIAL INFORMATION” shall mean all information identified in paragraph 12 of this Order;

(b) “COUNSEL” shall mean all attorneys of record in the above-captioned case and their agents; and

(c) “SUPPORT PERSONNEL” shall mean any clerical and/or support staff employed by COUNSEL, specifically including (i) secretarial support staff, (ii) paralegal employees, (iii) any independent stenographer retained to record and transcribe testimony in this action; and (iv) any in-house or independent entity retained or used for the sole purpose of making photocopies of CONFIDENTIAL INFORMATION.
2. Any information disclosed pursuant to this Protective Order shall be used solely for the purposes of this lawsuit and may not be used, or disclosed, for any other purpose.
3. The receiving party’s COUNSEL shall be permitted to disclose such CONFIDENTIAL INFORMATION to their client(s) and any consulting and/or testifying experts only to the extent necessary to prepare this matter for trial and then only after such individuals have read this Stipulated Protective Order and have specifically agreed in writing not to discuss, disclose, or otherwise use any CONFIDENTIAL INFORMATION of the disclosing party in violation of the terms and spirit of this Protective Order. The requirement of a written agreement may be satisfied by having the individual sign and date a copy of this Protective Order. The original signed copy of the Protective Order shall be kept by COUNSEL for the receiving party.
4. The receiving party’s COUNSEL shall be permitted to disclose CONFIDENTIAL INFORMATION to SUPPORT PERSONNEL without the need for a written agreement provided each individual is instructed to maintain such information in strict confidence and then only to the extent necessary to prepare this matter for trial.
5. The receiving party, COUNSEL, all SUPPORT PERSONNEL thereof, and any experts employed by the receiving party or COUNSEL are strictly prohibited from disclosing CONFIDENTIAL INFORMATION to any individual not contemplated by the terms of this Protective Order absent a court order, subpoena, or the written consent of the originating party.
2

If a party receives a subpoena or legally enforceable order requiring disclosure of any CONFIDENTIAL INFORMATION, the receiving party shall object to the disclosure of such information, citing this Protective order, and shall immediately provide notice thereof to the originating party and its counsel.
6. Nothing contained herein shall preclude a party from requesting or seeking an order permitting the disclosure of CONFIDENTIAL INFORMATION to non-party witnesses. The parties agree to confer in good faith to resolve any concerns regarding the disclosure of CONFIDENTIAL INFORMATION to non-party witnesses.
7. CONFIDENTIAL INFORMATION disclosed during a deposition shall be so designated on the record and, unless otherwise agreed by COUNSEL, the Court Reporter shall be instructed to separately transcribe such testimony under separate cover with each page thereof clearly marked as “CONFIDENTIAL.”
8. All transcripts, exhibits, discovery responses, and any other documents filed with the Court which have been designated as CONFIDENTIAL INFORMATION shall be filed in a sealed envelope bearing the title of this action with an indication of the general nature of its contents and a statement substantially in the following form:
“THIS ENVELOPE CONTAINS CONFIDENTIAL DOCUMENTS FILED IN THIS CASE BY (NAME OF PARTY) AND, EXCEPT BY ORDER OF THE COURT OR PURSUANT TO STIPULATION BY THE PARTIES, SHALL NOT BE OPENED NOR THE CONTENTS THEREOF DISPLAYED OR REVEALED TO ANYONE OTHER THAN TO THE COURT OR COUNSEL OF RECORD.” This provision shall not be deemed to prevent additional copies of any pleading or paper from being hand-delivered to the Court’s chambers provided, however, such copies comply with the requirements set forth herein. 9. A party or any member of the public may apply to the Court for a ruling that a
3

specific document (or category of documents) deemed confidential is not entitled to such status and protection. The party that designated the document as confidential shall be notified of the application and shall be provided an opportunity to respond. To maintain the confidentiality of any challenged document (or category of documents) the proponent of the confidentiality must show by a preponderance of the evidence that there is good cause for the document to have such protection.
10. Procedures for utilizing and disclosing CONFIDENTIAL INFORMATION during trial shall be discussed and agreed upon by the parties prior to the submission of the Final Pre-trial Order and, if necessary, incorporated therein.
11. Upon termination of this litigation, whether by final judgment and appeal, or by settlement, all materials and documents designated as CONFIDENTIAL INFORMATION, as well as all copies, summaries, and abstracts thereof, shall be returned to the originating source or destroyed.
12. This Protective Order applies to the documents listed below. From time to time, by agreement of the parties, additional documents may be added to this list by the filing of a supplemental list with the Court.
The following documents are included in the Protective Order: a. Documents which contain confidential personal information, which cannot
otherwise be redacted, including but not limited to social security and driver license numbers, bank information, or information regarding minor children. b. Medical records of Janice Patrick. c. Medical records of Arrel Jones. IT IS SO ORDERED this7th day of April, 2005.
4

