., .". , Case 2:02-cv-02042-JCC Document 1 Filed 09/27/2002 Page 1 of 4
!

1 2 3 4 5 6
J~'1 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

A Luis John F

LSutacnelreoy,,JrA. cRtmegglOSun~aelrAvittsoorrnyeyT

nal

Attot'Rey

__

FILED

OB'GlNAL

Wesley KatahIra, Sentor Tnal Attorney

____ NrFR

Equal Employment Opportunity Commission --LODGED

R" ED

909 First Avenue, SUite 400 Seattle, Washington 98104 Telephone (206) 220-6851
Attorneys for Plaintiff

,vIR SiP

2 -1-IQ-Q-~

'EC'EIV'ED
AA

'" ~a~~IIfIIifiClr :.a'\I~i ~

DOtny

UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRlcnOF WASHINGTON

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

2 04 2n l
)

i

C11!IV}H'~>

-

'-/

)

PlamtIff,

) JURY TRIAL DEMAND

)

v.

)

)

MARITIME EMPLOYMENT SERVICES, INC, )

)

Defendant.

)

--------------------------)

NATURE OF THE ACTION

ThIs is an action under Title VII of the Civil Rights Act of 1964 ("Title VII") and Title I of

the Civil Rights Act of 1991 to correct unlawful employment practices on the basiS of sex and to

proVide appropnate reliefto Cleo Reed and a class ofSimilarly situated females who were adversely

affected by such practices. As alleged with greaterparbcularity in paragraphs 9-13 below, Defendant

Maritime Employment Services, Inc (the "Employment Agency") failed to refer Ms. Reed and a

class ofsimilarly Situated females for employment as licensed mates or masters aboard commercial

shIppmg and fishmg vessels because of their sex, female

JURISDICTION AND VENUE

1 Jurisdiction ofthis Court IS invoked pursuantto 28 U.s C. §§ 451,1331,1337,1343

and 1345 This action IS authorized and instituted pursuant to SectIOns 706(f)(I) and (3) ofTitle VII,

27

111111111111111111111111111111111111111111111111111111111111 EMPLOYMENT OPPORTUNITY COMMISSION

28

1111111111111111111111111111111111111111

Seattle Dlstnct Office 909 F'1tSt Avenue, SUIte 400

CV 02-2042 #1

Se.ttle, WasJungton 98104-1061 Telephone (206) 220-6883

PLAINTIFF'S \~_________- - - - - - - - - - - - -

FacslnuJe (206)220-6911 TDD (206) 220-6882

Case 2:02-cv-02042-JCC Document 1 Filed 09/27/2002 Page 2 of 4

as amended, 42 U.S C. §§ 2000e-5(f)(I) and (3). This action IS also authorized and instituted

2 pursuant to SectIOn 102 of the CIVIl Rights Act of 1991,42 U.S C. § 1981a

3

2

The employment practices alleged to be unlawful were and are committed Wlthm the

4 JurisdictIOn of the Umted States Distnct Court for the Western District of Washington

5

PARTIES

6

3. Plaintiff, the Equal Employment Opportunity COlllIIllssion (the "CommissIOn"), is

7 the agency of the Umted States of Amenca charged With the admimstration, interpretation and

8 enforcement of Title VII and is expressly authorized to brmg this action by Sections 706(f)(1) and

9 (3) ofTitle VII, as amended, 42 USC §§ 2000e-5(f)(I) and (3).

10

4. At all relevant times, Defendant Employment Agency has procured employees for an

II employer and/or has procured for employees opportunities to work for an employer and has been an

12 employment agency Wlthm the meaning of SectIOn 701(c) of Title VII, 42 U.S.C. § 2000e(c).

13

CONCILIATION

14

8

Prior to institution of this laWSUit, the COlllIIllsslOn's representatives attempted to

15 eliminate the unlawful employment practices alleged below and to effect voluntary compliance with

16 Title VII through informal methods of conCIliation, conference and persuasion within the meaning

17 of SectIon 706(b) ofTitle VII, 42 U.S C. § 2000e-5(b).

