Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 1 of 7

V r ,_,,_ "'i'CTCOURT

WE"-

. _ ,, .:T OF LOUISINM. - _,\iED

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA
MONROE DIVISION

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
versus
KILPATRICK CENTRAL AMERICAN LIFE INSURANCE CO., ala/o KILPATRICK FUNERAL HOMES
Defendant.

§ 3:06cv1351

§ §

JUDGE JAMES

§ MAG. JUDGE HAYES

§

§ COMPLAINT §
§

§ § JURY TRIAL § DEMANDED §

§

§

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 ofsex and retaliation, and to provide appropriate reliefto Ms. Rhonda J. Woodard. The Commission alleges that Ms. Woodard was sexually harassed by Insurance Agent Ron Franklin. Ms. Woodard rejected Mr. Franklin's advances. Ms. Woodard complained about Mr. Franklin's behavior to her immediate supervisor, Claims Manager Donna Pilcher. Ms. Woodard also submitted a written complaint about Mr. Franklin's behavior to his immediate supervisor, Regional Manager Daniel Graffeo. The Commission further aJJeges that in retaliation for filing the sexual harassment complaint, the Defendant terminated Ms. Woodard. The Commission's allegations are discussed in greater particularity in paragraph 7 below.

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 2 of 7
JURISDICTION AND VENUE 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 pursuantto Section 706(1)(1) and (3) of Title VII ofthe Civil Rights Act of1964, as amended, 42 U.S.C. Section 2000e-5(f)(1) and (3) ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981a. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Western District of Louisiana, Monroe Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title Vll, and is expressly authorized to bring this action by Section 706(f)(l) and (3) ofTitle VII, 42 U.S.C. Section 2000e-5(f)(l) and (3). 4. At all relevant times, Defendant, Kilpatrick Central American Life Insurance Co., afafo Kilpatrick Funeral Homes (the "Employer" or "Defendant"), has continuously been a Louisiana corporation doing business in the State of Louisiana and the City of West Monroe, and has continuously had at least 15 employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting conunerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).
2

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 3 of 7
STATEMENT OF CLAIMS
6. More than thirty days prior to the institution of this lawsuit, Ms. Rhonda J. Woodard
filed a charge with the Coiillllission alleging violations ofTitle Vllby the Employer. All conditions
precedent to the institution of this lawsuit have been fulfilled.
7. Since at least May of2004, Defendant has engaged in unlawful employment practices
in West Monroe, Louisiana, in violation of Section 703(a) and 704(a) of Title Vll, 42 U.S.C. §
2000e-2(a) and §2000e-3(a). Specifically:
A. While an employee of Defendant, Ms. Woodard was sexually harassed by insurance agent Ron Franklin. Said harassment included but is not limited to inappropriate sexual statements, requests for dates, and inappropriate and unwarranted touching. Woodard began her employment with the Defendant as a secretary/cashier on July 3, 2003. She worked under the supetvision of Donna Pilcher, Claims Manager, in the West Momoe, Louisiana area. During her tenure with the Defendant, Woodard was assigned to work with insurance agent Ron Franklin. From the very beginning oftheir working relationship, Franklin subjected her to unwelcome sexual comments which escalated into sexual advances where Franklin would repeatedly ask her to lunch or dinner. Despite her repeated rejections, Franklin's behavior persisted. After several months of this behavior, Franklin began to "brush up against'' Woodard alleging it was just a "mistake." Again, despite her repeated rejections, this behavior continued. In August 2004, Woodard complained to her immediate supervisor, Donna Pilcher, who indicated she would discuss the matter with Pilcher's boss, Beth Bostwick. Woodard heard nothing back from Pilcher and Franklin's behavior continued. In October 2004, Woodard submitted a letter to Defendant's Regional Manager Daniel Graffeo informing him of Franklin's sexual comments, touching and advances to which she got no reply. Mr. Graffeo managed Franklin's work. Despite Woodward's verbal and written requests, and despite Franklin's history of sexual harassing behavior, Defendant took no immediate responsive action to address Ms. Woodard's complaints contrary to their policy.
B. Ms. Woodard complained a bout Mr. Franklin's behavior verbally to her immediate supeiVisor, Claims Manager Donna Pilcher who stated she would discuss the matter with her own supervisor, Beth Bostwick, who according to Defendant's policy is one of the persons to whom complaints are made. Ms. Woodard never heard anything more from Ms. Pilcher or anyone else.
3

