, .

Civil Action No.

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05 JUL 14 AM 10: 31.

IN THE UNITED STATES DISTRICT COumG· OF T"e

FOR THE DISTRICT OF NEBRASKA '-

1,,- CLERK

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
THE HERTZ CORPORATION, Defendant.

COMPLAINT AND JURY TRIAL DEMAND
NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964 to correct unlawful employment practices on the basis of race and color, Black, and to provide appropriate relief to James Lam Bil ("Lam Bil"), who was adversely affected by such practices. As alleged with greater particularity below, the United States Equal Employment Opportunity Commission ("Plaintiff' or the "Commission") alleges that The Hertz Corporation ("Defendant") subjected Lam Bil to offensive racial comments and created a hostile work environment in violation of Title VII.
RECEIVED
JUL 1 /! Z005
CLERK U.S. DISTRICT COURT
OMAHA

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 4S1, 1331, 1337, 1343 and 134S. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of Title VII ofthe Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-S(f)(I) and (3), and Section 102 of the Civil Rights Act of 1991,42 U.S.C. §1981A. 2. The employment practices were committed within the jurisdiction of the United States District Court for the District of Nebraska.
PARTIES 3. Plaintiff is an agency of the United States government charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Sections 706(F)(I) and (3) ofTitle VII, 42 U.S.C. § 2000e-S(f)(I) and (3). 4. At all relevant times, Defendant was a Deleware corporation doing business in the State of Nebraska, the City of Omaha, and has continuously had at least fifteen (IS) employees. S. At all relevant times, Defendant 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).
GENERAL ALLEGATIONS 6. More than thirty (30) days prior to the institution of this lawsuit, Lam Bil filed a charge with the Commission alleging violations of Title VII by Defendant. 7. All conditions precedent to the institution of this lawsuit have been fulfilled. 8. Lam Bil worked for Defendant as a Transporter in Omaha, Nebraska.
2

9. On or about September 6,2002, Manager Crista Lorence ("Lorence") (white) made racially derogatory remarks when she referred to Lam Bil as "ape"while in the presence of approximately six (6) other employees.
10. General Manager Tim Jaekels ("Jaekels") was advised of Lorence's conduct. 11. On or about September 20, 2002, Jaekels met with Lam Bil and Lorence. Lorence denied Lam Bit's allegation. 12. Defendant failed to conduct an investigation or take remedial action as a result of Lam Bit's allegations. 13. On or about October 10, 2002, Lorence referred to Lam Bil as a "monkey" in the presence of other employees. 14. Lam Bil reported the incident to Jaekels on or about October II, 2002. IS. Jaekels took no action in response to Lam Bil's allegation. 16. Lam Bil resigned on or about October 18, 2002.
CLAIM FOR RELIEF 17. The effect of the practices complained of in the paragraphs above has been to deprive Lam Bil of equal employment opportunities and otherwise adversely affect his status as an employee because of his race and color, Black. 25. The unlawful employment practices complained of in the paragraphs above were intentional. 26. The unlawful employment practices complained of in the paragraphs above were done with malice or with reckless indifference to the federally protected rights of Lam Bil.
3

PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court:
A. Grant a pennanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in, maintaining, or failing to remedy a hostile work environment, and any other employment practice which discriminates on the basis of race or color.
B. Order Defendant Employer, to make whole Lam Bil by providing appropriate backpay with prejudgment interest, in an amount to be detennined at trial, and other affinnative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to reinstatement of Lam Bi!.
C. Order Defendant Employer to make whole Lam Bil by providing compensatory damages in amounts to be proved at trial, and other affinnative and equitable relief necessary to eradicate the effects of its unlawful employment practices.
D. Order Defendant Employer to pay punitive damages for their malicious and reckless conduct described above, in an amount to be detennined at tria!.
E. Grant such further relief as the Court deems necessary and proper in the public interest.
F. Award the Commission its costs of this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
4