18

STATEMENT OF CLAIMS

19

9. More than thirty days prior to the mstitution ofthis laWSUit, Cleo Reed filed a charge

20 of dlscnmmatlOn With the Commission allegmg violations of the Title VII by Defendant

21 Employment Agency. All conditIons precedent to the institution ofthis lawsuit have been fulfilled.

22

10. Since at least January I, 2001, Defendant Employment Agency has engaged m

23 unlawful employment practices at its facility m Seattle in violation of SectIOn 703(b) of Title VII,

24 42 U.S.C. § 2000e-2(b). These practices included failing to refer Ms. Reed and a class ofsimIiarly

25 situated females for employment as licensed mates or masters aboard commerCial shipping and

26 fishing vessels because of their sex, female.

27 28
PLAINTIFF'S COMPLAINT PAGE - 2

US EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle DIstnct Office
909 FIrst Avenue, Suite 400 Seattle, Washmgton 98104 1061
Telephone (206) 220-6883 Facslllllie (206) 220 6911 TOD (206) 220-6882

Case 2:02-cv-02042-JCC Document 1 Filed 09/27/2002 Page 3 of 4

II. The effect ofthe practIce(s) complained ofin paragraph 10 above has been to deprive

2 Ms. Reed and a class of sllTI1larly situated females ofequal employment opportunities and othel'Wlse

3 adversely affect their status as applicants for employment because oftheir sex.

4

12. The unlawful employment practices complained of m paragraph 10 above were and

5 are intentional

6

13 The unlawful employment practices complained of m paragraph 10 above were and

7 are done With malice or With reckless mchfference to the federally protected rights of Ms. Reed and

8 and a class of Similarly situated females who were unlawfully denied referral for employment

9

PRAYER FOR RELIEF

10

Wherefore, the CommiSSIOn respectfully requests that this Court:

11

A. Grant a permanent mjunction enJoming Defendant Employment Agency and Its

12 officers, agents, successors, assigns, and all persons m active concert or participation With it, from

13 engagmg in referral practices that discriminate on the basis of sex and in any other employment

14 practice which discrimmates on the basis of sex.

15

B. Order Defendant Employment Agency to mstltute and carry out poliCies, practices

16 and programs which provide equal employment opportunities for women and winch eradicate the

17 effects of ItS past and present unlawful employment practices.

18

C. Order Defendant Employment Agency to make whole Cleo Reed and a class of

19 sinularly situated females by providmg appropriate backpay with prejudgment mterest, in amounts

20 to be proved at trial, and other affirmative relief necessary to eradicate the effects of ItS unlawful

21 employment practices.

22

D. Order Defendant Employment Agency to make whole Ms. Reed and a class of

23 similarly Situated females by provldmg compensation for past and future pecuniary losses resulting

24 from the unlawful employment practices described m paragraphs 10-13 above, includmg without

25 lumtation past and future out-of-pocket expenses, in amounts to be determmed at trial

26

E. Order Defendant Employment Agency to make whole Ms Reed and a class of

27 28
PLAINTIFF'S COMPLAINT PAGE - 3

US EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Seattle Dutnet OrrKe 909 FIrst Avenue, Suite 400
Seattle Wuhmgton 98104·1061 Telephone (206) 220 6883 FlICSIDllle (206) 220-6911 TDD (206) 220-6882

• Case 2:02-cv-02042-JCC Document 1 Filed 09/27/2002 Page 4 of 4

similarly situated females by providing compensatIOn for past and future non-pecuniary losses

2 resulting from the unlawful practices complained of m paragraphs 10-13 above, includmg without

3 limitation emotional pam, suffering, loss of enjoyment of life and humilIation m amounts to

4 determined at trial.

5

F. Order Defendant Employment Agency to pay Ms Reed and a class of similarly

6 situated females punitive damages for Its malicious and/or reckless conduct described m paragraphs

7 10-13 above m an amount to be determined at trial.

8

G. Grant such further relIef as the Court deems necessary and proper m the public

9 mterest.

10

H Award the Commission ItS costs of this action.

11

JURY TRIAL DEMAND

12

The Commission requests a jury trial on Juestions of fact raised by ItS complamt

13

DATED this a:1.61t day of

o~/n;0

,2002.