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 4 of 7

On or about October 18, 2004, Ms. Woodard submitted a letter to Regional Manager Daniel Graffeo, who according to the Defendant was Mr. Franklin's immediate supervisor, complaining about Mr. Franklin's unwelcome sexual jokes, advances and inappropriate touching. Ms. Woodard received no response to her complaint. On or about October 28, 2004, Ms. Woodard requested a transfer to another office to get away from Franklin. No action was taken to address her written complaint nor her request for a transfer. Rather, as a result ofher complaints, the Defendant tenninated Ms. Woodard in November 2004 in retaliation for complaining about Franklin, who had a history of sexual harassment, but was considered a "good salesman." This interfered with Ms. Woodard's efforts to advance her EEO rights protected by Title VII.

8.

The effects of the practices complained of in paragraph 7 above have been to deprive

Ms. Woodard of equal employment opportunities and to otherwise adversely affect her status as an

employee, because of sex and opposition to practices made unlawful under Title Vll of the Civil

Rights Act of 1964, as amended.

9. intentional.

The unlawful employment practices complained of in paragraph 7 above were

10. The unlawful employment practices complained of in paragraph 7 were done with malice or with reckless indifference to the federally protected rights of Ms. Woodard.

PRAYER FOR RELIEF

Wherefore, the Commission respectfully requests that this Court:

A. Grant a pennanent injunction enjoining Defendant, its officers, successors, assigns,
and all persons in active concert or participation with it, from engaging iri sexual harassment,
retaliation, and any other employmentpractice which discriminate on the basis ofsex and retaliation. B. Order Defendant Employer to institute and carry out policies, practices, and programs
which provide equal employment opportunities for women and for employees who participate or

4

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 5 of 7
oppose unlawful employment practices and which eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant Employer to make whole Ms. Woodard by providing reinstatement, appropriate back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices including but not limited to compensatory and punitive damages.
D. Order Defendant Employer to make whole Ms. Woodard byproviding compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7, including but not limited to job search expenses in amounts to be determined at trial.
E. Order Defendant Employer to make whole Ms. Woodard byproviding compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including emotional pain, suffering, inconvenience, loss ofenjoyment oflife and humiliation, in amounts to be determined at trial.
F. Order Defendant Employer to pay Ms. Woodard punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
H. 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. JAMESL.LEE Deputy General Counsel No Bar Roll Number Assigned
5

<

•

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 6 of 7

GWENDOLYN YOUNG REAMS

Agent for Service: Robin Kilpatrick Fincher President, Kilpatrick Funeral Homes
1401 North 7'' Street
West Monroe, Louisiana 71291

Acting S pervisory Trial Attorney

No Bar Roll Number Assigned

Equal Employment Opportunity Commission

Houston District Office

1919 Smith Street, 1• Floor

7J Houston, Texas

~

~-BUTLER (T.A.)

Senior Trial Attorney

Bar Roll Number 1286

Equal Employment Opportunity Commission

New Orleans Field Office

1555 Poydras Avenue, Suite 1900

New Orleans, LA 70112

Tel: (713)209-3398 (Sacher)

(713) 209-3400 (Sustaita)

(504) 595-2872 (Butler)(TA)

Fax: (504) 595-2886

COUNSEL FOR PLAINTIFF,

U.S. EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

6

Case 3:06-cv-01351-RGJ-KLH Document 1-1 Filed 08/09/2006 Page 7 of 7

(/d$l U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

New Orleans Field Office

1555 Poydra:o; Avenue, Suite 1900

New Orleans, LA 70112-

Michelle Butler Direct Dial (504) 595-2872

(504) 595-2825 TIY (504) 589-1958 FAX (504) 589-686\

August 8, 2006

Sent by Express Mail

Honorable Richard Shemwell United States Clerk of Court United States District Court Western District of Louisiana 300 Fannin Street, Suite 1167 Shreveport, Louisiana 71101

U.S.DISIRtCT COURT WESTERN DISTRICT OF LOUISIANA
RECEIVED
AUG 0 9 1006
Et.4Wfll, CLERK

RE: EEOC v. Kilpatrick Central American Life fusurance Company a/a/o Kilpatrick Funeral Homes

Dear Sir:

Enclosed, please find an original and five copies ofPlaintiffEEOC's Complaint against Kilpatrick Central American Life Insurance Company a/a/o Kilpatrick Funeral Homes along with the Civil Cover Sheet and the Financial & Civil Allotment Sheet. EEOC would like to file this complaint with the court. Please return the excess stamped copies of the complaint in the self-
addressed stamped envelope. Thank you.