,

Dated: July 13, 2005

Respectfully Submitted,

ERIC S. DREIBAND General Counsel
GWENDOLYN REAMS Associate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1801 L Street, N.W. Washington, DC 20507
JOSEPH H. MITCHELL Regional Attorney
NANCY A. WEEKS Supervisory Trial Attorney
~~ KIM R. ROGERS Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Denver District Office 303 East 17th Avenue, Suite 510 Denver, CO 80203 (303) 866-1361 FAX (303) 866-1375
NOTE: It is sufficient for service on the EEOC that pleadings, notices, and any other court documents be served on the Trial Attorneys. Duplicate service is not required on the General Counsel in Washington, D.C.
5

 
 Civil Action No.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
THE HERTZ CORPORATION, Defendant.

CONSENT DECREE

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RECEIVED
JU~ 1 11 Z005
CLERK U.S. D!STRICT COURT
O~~HA

TABLE OF CONTENTS I. RECITALS ............................................................... 1 II. JURISDICTION .......................................................... 2 III. ISSUES RESOLVED ...................................................... 2 IV. MONETARY RELIEF .................................................... 2 V. EQUITABLE RELIEF ..................................................... 3
A. Scope ........................................................... 3 B. Injunctive Relief .................................................. 3 C. Anti-discrimination Policy ......................................... 3 D. Training ........................................................ 4 E. Posting of Notice .................................................. 6 F. Record Keeping And Reporting Provisions ........................... 6 VI. RETENTION OF JURISDICTION AND FILING OF DECREE ................. 9 VII. ENFORCEMENT ........................................................ 9 VIII. EEOC AUTHORITY .................................................... 9 IX. COSTS AND ATTORNEY'S FEES ......................................... 10 X. NOTICE ................................................................ 10 Attachment A ............................................................... 12

I. RECITALS 1. This matter was instituted by Plaintiff, Equal Employment Opportunity Commission ("Commission" or "Plaintiff' or "EEOC"), an agency of the United States government, alleging that, in September - October ,2002, Defendant, The Hertz Corporation ("Hertz" or "Defendant") subjected James Lam Bil to verbal harassment based on his race, Black, and failed to take immediate remedial action to prevent future harassment. 2. The Commission and Defendant, desiring to settle this action by an appropriate Consent Decree ("Decree"), agree to the jurisdiction of this Court over the parties and the subject matter ofthis action, and agree to the power of this Court to enter a Consent Decree enforceable against Defendant. 3. This Decree is [mal and binding upon the parties as to the issues resolved, as well as upon their successors and assigns. 4. The parties agree that this Consent Decree fairly resolves the issues alleged in this lawsuit, and constitutes a complete resolution of all of the Commission's claims of unlawful employment practices under Title VII that arise from the charge of discrimination (32E-200300141) filed by James Lam Bil. 5. For the purpose of amicably resolving disputed claims, the Defendant joins with the Commission in requesting this Court to adjudge as follows: IT IS ORDERED, ADJUDGED, AND DECREED AS FOLWWS:
Page I of 12

II. JURISDICTION

6. The parties stipulate to the jurisdiction of the Court over the parties and subject

matter of this action, and have waived the entry of fmdings of fact and conclusions of law.

7. The duration of this Decree shall be two (2) years from the date of signing by the

Court.

III. ISSUES RESOLVED

8. This Decree resolves all claims for damages arising out of the issues and claims

f,' 3? setforth in Civil Action No.

115 (!J/ 3

9. Defendant and its officers, agents, employees, sucoessors, and all other persons in

active concert or participation with any of them will not interfere with the relief herein ordered,

but shall cooperate in the implementation of this Decree.

IV. MONETARY RELIEF

10. Defendant agrees to pay the amount of$8,500 to James Lam Bil for compensatory

and punitive damages, and interest.

10.1 Payments pursuant to this Paragraph 10 shall be paid to James Lam Bil by

certified check within five business days after entry ofthis Consent Decree

by the Court;

10.2 Defendant shall pay all administrative and/or other costs associated with

the payment of monetary reliefunder this Decree.