14
15 A. LUIS LUCERO, JR. RegIOnal Attorney
16 JOHN F. STANLEY
17 Acting Supervisory Trial Attorney

GWENDOLYN YOUNG REAMS Associate General Counsel

18 WESLEY KATAHIRA Semor Trial Attorney
19
20 Bya.,,~ EQUALECOYM 21 OPPORTIJNITY COMMISSION
Seattle District Office 22 909 Fust Avenue, SUite 400
Seattle, Washington 98104 23 Telephone (206) 220-6851

Office of the General Counsel 1801 "L" Street NW Washington, D C 20507

24 Attorneys for P1amtiff
25

26

27 28
PLAINTIFF'S COMPLAINT PAGE - 4

u S. EQUAL EMPWYMENT OPPORTUNITY COMMISSION
Seattle Dlstnd Office
909 F'1fSt Avenue, Sulte 400
Seattle, WasbmglOn 98104-1061
Telephone (206) 220-6883
Facsllrule (206) 2ZD-69i1 roD (206) 220-6882

 
 Case 2:02-cv-02042-JCC Document 4 Filed 10/17/2002 Page 1 of 5

2
3
4 1111111111111111111111111111111111111111111111111111111 5 1111111111111111111111111111111111111111
cv 02-02042 #00000004

HONORABLE JOHN COUGHENOUR

~FILED
_ _ LODGED

ENTERED RECEIVED

OCT 17 2002 PM

AT SEATTLE

CLERK U S DISTRICT COURT

WESTERN OISTRICT OF WASHINGTON

BY

DEPUTY

7

UNITED STATES DISTRICT COURT

8

WESTERN DISTRICT OF WASmNGTON

AT SEATTLE
9

10

EQUAL EMPLOYMENT

11

OPPORTUNITY COMMISSION

12 vs.

Plaintiff,

13
MARITIME EMPLOYMENT SERVICES,

14

INC.,

NO. CV 02-2042C
DEFENDANT'S ANSWER AND AFFIRMATIVE DEFENSES TO COMPLAINT

15 16
17 TO.

Defendant The Equal Employment Opportunity CommiSSIon (EEOC)

18 AND TO: A. Luis Lucero, Jr., Regional Attorney and Kathryn Olson, Supervisory Attorney, Counsel for Plamtiff(EEOC)
19 In answer to Plaintiff's Complamt, Defendant Maritune Employment Services, Inc.,
20

admits, denies, and alleges as set forth below. Each and every allegation of Plaintiff's 21

22

Complaint not expressly admitted IS denied

23

24

25
ORIGINAL~c DEFENDANT'S ANSWER -1 -~

Law OffIce of Reba Weiss 3316 Fuhrman Avenue East, Suite 250

f

Seattle, Washington 98102

206-86~260 Fax: 206- 860-0269

Case 2:02-cv-02042-JCC Document 4 Filed 10/17/2002 Page 2 of 5

NATURE OF THE ACTION

2

Defendant admits that PlaintIff has filed an action under Title VII of the L:1V11 Rights Act

3

of 1964 and Title I of the Civil RIghts Act of 1991. Defendant specifically denies each and

4
every other allegatIon contained m this paragraph.

5 JURISDICTION AND VENUE
6
1. Answenng paragraph I, Defendant admits that JurisdictIon is asserted pursuant to 28
7
U.S.C. §§ 451,1331,1337,1343 and 1345 and that Plaintiffhas instItuted this action 8
pursuant to § 706(t)(1) and (3) of Title VII as amended, and §102 of the Civil RIghts 9

10

Act of 1991,42 U.S.C. §198Ia. Defendant denies the remaining allegations in

11

paragraph 1.

12

2. Answering paragraph 2, Defendant admits doing busmess within the Junsdiction of

13

tlus Court. Defendant denies committing unlawful employment practIces. Defendant

14

denies the remaining allegations in paragraph 2.