Enclosure

Jli J Sincerely, d1 /J/Jg
~{~~-~tler
Senior Trial Attorney

 
 Case 3:06-cv-01351 -RGJ-KLH
U. S. DISTF~ICT COURT WESTERN DISTRICT OF LOUISIANA
RECEIVED

Document 3

Filed 09/21/2006

Page t of 8

SEP g 1 2006
UNITED STATES DISTRICT COURT

~OBERr ~~kL. CL~ESTERN DISTRICT OF LOUISIANA

BY ~’ -- DE~U~’Y |

MONROE DIVISION

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

CIVIL ACTION NO. 3:06CV1351~

Plaintiff,

JUDGE JAMES

versus

MAG. JUDGE HAYES

CENTRAL AMERICAN LIFE INSURANCE CO.,
Defendant.

JURY TRIAL DEMANDED

EEOC’S FIRST AMENDED COMPLAINT NOW INTO COURT, through undersigned counsel, comes Plaintiff, the United States Equal Employment Opportunity Commission, and files its First Amended Complaint. The ptLrpose of the filing of this First Amended Complaint is to correct the name of the Defendant Corporation, which was erroneously identified as I{ilpatrick Central American Life Insurance Co., a/a/o Kilpatrick Funeral Homes. Counsel for the Defendant Corporation has informed Plaintiff that its correct title is Central American Life Insurance Co.
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 retaliation, and to

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 2 of 8
provide appropriate relief to Ms. Rhonda J. Woodard. The Commission alleges that Ms. Woodard was sexually harassed by Insurance Agent Ron Franklin. Ms. Woodard rejected Mr. Franklin’s advances. Ms. Woodard complained about Mr. Franklin’s behavior to her immediate supervisor, Claims Manager Donna Pilcher. Ms. Woodard also submitted a written complaint about Mr. Franklin’s behavior to his immediate supervisor, Regional Manager Daniel Graffeo. The Commission further alleges that in retaliation for filing the sexual harassment complaint, the Defendant terminated Ms. Woodard. The Commission’s allegations are discussed in greater particularity in paragraph 7 below.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 706(0(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5(f)(1) and (3) ("Title VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981a. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Westem District of Louisiana, Monroe Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "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(0(1) and (3) of Title VII, 42 U.S.C. Section 2000e-5(f)(1) and (3).

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 3 of 8

4. At all relevant times, Defendant, Central American Life Insurance Co., (the

"Employer" or "Defendant"), has continuously been a Louisiana corporation doing business in the

State of Louisiana and the City of West Monroe, and has continuously had at least 15 employees.

5. At all relevant times, Defendant Employer has continuouslybeen an employer engaged

in an industry affecting commerce within the meaning of Section 701(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, Ms. Rhonda J. Woodard

filed a charge with the Commission alleging violations of Title VII by the Employer. All conditions

precedent to the institution of this lawsuit have been fulfilled.

7. Since at least May of 2004, Defendant has engaged in unlawful employment practices

in West Monroe, Louisiana, in violation of Section 703 (a) and 704(a) of Title VII, 42 U.S.C. § 2000e-

2(a) and §2000e-3(a). Specifically:

Ao

While an employee of Defendant, Ms. Woodard was sexually harassed by

insurance agent Ron Franklin. Said harassment included but is not limited to

inappropriate sexual statements, requests for dates, and inappropriate and

unwarranted touching. Woodard began her employment with the Defendant

as a secretary/cashier on July 3, 2003. She worked under the supervision of

Donna Pilcher, Claims Manager, in the West Monroe, Louisiana area. During

her tenure with the Defendant, Woodard was assigned to work with insurance

agent Ron Franklin. From the very beginning of their working relationship,

Franklin subjected her to unwelcome sexual comments which escalated into

sexual advances where Franklin would repeatedly ask her to lunch or dinner.