10.3 Defendant shall mail a copy of the certified check to the EEOC Attn. Kim

Rogers, Trial Attorney, 303 E. 17" Ave. Ste 510, Denver, CO 800 II

Page 2 of 12

V. EQUITABLE RELIEF

A. Scope

11. The tenns of this Decree shall apply to all Hertz facilities in Nebraska, excluding

Hertz Local Edition locations.

B.

Injunctive Relief

12. During the tenn of this Consent Decree, Defendant, its officers, agents, successors

and other persons in active concert or participation with it, or any of them, are eIUoined from

engaging in any employment practice which discriminates on the basis of race or color.

13. During the tenn of this Consent Decree, Defendant, its officers, agents, successors

and other persons in active concert or participation with them, or any of them, are enjoined from

engaging in reprisal or retaliation of any kind against any person because of such person's

opposition to any practice made unlawful under Title VII of the Civil Rights Act of 1964, as

amended, the Americans with Disabilities Act, the Age Discrimination in Employment Act, or

the Equal Pay Act, because of such person's filing a charge, testifying or participating in any

manner in any investigation, proceeding or hearing under any of these statutes, because such

person was identified as a witness or possible witness for the Commission, because such person

participated in any manner in this action or in the investigation giving rise to this action, or

because such person is designated as an aggrieved individual under this Decree.

C. Anti-discrimination Policy

14. Defendant shall adopt and/or maintain a policy proscribing discrimination based

on race or color, and proscribing retaliation against any employee who complains about race

Page 3 of 12

discrimination or who files a charge of discrimination alleging race discrimination. ("AntiDiscrimination Policy"). Defendant shall post and keep posted for the duration of this Decree, in a conspicuous place in each of its facilities, where notices to employees and applicants for employment are customarily kept or posted, a copy of the Anti-Discrimination Policy. Within thirty (30) days of entry of this Decree, Defendant shall provide a copy of the AntiDiscrimination Policy, and will provide the policy to newly hired employees within ten (l0) days of their hire. Within forty-five (45) days of entry of this Decree, Defendant shall forward a copy of the Anti-Discrimination Policy to the Commission and a letter indicating that the AntiDiscrimination Policy has been posted and distributed. D. Training
15. Beginning August 1,2005, and annually thereafter, Defendant shall conduct annual training for all its employees on what constitutes employment discrimination. Training will include employee notification of the Defendant's policy and procedures for registering complaints of discrimination. Defendant agrees that said training will also counsel employees on the penalties of engaging in such discriminatory behavior. Defendant agrees that said training will include the Defendant's non-retaliation policy. All training under this Paragraph 15 shall be at Defendant's selection and expense. The training will be conducted as follows:
15.1 Non-managerial Employees. Defendant will require non-managerial employees to attend two (2) hours of training per year regarding workplace discrimination, with emphasis on harassment and retaliation. Harassment training will include discussion of harassment based on race, color, national origin,
Page 4 of 12

disability, gender, age, and religion. Additionally, Defendant will require new employees to complete tbe requisite two (2) hours of training within ninety (90) days ofbeing hired.
15.2 Managerial and Supervisory Employees Defendant will require all individuals who work in a managerial or supervisory capacity
to receive at least eight (8) hours of training annually regarding Title vn and other federal anti-
discrimination laws. Four (4) of the eight (8) hours must directly address harassment, retaliation, and racial discrimination. Additionally, Defendant will require employees newly hired or promoted into a managerial or supervisory position to complete the requisite four (4) hours of training witbin tbirty (30) days of being hired or promoted.
15.3 Human Resource Employees Defendant will require all individuals who work in a human resource capacity to receive
at least twenty (20) hours of training annually regarding Title vn and otber federal anti-
discrimination laws. Four (4) of the twenty (20) hours must directly address harassment, retaliation, and racial discrimination. Additionally, Defendant will require employees newly hired or promoted into a human resource position to complete seven (7) hours of general EEO training witbin tbirty (30) days of being hired or promoted into a human resource position.
16. Defendant agrees tbat tbe first such training session for each employee group identified in Paragraph 15, above, will take place witbin one hundred twenty (120) days after entry of this Decree. Defendant agrees tbat all personnel shall botb register and attend tbe seminar training sessions. In tbe semi-annual reports required under the Reporting provisions of this Decree, Defendant shall submit copies of tbe agenda of tbe training programs, identify tbe
Page 5 of 12