15

PARTIES

16

3. Answering paragraph 3, Defendant admits that PlaintIff is the agency of the United

17
States of Amenca charged with the administratIon, mte!pretation and enforcement of

18
Title VII and is authorized to bnng lawsuits under §706(t)(1) and (3) of Title VII, as
19
amended, 42 U.S.C. §§20003-5(t)(1) and (3). Defendant denies the remaining 20

allegations contained in paragraph 3.
21

22

4. Answering paragraph 4, to the extent that this paragraph poses a legal question, no

23

response is required. To the extent a response is required, Defendant admits that it

24

has sometimes found employment for some of Its clients. Defendant denies all

25

remaining allegations contained in paragraph 4

DEFENDANT'S ANSWER -2

Law Office of Reba Wei.. 3316 Fuhrman Avenue East, Suite 250
Seattle, Washington 98102 206-860-0260 Fax: 206- 860-0269

• >

Case 2:02-cv-02042-JCC Document 4 Filed 10/17/2002 Page 3 of 5

CONCILIATION

2

5. Answenng paragraph 8, Defendant admits that it was contacted by an EEOC

3

representative pnor to the institution of this lawsuit. Defendant denies all remammg

4
allegatlons contained in paragraph 8.
5 STATEMENT OF CLAIMS
6 6. Answering paragraph 9, Defendant admits that Cleo Reed filed a charge of
7
discnmination with the EEOC more than 30 days prior to the institution ofthis 8
lawsuit. Whether all conditions precedent to the mstitution of this lawsuit were 9

10

fulfilled is a legal question to which no response is required. Defendant denies all

11

remaining allegations contained in paragraph 9.

12

7. Answering paragraph 10, Defendant demes each and every allegation contained in

13

paragraph 10.

14

8. Answering paragraph 11, Defendant denies each and every allegation contained in

15

paragraph 11.

16

9 Answering paragraph 12, Defendant denies each and every allegation contained in

17 paragraph 12.

18 10. Answering paragraph 13, Defendant denies each and every allegation contamed m
19
paragraph 13 20

AFFIRMATIVE DEFENSES
21

22

By way of further answer to Plaintiff's Complaint and as affinnatlve defenses, Defendant

23

mcorporates by reference herein its answers to paragraphs 1-13 herem and further asserts the

24

following affmnative defenses:

25

DEFENDANT'S ANSWER -3

Law Olllee of Reba Weiss 3316 Fuhrman Avenue East, Snite 250
Seattle, Wasblngton 98102 206-860-0260 Fax: 201>- 860-0269

· ,

Case 2:02-cv-02042-JCC Document 4 Filed 10/17/2002 Page 4 of 5

1

1. Failure to state a claim upon which relief can be granted.

2

2. At all times, Defendant was acting In good faith.

3

3. Plamtiffs claim may be barred based on the doctrines of waiver and estoppel.

4

4. The practices of the Defendant are now, and were during the period of time referred to In

5 the complaint, conducted in all respects in accordance with local, state and federal laws,

6 regulations and constitutIOns.
7
5. Failure to mitigate damages. 8

6. Statute of Lunitations.
9

7. Laches.
10

11

8. Failure to conciliate.

12

9. The scope of the charge filed with the EEOC in this matter limits plaintiff s claims.

13

10. Defendant reserves the right to raise additional affirmative defenses based on discovery

14

to be conducted in this action.

15

RELIEF

16

Wherefore, having fully answered Plaintiffs Complaint, Defendant prays for the

17 following relief:
18 1 For the dismissal ofPlamtIffs complaint with prejudice,
19 2. For Defendant's costs of defense, including reasonable attorney's fees; and
20
3. For such further and other relief as the court deems just and equitable. 21

22

23

24

25

DEFENDANT'S ANSWER -4
- - - - - - - - --.~~~-

Law Omce of Reba Weiss 3316 Fuhrman Avenue East, Suite 250
Seattle, Washington 98102 20fi..860..0260 Fax: 286- 860-0269

·., ~

Case 2:02-cv-02042-JCC Document 4 Filed 10/17/2002 Page 5 of 5

Dated this\b- day of October, 2002.

2

3

4

Reba elSS ~ ~ ~

5

Law Office of Reba Weiss

6

3316 Fuhnnan Avenue East, Suite 250

Seattle, WA 98102

7

Attorney for Defendant

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

DEFENDANT'S ANSWER ·5

Law Office Df Reba Weiss 3316 Fuhrman Avenue East, Suite 250
Seattle, WashingtDn 98102 206-860-0260 Fax: 206- 860-0269

 
 Case 2:02-cv-02042-JCC Document 15 Filed 03/04/2004 Page 1 of 3

1

HONORABLE JOHN C. COUGHENOUR

2 A. LUIS LUCERO, JR., REGIONAL ATTORNEY 3 JOHN STANLEY, ACTING SUPERVISORY TRIAL ATTORNEY
WESLEY KATAHIRA, SENIOR TRIAL ATTORNEY 4 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
909 FIRST AVENUE, SUITE 400 5 SEATTLE, WA 98104
6

7

8

9

10

11

12

UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF WASHINGTON

13

EQUAL EMPLOYMENT OPPORTUNITY )

14 COMMISSION,

)

15

) Plaintiff, )

CIVIL ACTION NO. CV 02-3053

16

)

)

EEOC’S RESPONSE TO COURT’S

17

v.