Despite her repeated rejections, Franklin’s behavior persisted. After several

months of this behavior, Franklin began to "brush up against" Woodard

alleging it was just a "mistake." Again, despite her repeated rejections, this

behavior continued. In August 2004, Woodard complained to her immediate

supervisor, Donna Pilcher, who indicated she would discuss the matter with

Pilcher’s boss, Beth Bostwick. Woodard heard nothing back from Pilcher and

Franklin’s behavior continued. In October 2004, Woodard submitted a letter

3

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 4 of 8
to Defendant’s Regional Manager Daniel Graffeo informing him of Franklin’s sexual comments, touching and advances to which she got no reply. Mr. Graffeo managed Franklin’s work. Despite Woodward’s verbal and written requests, and despite Franklin’s history of sexual harassing behavior, Defendant took no immediate responsive action to address Ms. Woodard’s complaints contrary to their policy.
Bo Ms. Woodard complained about Mr. Franklin’s behavior verbally to her immediate supervisor, Claims Manager Donna Pilcher who stated she would discuss the matter with her own supervisor, Beth Bostwick, who according to Defendant’s policy is one of the persons to whom complaints are made. Ms. Woodard never heard anything more from Ms. Pilcher or anyone else. On or about October 18, 2004, Ms. Woodard submitted a letter to Regional Manager Daniel Graffeo, who according to the Defendant was Mr. Franklin’s immediate supervisor, complaining about Mr. Franklin’s unwelcome sexual jokes, advances and inappropriate touching. Ms. Woodard received no response to her complaint. On or about October 28, 2004, Ms. Woodard requested a transfer to another office.to get away from Franklin. No action was taken to address her written complaint nor her request for a transfer. Rather, as a result of her complaints, the Defendant terminated Ms. Woodard in November 2004 in retaliation for complaining about Franklin, who had a history of sexual harassment, but was considered a "good salesman." This interfered with Ms. Woodard’ s efforts to advance her EEO rights protected by Title VII.
8. The effects of the practices complained of in paragraph 7 above have been to deprive
Ms. Woodard of equal employment opportunities and to otherwise adversely affect her status as an
employee, because of sex and opposition to practices made unlawful under Title VII of the Civil
Rights Act of 1964, as amended.
9. The unlawful employment practices complained of in paragraph 7 above were
intentional.
10. The unlawful employment practices complained of in paragraph 7 were done with
malice or with reckless indifference to the federally protected rights of Ms. Woodard.

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 5 of 8
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in sexual harassment, retaliation, and any other employment practice which discriminate on the basis of sex and retaliation. B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for women and for employees who participate or oppose unlawful employment practices and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant Employer to make whole Ms. Woodard byproviding reinstatement, appropriate back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices including but not limited to compensatory and punitive damages. 13. Order Defendant Employer to make whole Ms. Woodard by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7, including but not limited to job search expenses in amounts to be determined at trial. E. Order Defendant Employer to make whole Ms. Woodard by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including emotional pain, suffering, inconvenience, loss of enjoyment of life and humiliation, in amounts to be determined at trial. F. Order Defendant Employer to pay Ms. Woodard punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 6 of 8
G. Grant such further relief as the Court deems necessary and proper in the public interest.
H. 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.
RONALD S. COOPER General Counsel
JAMES L. LEE Deputy General Counsel No Bar Roll Number Assigned
GWENDOLYN YOUNG REAMS Associate General Counsel No Bar Roll Number Assigned Equal Employment Opportunity Commission 1801 L Street, N.W. Washington, D.C. 20507
JIM SACHER Regional Attorney Bar Roll Number 14888
RUDY SUSTAITA Acting Supervisory Trial Attorney No Bar Roll Number Assigned Equal Employment Opportunity Commission Houston District Office 1919 Smith Street, 7th Floor Houston, Texas 77002
MICHELLE T. BUTLER (T.A.) Senior Trial Attorney Bar Roll Number 1286 Equal Employment Opportunity Commission New Orleans Field Office
6

Case 3:06-cv-01351-RGJ-KLH Document 3 Filed 09/21/2006 Page 7 of 8

Agent for Service: Tex R. Kilpatrick 1401 North 7th Street West Monroe, Louisiana 71291

1555 Poydras Avenue, Suite 1900 New Orleans, LA 70112 Tel.: (713) 209-3398 (Sacher)
(713) 209-3400 (Sustaita) (504) 595-2872 (Butler)(TA) Fax: (504) 595-2886
COUNSEL FOR PLAINTIFF, U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