individuals providing the training, and provide the registries of attendance. 17. Defendant shall provide the Commission with thirty (30) days notice that a
seminar-training session will be conducted. E. Posting of Notice
18. Within five (5) business days of the entry of this Consent Decree, Defendant shall post in a conspicuous place in each of its facilities where notices to employees and applicants for employment are customarily kept or posted, the Notice attached as Attachment A to this Decree. The Notice shall remain posted for the duration of this Decree. lfthe Notice becomes defaced or illegible, Defendant will replace it with a clean copy. Defendant shall certify to the Commission, in writing, within twenty (20) days of entry of this Decree that the Notice has been properly posted and shall provide recertification in each of the semi-annual reports required under the Reporting provision of this Consent Decree. F. Record Keeping And Reporting Provisions
19. For the duration of this Consent Decree, Defendant shall maintain all records concerning implementation of this Consent Decree. The Commission shall have the right to interview any personnel employed by Defendant for the purpose of determining Defendant's compliance with the terms of this Consent Decree. In the event the Commission exercises its right to interview personnel pursuant to this paragraph, said interviews shall be scheduled with due regard to the convenience of the individual to be interviewed.
20. Each party shall bear its own costs in conjunction with the maintenance of records, preparation of any report, access or copying of records, or interviews of employees.
21. Defendant shall provide semi-annual reports for each six-month period following
Page 6 of 12

the entry of the Decree. The reports shall be due thirty (30) days following the respective sixmonth period, except the fmal report which shall be submitted to the Commission two weeks prior to the date on which the Consent Decree is to expire.
22. Each report shall provide the following information: 22.1 Complaints of Race Discrimination 22.1.1 For purposes of this Paragraph 22.1, the term "complaint of race discrimination" will include any written or verbal complaint which alleges discrimination based on race, color, or national origin, or alleges conduct, which the Defendant recognizes as presenting an allegation of race discrimination. For example, an employee may complain that he was denied promotion because he is Black, or that co-workers call him "coon". These are "complaints of discrimination" even though the employee does not expressly allege discrimination. 22.1.2 The name, address and telephone number of each person making a complaint of race discrimination to Defendant or to any federal, state, or local government agency. 22.1.3 A brief summary of each complaint, including the date of the complaint, the name of the individual(s) who allegedly engaged in the discriminatory conduct, the Defendant's response to the complaint, the name of the person who investigated or responded to the complaint, and what, if any resolution was reached; 22.1.4 Copies of all documents memorializing or referring to the
Page 7 of 12

complaint, investigation, and/or resolution thereof. 22.2 Training
22.2.1 For each training program required under Para. 15, and conducted during the reporting period, Derendant shall submit a registry of attendance. 22.2.2 For each training program required under Para. 15.3 (HR), and completed during the reporting period, Defendant shall provide a certificate of completion. 22.2.3 For each training program conducted by Defendant's staff, Defendant will provide the following information: (a) a detailed agenda; (b) copies of all training material provided to or utilized by the trainer(s); (c) the name ofeach training and a summary ofhis or her qualifications. 22.2.4 For each training program conducted by a vendor not affiliated with Defendant, Defendant will identity the vendor and provide a copy of the program agenda. 22.3 Posting of Notice: Defendant shall re-certity to the Commission, that the Notice required to be posted under Paragraph 18 of this Consent Decree has been properly posted or, if removed, was promptly replaced, during the duration of the reporting period.
Page 8 of 12