)

ORDER TO SHOW CAUSE AND

18

)

APPLICATION FOR ENTRY OF

)

DEFAULT JUDGMENT

19 MARITIME EMPLOYMENT SERVICES, )

INC.

)

20

)

NOTE ON MOTION CALENDAR: March 4, 2004

21

Defendant. ) )

22 Plaintiff, Equal Employment Opportunity Commission (“EEOC” or “the Commission”)
23
files this Response to the Court’s March 1, 2004 Minute Order requiring EEOC to “show cause 24

25 why this matter should not be dismissed for Plaintiff’s failure to prosecute pursuant to

26 Fed.R.Civ.P. 41(b).” The parties had previously jointly moved for entry of default based on

27 E Q U AL EM P L OY M E NT O P PO R T UN IT Y C OM M I SS IO N

Seattle District Office

28

Federal Office Building 909 First Avenue, Suite 400

EEOC’S RESPONSE TO COURT’S ORDER TO SHOW CAUSE

Seattle, W ashington 98104-1061 Telephone (206) 220-6883

AND APPLICATION FOR DEFAULT JUDGMENT - PAGE 1

Fax (206) 220-6911 TDD (206) 220-6882

Case 2:02-cv-02042-JCC Document 15 Filed 03/04/2004 Page 2 of 3

1 defendant Maritime Employment Services, Inc.’s (“Maritime” or “defendant”) failure to defend.
2 See Parties’ Agreed Motion for Entry of Default. The Court entered default against Maritime. 3
See Order Granting Parties’ Agreed Motion for Entry of Default. This matter should not be 4
dismissed pursuant to Fed.R.Civ.P. 41(b) since defendant has already been found to be in default 5
6 and this action will be otherwise be dismissed upon entry of a default judgment, for which EEOC

7 is now applying.

8

APPLICATION FOR ENTRY OF DEFAULT JUDGMENT

9 Pursuant to Fed.R.Civ.P. 55(b)(2), EEOC applies to the Court for entry of a default
10 judgment against Maritime. Pursuant to Fed.R.Civ.P. 55, EEOC shall serve Maritime written
11

12 notice of the application for judgment at least 3 days prior to the hearing on EEOC’s application.

13 The parties moved for default because defendant is no longer doing business, recently dissolved

14 as a corporation, has no assets from which to pay monetary damages and lacks liability insurance
15 to cover EEOC’s monetary claims. Thus, no hearings are necessary for the Court “to take an 16
account or to determine the amount of damages or to establish the truth of any averment by 17 18 evidence or to make any investigation of any other matter,” to enable the court to enter judgment
19 or to carry it into effect. Fed.R.Civ.P. 55(b)(2).

20

CONCLUSION

21

For the foregoing reasons, EEOC respectfully requests that the Court not dismiss this

22 action pursuant to Fed.R.Civ.P. 41(b) but instead enter default judgment pursuant to
23

Fed.R.Civ.P. 55(b)(2). 24

25

26

27 E Q U AL EM P L OY M E NT O P PO R T UN IT Y C OM M I SS IO N

Seattle District Office

28

Federal Office Building 909 First Avenue, Suite 400

EEOC’S RESPONSE TO COURT’S ORDER TO SHOW CAUSE

Seattle, W ashington 98104-1061 Telephone (206) 220-6883

AND APPLICATION FOR DEFAULT JUDGMENT - PAGE 2

Fax (206) 220-6911 TDD (206) 220-6882

Case 2:02-cv-02042-JCC Document 15 Filed 03/04/2004 Page 3 of 3

1

DATED this 4th day of March, 2004.