7

 
 Case 3:06-cv-01351-RGJ-MLH Document 14 Filed 12/15/2006 Page 1 of 4

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA

MONROE DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

JUDGE: JAMES

VS. 06-1351

MAGISTRATE: HAYES

CENTRAL AMERICAN LIFE INSURANCE COMPANY

CORRECTIVE DOCUMENT ________________________________________________________________________

INTERVENOR COMPLAINT ________________________________________________________________________

The Intervenor Complaint of Rhonda Woodard, major resident and domiciliary of

Ouachita Parish, Louisiana, respectfully represents that:

1.

Made defendant herein is:

CENTRAL AMERICAN LIFE INSURANCE COMPANY, a licensed insurance company authorized to do and doing business in the State of Louisiana with its registered office at 1401 North Seventh Street, West Monroe, LA 71291.

2.

This cause arises under Title VII of the Civil Rights Act of 1964 as amended by

the Civil Rights Act of 1991. Thus, the court's jurisdiction is based upon a federal

question pursuant to 28 U. S.C. §1331.

Case 3:06-cv-01351-RGJ-MLH Document 14 Filed 12/15/2006 Page 2 of 4
3. Intervenor plaintiff was employed by the defendant as a secretary/cashier from July 3, 2002 until Novem ber 2004 when she was terminated. At all times pertinent, interven or plaintiff fully and properly performed all functions of her job.
4. While employed by defendant, intervenor plaintiff was sexually harassed by coworker Ron Franklin. The harassment included inappropriate sexual remarks, requests for dates and inappropriate touching. Intervenor plaintiff rejected any sexual advances by Ron F ranklin and reported the behavior to her immediate su pervisor, Donna Pilch er. Ms. Pilcher said she w ould discuss the matter with her supervisor, Beth Bostwick. Nothing was done by the defendant to correct the behavior or M r. Franklin. Mr. Franklin had a history of sexual harassment with defendant, but nothing was ever done to discipline M r. Franklin by defendant.
5. In October 2004, intervenor plaintiff submitted a written complaint to the Regional Manager Daniel Graffeo giving details of the sexual harassment by Ron Franklin. She received no reply to her written complaint and the sexually harassing behavior of Mr. Franklin continued toward intervenor plaintiff. On October 2, 2004, intervenor plaintiff requested a transfer to another office to get away from Mr. Franklin.

Case 3:06-cv-01351-RGJ-MLH Document 14 Filed 12/15/2006 Page 3 of 4
6. In November 2004, intervenor plaintiff was terminated in retaliation for filing a sexual harassment complaint about Mr. Franklin.
7. At all times pertinent, defendant employed more than fifteen (15) employees.
8. On or about November 23, 2004, a Charge of Discrimination was filed with the Equal Employment Opportunity Commission in New Orleans. On August 9, 2006, this cause was filed by the Equal Employment Opportunity Commission and contemporaneously with this Complaint, intervenor plaintiff files a Motion to Intervene.
9. Because of her dismissal from her position with defendant, intervenor plaintiff has suffered extreme emotional distress, pain and suffering. Intervenor plaintiff has also suffered loss of income as a result of the actions of defendant.
10. Interven or plaintiff desire s a trial by ju ry. WHEREFO RE, intervenor plaintiff prays that after due proceedings there be judgment in her favor and against defendant for a sum reasonable in the premises to compensate her for the emotional distress, pain and suffering and loss of income calculated to be the sum of $250,000.00; punitive damages in the sum of $100,000.00; all costs of these proceedings; a reasonable attorney s fee; legal interest from date of judicial

Case 3:06-cv-01351-RGJ-MLH Document 14 Filed 12/15/2006 Page 4 of 4
demand until paid; reinstatement to a position at whatever Central American Insurance Company location is appropriate and/or comparable to the one from which she was dismissed; and such other relief as the Court deems just and equitable.
S/J. Michael Rhymes J. Michael Rhymes #11212 Attorney at Law 401 Hudson Lane Monroe, LA 71201 (318) 388-4500 (telephone) (318) 361-0209 (facsimile) Attorney for Rhonda Woodard
CERTIFICATE OF SERVICE On December 13, 2006 the above and foregoing Intervenor Complaint was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to Harry Moffett, IV, Michelle T. Butler, Jim Sacher and Rudy Sustaita.
S/ J. MICHAEL RHYMES J. Michael Rhymes #11212