S/Christopher A. Nuechterlein United States Magistrate Judge COURT, NORTHERN DISTRICT OF INDIANA, SOUTH BEND DIVISION

APPROVED:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

PRODESIGN, LLC

By: s/Jo Ann Farnsworth Jo Ann Farnsworth
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 101 W. Ohio St. Indianapolis, IN 46204
Attorney for Plaintiff

By: s/Julie M. Conrad David Carr Julie Conrad Beth Hatfield
ICE MILLER One American Square Box 82001 Indianapolis, IN 46282
Attorneys for Defendant

ROBBIE CALDWELL

By: s/Laura L. Ezzell
Edward J. Chester Laura L. Ezzell 230 N. Main Street Suite 2 P.O. Box 1768 Elkhart, IN 46515-1768
Attorneys for Plaintiff-Intervenor

5

Copies to: Jo Ann Farnsworth EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 101 W. Ohio St., Suite 1900 Indianapolis, IN 46204 Edward J. Chester Laura L. Ezzell 230 N. Main Street Suite 2 P.O. Box 1768 Elkhart, IN 46515-1768 David J. Carr Julie M. Conrad Beth Hatfield ICE MILLER One American Square Box 82001 Indianapolis, IN 46282-0002
6

 
 CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

CASREF, PROTO, TERMED
U.S. District Court Northern District of Indiana [LIVE] USDC Northern Indiana (South Bend)
CIVIL DOCKET FOR CASE #: 3:04-cv-00623-RLM-CAN

Equal Employment Opportunity Commission v. Prodesign LLC Assigned to: Judge Robert L Miller Jr Referred to: Magistrate Judge Christopher A Nuechterlein Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/30/2004 Date Terminated: 10/12/2005 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Jo Ann Farnsworth Equal Employment Opportunity Commission - Ind/IN 101 W Ohio Street Suite 1900 Indianapolis, IN 46204-4203 317-226-7949 Fax: 317-226-5571 Email: joann.farnsworth@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Laurie A Young Equal Employment Opportunity Commission - Ind/IN 101 W Ohio Street Suite 1900 Indianapolis, IN 46204-4203 317-226-7947 Fax: 317-226-7203 Email: legal.station@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Intervenor Plaintiff

Michelle F Eisele Equal Employment Opportunity Commission - Ind/IN 101 W Ohio Street Suite 1900 Indianapolis, IN 46204-4203 317-226-7059 Fax: 317-226-5571 Email: michelle.eisele@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

1 of 6

6/11/2007 12:17 PM

CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

Mrs Robbie L Caldwell
Intervenor Plaintiff Janice Patrick V. Defendant Prodesign LLC

represented by Edward J Chester Chester Law Office 230 North Main Street Suite 2 PO Box 1768 Elkhart, IN 46515-1768 574-296-1515 Fax: 574-295-9316 Email: ed@chesterlawoffice.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laura L Ezzell Chester Law Office 230 North Main Street Suite 2 PO Box 1768 Elkhart, IN 46515-1768 574-296-1515 Fax: 574-295-9316 Email: laura@chesterlawoffice.com ATTORNEY TO BE NOTICED
represented by Janice Patrick PRO SE
represented by Beth Hatfield Hatfield & Peters LLC 801 Newton Street Jasper, IN 47546 812-482-7100 Fax: 812-482-7133 ATTORNEY TO BE NOTICED
David J Carr Ice Miller LLP - Ind/IN One American Square Suite 3100 Indianapolis, IN 46282-0200 317-236-5840 Fax: 317-592-4810 Email: CARR@icemiller.com ATTORNEY TO BE NOTICED
Julie M Conrad Ice Miller LLP - Ind/IN One American Square Suite 3100 Indianapolis, IN 46282-0200

2 of 6

6/11/2007 12:17 PM

CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

317-236-5894 Fax: 317-592-4814 ATTORNEY TO BE NOTICED

Date Filed 09/30/2004
09/30/2004 09/30/2004 09/30/2004 09/30/2004 10/12/2004
10/12/2004
10/15/2004 10/15/2004 10/18/2004 10/18/2004 10/26/2004 10/27/2004
10/27/2004 11/01/2004