2 A. LUIS LUCERO, JR. 3 Regional Attorney

ERIC S. DREIBAND General Counsel

4 JOHN F. STANLEY Acting Supervisory Trial Attorney
5
6 WESLEY KATAHIRA Senior Trial Attorney
7

JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel

8 BY: /s/ Wesley Katahira

9

ARDC # 6188026

10 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
11 Seattle District Office 12 909 First Avenue, Suite 400
Seattle, Washington 98104 13 Telephone (206) 220-6937

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

14

Attorneys for Plaintiff

15

16

17

18

19

20

21

22

23

24

25

26

27 E Q U AL EM P L OY M E NT O P PO R T UN IT Y C OM M I SS IO N

Seattle District Office

28

Federal Office Building 909 First Avenue, Suite 400

EEOC’S RESPONSE TO COURT’S ORDER TO SHOW CAUSE

Seattle, W ashington 98104-1061 Telephone (206) 220-6883

AND APPLICATION FOR DEFAULT JUDGMENT - PAGE 3

Fax (206) 220-6911 TDD (206) 220-6882

 
 •
Case 2:02-cv-02042-JCC Document 17 Filed 03/18/2004 Page 1 of 2

1

2

3

111111111111111111111111111111111111111111111

11111111111111111111111 11111111111111111
4 02-CV-02042-lICST

5

6

7

UNITED STATES DlSTRlCT COURT

8

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

9

IO

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

11

Pluintiff,

CASE NO. C02-2042C

12

v.

ORDER

13 MARITIME EMPLOYMENT SERVICES, INC.,

14

Defendant.

15

16

This matter comes before the Court on Plaintifr's Application for Entry of Default Judgment

17 (Dkt. No. 15). On October 15, 2003, the Court issued an order (Dkt. No. 13) granting the partie,'

18 Agreed Motion for Entry of Def.ult (Ok!. No.9). Plaintiff now requests that the Court enter. default

19 judgment against Defendant with respect to Defendant's liability only.l Pursuant to Fed. R. Civ. p,

20 55(b)(2), PI.intiffs counsel certifies that it has served Defendant's counsel with. copy of the

21 application at hand.

22

Having reviewed th~ papers submitted by Plaintiff, the Court GRANTS Plaintiffs Application

23
I Plaintiff's current application and the parties' stipulated motion for entry of default (Dkt. No.9) 24 indicate that Defendant "is no lon.ger doing business, recently dis:::olved as a corporation, has no assets
from which to pay monetary damages and lacks liability insurance to cover EEOC's monetary claims." 25 (PI.', Application at 2.) Accordingly, Plaintiff docs no! seek an award of damages against Defendant.
26 ORDER-J

.. ."

Case 2:02-cv-02042-JCC Document 17 Filed 03/18/2004 Page 2 of 2

I for Entry of Default Judgment (Dkl. No. 15). The Clerk is hereby directed to cnter judgment in favor of

2 Plaintiff. The judgment should contain the following note: "This judgment is entered with respect

3 to Defendant's liability only."

4 5

t~is d SO ORDERED

day of March, 2004.

6

\ ~.

\.

7 GE

8

9

10

II

12

J3

14

15

16

17

18

19

20

21

22

23

24

25

26 ORDER-2

 
 WAWD CM/ECF Version 2.5 - Docket Report

Page 1 of 3

CLOSED, JURYDEMAND
U.S. District Court WESTERN DISTRICT OF WASHINGTON (Seattle) CIVIL DOCKET FOR CASE #: 2:02-cv-02042-JCC

EEOC v. Maritime Empl Svcs Assigned to: John C Coughenour Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/27/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by A Luis Lucero, Jr EQUAL EMPLOYMENT OPPORTUNITY COMMISSION SEATTLE DISTRICT OFFICE 909 FIRST AVE STE 400 SEATTLE, WA 98104-1061 206-220-6883 Email: LUIS.LUCERO@EEOC.GOV LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Maritime Employment Services Inc

represented by Reba Weiss 1218 THIRD AVE STE 1500 SEATTLE, WA 98101 206-622-2086 Email: rebalaw@hotmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/27/2002 10/01/2002 10/08/2002 10/17/2002

#

Docket Text

1 COMPLAINT and JURY DEMAND (Summons(es) issued) Receipt # fee waived (USA) (PM) (Entered: 10/01/2002)

2 RETURN OF SERVICE of summons and complaint executed upon defendant Maritime Empl Svcs on 9/30/02 (LS) (Entered: 10/03/2002)