VI. RETENTION OF JURISDICTION AND FILING OF DECREE 23. This Court shall retain jurisdiction of this case for purposes of compliance with this Decree and entry of such further orders or modifications as may be necessary or appropriate to effectuate equal employment opportunities for employees. Upon submission of the final report referenced in Paragraph 21, and the expiration ofa period of thirty (30) days after submission of said report, within which the Commission has not filed an objection thereto, the Commission and Defendant shall promptly file a Joint Stipulation for Dismissal with Prejudice (Joint Stipulation) of this civil action, upon which filing this Decree shall automatically dissolve, and this Civil Action shall be dismissed with prejudice. If the Commission files an objection to the final report within said thirty-day (30) period, the Parties will file the Joint Stipulation promptly after the Court's resolution of the Commission's objection.
VII. ENFORCEMENT 24. There is no private right of action to enforce Defendant's obligations under the Decree and only the Commission and Defendant, or their successors or assigns, may enforce compliance herewith. 25. Enforcement may be had by the Commission or Defendant petitioning the Court for enforcement of the terms of this Decree.
VIII. EEOC AUTHORITY 26. With respect to matters or charges outside the scope of this Decree, this Decree shall in no way limit the powers of the Commission to seek to eliminate employment practices or acts made unlawful by any of the statutes over which the EEOC has enforcement authority, and are unrelated to the claims asserted in this lawsuit.
Page 9 of 12

IX. COSTS AND ATTORNEY'S FEES

27. Each party shall be responsible for and shall pay its own costs and attorney's fees.

X. NOTICE

28. Any notice, report, or communication required under the provisions of this Decree

shall be sent by certified mail, postage prepaid, to the appropriate parties as follows:

Regional Attorney Denver District Office Equal Employment Opportunity Commission 303 E. 17th Avenue, Suite 510 Denver, CO 80203

The Hertz Corporation 225 Brae Boulevard Park Ridge, NJ 07656

9.:::s ~
SO ORDERED this 2-!(" day of

,2005.

BY THE COURT:

Page 10 of 12

APPROVED AS TO FORM:
Joseph H. Mitchell Regional Attorney
Nancy A. Weeks Supervisory Trial Attorney
~GKimz' R.a RO-~ geer~ S~ Trial Attorney (303) 866-1361

F~
Senior Staff Counsel 225 Brae Blvd. Park Ridge, NJ 07656-0713
Attorney for Defendant

Equal Employment Opportunity Commission 303 East 17th Avenue, Suite 510 Denver, CO 80203

Attorneys for Plaintiff

BY CONSENT:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

THE HERTZ CORPORAnON

~((/t4&/// ~ BY: JOSePbOMhChi1

~ BY:

Regional ttorney

Senior Staff Counsel

Dat:¥

Page 11 of 12

· .

ATTACHMENT A

NOTICE

The following notice is being posted pursuant to the tenns of a Consent Decree reached between the parties in EEOC v. The Hertz Corporation. filed in the United States District Court for the District of Nebraska, Civil Action No.

Management of The Hertz Corporation wishes to emphasize the company's fundamental policy of providing equal employment opportunity in all of its operations and in all areas of employment practices. Hertz respects the right of its employees and applicants for employment to work in an environment free from discrimination and reaffinns its commitment to complying with the strictures of Title VII. It is our policy to prohibit all discrimination in terms of hiring, promotion, compensation, benefits, discharge or discipline because ofrace or color, as well as all other protected bases. Each of us at Hertz deserves a workplace where we can achieve our full potential.

Unlawful Discrimination: Under federal law, it is unlawful for an employer to discriminate based on race, color, religion, sex, national origin, age (over 40), or disability. This means that a supervisor or manager cannot make decisions about hiring, promotion, pay, or other conditions of employment, based on race, color, religion, sex, national origin, age (over 40), or disability. This policy extends to insurance benefits and all other tenns, conditions and privileges of employment.