#

Docket Text

1 COMPLAINT with Jury Demand against Prodesign LLC , filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(jld) (Entered: 10/01/2004)
2 Summons Issued as to Prodesign LLC. (jld) (Entered: 10/01/2004)
3 NOTICE of Appearance by Jo Ann Farnsworth on behalf of Equal Employment Opportunity Commission (jld) (Entered: 10/01/2004)
4 NOTICE of Appearance by Michelle F Eisele on behalf of Equal Employment Opportunity Commission (jld) (Entered: 10/01/2004)
5 NOTICE of Appearance by Laurie A Young on behalf of Equal Employment Opportunity Commission (jld) (Entered: 10/01/2004)
6 SUMMONS Returned Executed by Equal Employment Opportunity Commission. Prodesign LLC served on 10/5/2004, answer due 10/25/2004. (jld) (Entered: 10/13/2004)
7 SUMMONS Returned Executed by Equal Employment Opportunity Commission. Lexis Nexis Document Solutions, Registered Agent for Prodesign LLC served on 10/8/2004, answer due 10/28/2004. (jld) (Entered: 10/13/2004)
8 NOTICE of Appearance by David J Carr on behalf of Prodesign LLC (Carr, David) (Entered: 10/15/2004)
9 AGREED NOTICE to extend time to file answer filed by Prodesign LLC ; answer due by 11-29-2004. (Carr, David) (Entered: 10/15/2004)
10 NOTICE of Appearance by Julie M Conrad on behalf of Prodesign LLC (Conrad, Julie) (Entered: 10/18/2004)
11 NOTICE of Appearance by David J Carr on behalf of Prodesign LLC (Carr, David) (Entered: 10/18/2004)
12 NOTICE of Appearance by Beth Hatfield on behalf of Prodesign LLC (Hatfield, Beth) (Entered: 10/26/2004)
13 NOTICE OF PRETRIAL CONFERENCE: Joint Proposed Discovery Plan due by 12/6/2004. Rule 16 Preliminary Pretrial Conference set for 12/16/2004 at 11:30 AM in South Bend before Magistrate Judge Christopher A Nuechterlein. Signed by Judge Christopher A Nuechterlein on 10/27/04. (ksc) (Entered: 10/28/2004)
14 MAGISTRATE CONSENT FORMS sent to all parties (Standard Track). (ksc) (Entered: 10/28/2004)
15 MOTION To Allow Counsel To Participate In Pretrial Conference By Telephone by Plaintiff Equal Employment Opportunity Commission. (Farnsworth, Jo Ann)

3 of 6

6/11/2007 12:17 PM

CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

11/02/2004
11/02/2004 11/29/2004 11/30/2004 12/01/2004 12/02/2004 12/02/2004 12/02/2004 12/16/2004 12/16/2004 12/16/2004
12/17/2004 12/22/2004 12/22/2004 01/21/2005

(Entered: 11/01/2004)
16 ORDER granting 15 Motion to appear telephonically at the pretrial conference on 12/16/04 at 11:30 a.m. (South Bend time). The Court will allow all counsel to participate by telephone. The court will make arrangements. Signed by Judge Christopher A Nuechterlein on 11/2/04. (jld) (Entered: 11/03/2004)
17 Tracking Sheet sent. (jld) (Entered: 11/03/2004)
18 ANSWER to 1 Complaint by Prodesign LLC.(Carr, David) Modified on 11/30/2004 to reflect link to complaint (rmn ). (Entered: 11/29/2004)
19 REPORT of Rule 26(f) Planning Meeting. (Carr, David) (Entered: 11/30/2004)
20 NOTICE OF ENDORSEMENT of by Equal Employment Opportunity Commission (Farnsworth, Jo Ann) (Entered: 12/01/2004)
21 NOTICE of Appearance by Edward J Chester on behalf of Robbie L Caldwell (Chester, Edward) (Entered: 12/02/2004)
22 MOTION to Intervene by Intervenor Plaintiff Robbie L Caldwell. (Attachments: # 1 Complaint)(Chester, Edward) (Entered: 12/02/2004)
23 NOTICE of Appearance by Laura L Ezzell on behalf of Robbie L Caldwell (Ezzell, Laura) (Entered: 12/02/2004)
24 DISCLOSURE of Caldwell's Initial Disclosures filed by Mrs Robbie L Caldwell.(Ezzell, Laura) (Entered: 12/16/2004)
25 REPORT by Equal Employment Opportunity Commission Regarding Mediation. (Farnsworth, Jo Ann) (Entered: 12/16/2004)
26 RULE 16 PRELIMINARY PRETRIAL CONFERENCE held on 12/16/2004 before Judge Christopher A Nuechterlein : Pltf to submit ADR Report 12/31/2004. Court GRANTS MOTION to Intervene filed by Mrs Robbie L Caldwell. Initial Disclosures to be exchanged by 12/17/2004. Any amendments to the pleadings to be filed by 12/31/2004. Plaintiff expert witness disclosures and reports to be delivered to the defendant by 5/2/2005. Defendant expert witness disclosures and reports to be delivered to the plainitff by 6/1/2005. All discovery to be completed by 8/1/2005. Summary Judgment Packet to be filed by 10/3/2005. Telephonic Scheduling Conference set for 7/12/2005 03:00 PM in South Bend before Magistrate Judge Christopher A Nuechterlein. (slm, ) (Entered: 12/17/2004)
27 DISCLOSURE of Notice of Defendant's Initial Disclosures filed by Prodesign LLC.(Carr, David) (Entered: 12/17/2004)
28 ANSWER to 1 Complaint of Caldwell by Prodesign LLC.(Carr, David) Modified on 12/28/2004 to reflect document number of complaint (rmn ). (Entered: 12/22/2004)
29 MOTION to Consolidate Cases by Defendant Prodesign LLC. (Carr, David) (Entered: 12/22/2004)
30 ORDER denying 29 Motion to Consolidate Cases . Signed by Judge Christopher A Nuechterlein on 1/21/05. (jld) (Entered: 01/21/2005)