3 ATTORNEY APPEARANCE for defendant by Reba Weiss (LS) (Entered: 10/09/2002)

4 ANSWER AND AFFIRMATIVE DEFENSES to complaint [1-1] by

https://ecf.wawd.uscourts.gov/cgi-bin/DktRpt.pl?113376720235021-L_923_0-1

7/3/2006

WAWD CM/ECF Version 2.5 - Docket Report

Page 2 of 3

10/25/2002 10/25/2002 01/14/2003
06/04/2003 09/03/2003 09/03/2003 09/03/2003 09/29/2003
10/15/2003 03/01/2004 03/04/2004
03/04/2004 03/08/2004

defendant Maritime Empl Svcs (MH) (Entered: 10/18/2002)
5 MINUTE ENTRY: Status conference set for 9:00 1/14/03 (cc: all counsel) (LS) (Entered: 10/25/2002)
6 ORDER re: DISCOVERY and DEPOSITIONS by Chief Judge John C. Coughenour (cc: counsel, Judge) (LS) (Entered: 10/25/2002)
7 MINUTES OF STATUS CONFERENCE: JCC; Dep Clerk: JM; CR: Sue Palmerton; Counsel: Katahira/Weiss; Status conference held 9:00 1/14/03 ; Deadline to Join Additional Parties is 5/9/03 ; Jury trial set for 3/22/04 ; Voir dire/jury instructions deadline 3/18/04 ; Trial briefs to be submitted by 3/18/04 ; Pretrial Order due by 3/12/04 ; 39.1 designation effective 1/9/04 ; (cc: counsel, Judge) (LS) (Entered: 01/15/2003)
8 NOTICE by defendant of change of address for counsel (LS) (Entered: 06/06/2003)
9 STIPULATED MOTION for ENTRY OF Default Judgment ; Noting Date 9/3/2003. (Attachments: # 1 Proposed Order)(LS, ) (Entered: 09/04/2003)
10 DECLARATION of Wesley Katahira filed by Plaintiff Equal Employment Opportunity Commission re 9 MOTION for Default Judgment (LS, ) (Entered: 09/04/2003)
11 CERTIFICATE OF SERVICE by Defendant Maritime Employment Services Inc re 10 Declaration, 9 MOTION for Default Judgment. (LS, ) (Entered: 09/04/2003)
12 MINUTE ORDER 9re: STIPULATED MOTION for Default Judgment ; Court requests that within 15 judicial days of this Order, parties submit a written clarification with respect to the relief requested in their motion. by Judge John C Coughenour. (LS, ) (Entered: 09/29/2003)
13 ORDER granting 9 Parties' Agreed Motion for Entry of Default by Judge John C Coughenour. (LS, ) (Entered: 10/16/2003)
14 MINUTE ORDER TO SHOW CAUSE Show Cause Response due by 3/12/2004. by Judge John C Coughenour. (LS, ) (Entered: 03/02/2004)
15 APPLICATION FOR DEFAULT JUDGMENT AND RESPONSE to ORDER TO SHOW CAUSE by Plaintiff Equal Employment Opportunity Commission. (Katahira, Wesley) TEXT Modified on 3/5/2004 (LS, ). (Entered: 03/04/2004)
15 Response to Order to Show Cause AND MOTION FOR DEFAULT JUDGMENT NOTED on motion calendar; Noting Date 3/4/2004. (LS, ) (Entered: 03/05/2004)
16 CERTIFICATE OF SERVICE by Plaintiff Equal Employment Opportunity Commission re 15 Response to Order to Show Cause, re 15 Response to Order to Show Cause NOTED on motion calendar;. (Katahira, Wesley) (Entered: 03/08/2004)

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17 ORDER : Granting Plaintiff's Application for Entry of Default Judgment. This judgment is entered with respect to Defendant's liability only by Judge John C Coughenour. (LS, ) (Entered: 03/19/2004)
18 JUDGMENT BY COURT in favor of Plaintiff against Defendant. This judgment is entered with respect to Defendant's liability only. (LS, ) (Entered: 03/22/2004)

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https://ecf.wawd.uscourts.gov/cgi-bin/DktRpt.pl?113376720235021-L_923_0-1

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