Unlawful Harassment: Harassment is unwelcome conduct based on sex, race, religion, national origin, age, or disability that is so severe or pervasive that it alters employment conditions or creates a hostile work environment. It can be spoken or written, graphic or physical, and may include foul or obscene language or name-calling. It can be done to offend, or simply as insensitive joking. Harassment of any kind has no place in the work environment and will not be tolerated.

Unlawful Retaliation: It is also unlawful to discriminate, harass, or retaliate against any individual who reports or complains about what he or she believes to be unlawful discrimination based on race, color, religion, sex, national origin, age (over 40), or disability, or because he or she has filed, or participated in an investigation of, a charge of discrimination.

Reporting Improper Conduct: If you are aware of any events, conduct, or infonnation which you believe may indicate some improper discrimination or harassment, it is very important that you report the information so the necessary steps may be taken to investigate, identify, and promptly remedy any problems.

Any employee who believes that he/she has suffered discrimination or harassment on the basis of age, race, color, religion, sex, pregnancy, national origin, or disability, has the right to contact the EEOC directly at 1-800669-4000. In compliance with federal law, no official at The Hertz Corporation will retaliate against an employee who makes an internal complaint of discrimination or who contacts the EEOC, the Nebraska Employment Opportunity Cormnission, or its state counterpart.

This Notice shall remain posted for the tenn of two years.

The Hertz Corporation By:._ _ _ _ _ _ _ _ _ _ _ _ __

Date:_ _ _ _ _ _ __

Page 12 of 12

 
 CLOSED,TRIAL−OMAHA
U.S. District Court District of Nebraska (8 Omaha) CIVIL DOCKET FOR CASE #: 8:05−cv−00339−LSC−FG3

Equal Employment Opportunity Commission v. Hertz Corporation, The Assigned to: Chief Judge Laurie Smith Camp Referred to: Magistrate Judge F.A. Gossett Cause: 42:2000e Job Discrimination (Employment)
Plaintiff

Date Filed: 07/14/2005 Date Terminated: 09/11/2007 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Equal Employment Opportunity Commission

represented by Joseph H. Mitchell EQUAL EMPLOYMENT OPPORTUNITY COMMISSION − DALLAS 207 South Houston Street 3rd Floor Dallas, TX 75202 (303) 866−1370 Fax: (303) 866−1373 Email: JOSEPH.MITCHELL@EEOC.GOV ATTORNEY TO BE NOTICED

Kim R. Rogers EEOC − DENVER 303 East 17th Avenue Suite 510 Denver, CO 80203 (303) 866−1361 Fax: (303) 866−1375 Email: Kim.Rogers@eeoc.gov ATTORNEY TO BE NOTICED

Nancy A. Weeks EQUAL EMPLOYMENT OPPORTUNITY COMMISSION − DENVER 303 East 17th Avenue Suite 510 Denver, CO 80203 (303) 866−1947 Fax: (303) 866−1375 Email: Nancy.Weeks@eeoc.gov ATTORNEY TO BE NOTICED

V. Defendant Hertz Corporation, The

Date Filed 07/14/2005
07/14/2005 07/28/2005

# Docket Text
1 COMPLAINT with Jury Demand against Hertz Corporation, The; no Summons issued, by Attorney Kim R. Rogers on behalf of Equal Employment Opportunity Commission(CJP) (Entered: 07/14/2005)
2 CIVIL COVER SHEET (CJP) (Entered: 07/14/2005)
3 CONSENT DECREE. Signed by Judge Laurie Smith Camp on 7/28/2005. (JAE, ) (Entered: 07/28/2005)

09/11/2007 09/14/2007

4 ORDER that by operation of the Consent Decree 3 the Clerk close this matter for all purposes. Ordered by Judge Laurie Smith Camp. (CJP) (Entered: 09/12/2007)
5 Mail Returned as Undeliverable addressed to martha.muller@eeoc.gov regarding Order 4 . Receiptant no longer at this office. Other receiptants received notification of filing. E−mail not resent. (JAE, ) (Entered: 09/18/2007)