4 of 6

6/11/2007 12:17 PM

CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

03/01/2005 03/08/2005 03/10/2005 04/07/2005 06/08/2005 06/10/2005
07/12/2005
07/26/2005
07/27/2005
09/13/2005 09/14/2005 10/12/2005 10/12/2005 10/14/2005
10/14/2005

31 MOTION for Protective Order Stipulated by Parties by Intervenor Plaintiff Mrs Robbie L Caldwell. (Ezzell, Laura) (Entered: 03/01/2005)
32 DISCLOSURE of Caldwell's 26(e) supplemental disclosures filed by Mrs Robbie L Caldwell.(Ezzell, Laura) (Entered: 03/08/2005)
33 ORDER denying 31 Motion for Protective Order. Signed by Judge Christopher A Nuechterlein on 3/10/05. (ksc) (Entered: 03/11/2005)
34 STIPULATED PROTECTIVE ORDER. Signed by Judge Christopher A Nuechterlein on 4/7/05. (jld) (Entered: 04/07/2005)
35 Joint MOTION for Extension of Time to File Dispositive Motions by Intervenor Plaintiff Mrs Robbie L Caldwell. (Ezzell, Laura) (Entered: 06/08/2005)
36 ORDER granting 35 Motion for Extension of Time to File Dispositive Motions. The deadline for filing fully briefed dispositive motions is extended to 12/2/2005. Signed by Judge Christopher A Nuechterlein on 6/10/05. (ksc) (Entered: 06/10/2005)
37 Telephonic Scheduling Conference held on 7/12/2005 before Judge Christopher A Nuechterlein : Settlement Conference set for 9/13/2005 09:30 AM in South Bend before Magistrate Judge Christopher A Nuechterlein. (slm, ) (Entered: 07/13/2005)
38 MOTION for Extension of Time to Complete Discovery by Defendant Prodesign LLC. (Conrad, Julie) Correctly signed attachment(s) added on 7/27/2005 (rmn). Modified on 7/27/2005 to add correctly signed motion (rmn). (Entered: 07/26/2005)
39 ORDER granting re 38 MOTION for Extension of Time to Complete Discovery filed by Prodesign LLC. Motions terminated: 38. Discovery deadline is extended to/including 9/1/2005.. Signed by Judge Christopher A Nuechterlein on 7/27/05. (kds) (Entered: 07/27/2005)
40 Settlement Conference held on 9/13/2005 before Judge Christopher A Nuechterlein : Parties present; CASE SETTLED. (Tape #FTR 9/13/2005.) (slm, ) (Entered: 09/13/2005)
41 ORDER vacating any scheduling deadlines previously set herein, and directs the parties to file their dismissal papers by 10/14/2005.. Signed by Judge Robert L Miller Jr on 9/14/05. (kds) (Entered: 09/15/2005)
42 Joint STIPULATION to Dismiss with Prejudice by Defendants Prodesign LLC, Prodesign LLC. (Carr, David) (Entered: 10/12/2005)
43 CONSENT DECREE Signed by Judge Robert L Miller Jr on 10/12/05. (kds) (Entered: 10/13/2005)
44 ORDER granting Stipulation of Dismissal with Prejudice re 42 Joint STIPULATION to Dismiss with Prejudice. Each party shall bear its owns costs and attorney fees. Signed by Judge Robert L Miller Jr on 10/13/05. (kds) (Entered: 10/14/2005)
45 CLERK'S ENTRY OF JUDGMENT. (kds) (Entered: 10/14/2005)

5 of 6

6/11/2007 12:17 PM

CM/ECF USDC-INND Version 3.0.3 Live DB - Docket Report

https://ecf.innd.uscourts.gov/cgi-bin/DktRpt.pl?958732087820469-L_3...

PACER Service Center

Transaction Receipt

06/11/2007 13:20:01

PACER Login:

hs0328

Client Code:

eeoc

Description:

Docket Report

Search Criteria:

3:04-cv-00623-RLM-CAN

Billable Pages:

3

Cost:

0.24

6 of 6

6/11/2007 12:17 PM