 
 Case 3:06-cv-01351-RGJ-MLH Document 33 Filed 12/19/2007

RECEIVED I N MONROE, LA

DEC 1 9 2007

IN THE UNITED STATES DISTRICT COURT

RD RT H. SHEMWELL CLERK FOR THE WESTERN DISTRICT OF LOmSIANA

W£S ERN DISTRICT OF L6uISIANA

MONROE DIVISION

Page 1 of 8

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
and
RHONDA WOODARD,
Plaintiff-Iritervenor,
v.
CENTRAL AMERICAN LIFE INS. CO.,
Defendant

)

)

)

)

)

CIVIL ACTION NO. 06 CV1351

)

)

)

JUDGE JAMES

)

)

)

MAG. JUDGE HORNSBY

)

)

)

)

CONSENT DECREE

On August 9, 2006, the Equal Employment Opportunity Commission ("the CommiBsion" or the "EEOC") filed a complaint instituting Civil Action Number 03:06cv:1351 in the United States District Court for the Western District of Louisiana, Monroe Division, which complaint was amended on September 21,2006, to correct the Defendant's name to Central American Life Insurance Company ("CALICO", "Defendant", or "Employer".) The EEOC alleged violations of Section 703(a) of Title VII of the Civil Rights Act of 1964 as amended, 42 U.S.C. § 2000e2(a) ("Title VU"), and alleged that the Defendant engaged in unlawful employment practices because of sexual harassment and a gender-based hostile work enviromnent perpetrated against Charging Party Rhonda J. Woodard (,'Woodard" or "the Intervener") and that the Defendant subsequently terminated Woodard on or about November 9, 2004, in retaliation for complaiuing
1

Case 3:06-cv-01351-RGJ-MLH Document 33 Filed 12/19/2007 Page 2 of 8
about the harassment. On December 15, 2006, Woodard filed a Complaint in Intervention incorporating all allegations of the Commission's Complaint.
CALICO denies the allegations of Plaintiff Equal Employment Opportunity Commission and Intervenor Rhonda Woodard. Specifically, CALICO alleges Mrs. Woodard was not subjected to a hostile and offensive work environment and was terminated for non-retaliatory reasons.
The Commission, the Defendant and the Intervenor now wish to resolve all claims and controversies encompassed by this lawsuit to avoid the burden, expense or delay of further litigation, subject, however, to the approval of this Court.
THEREFORE, IT IS HEREBY AGREED AMONG THE COMMISSION, THE DEFENDANT AND THE INTERVENOR, AND ORDERED, ADJUDGED, AND DECREED THAT:
JURISDICTION AND PROCEDURAL MATTERS 1. The parties agree this Court has jurisdiction over the subject matter of this lawsuit and over the parties to this lawsuit. 2. The parties agree the purposes of Title VII will be furthered by the entry of this Decree, the terms ofwhich constitute a fair and equitable resolution. 3. The parties agree the negotiation, execution and entry of this Decree will resolve any and all claims of the Title VII violations alleged by the Commission and Intervenor Rhonda J. Woodard against the Defendant arising out of Commission Charge Number 270-2005-00587 and this lawsuit, Civil Action Number 03:06cv1351.
2

Case 3:06-cv-01351-RGJ-MLH Document 33 Filed 12/19/2007 Page 3 of 8
4. CALICO has at all times denied any liability unto the EEOC or Mrs. Woodard and contends its employment practices at all times complied with all applicable laws. Payment to Mrs. Woodard by CALICO is made to avoid the expenses related to the defense of this lawsuit, and shall not be perceived as an admission of liability.
5. The parties agree that this Decree may not be used in any other proceeding to attempt to show a pattern of conduct attributable to CALICO.
INDIVIDUAL RELIEF 6. Within thirty (30) days after the entry of this Decree the Defendant shall pay the sum of THIRTY FNE THOUSAND DOLLARS ($35,000.00) to Rhonda J. Woodard for claims that were raised in Commission Charge Number 270-2005-00587 and this lawsnit. The Defendant shall provide contemporaneously to the EEOC's Trial Attorney Michelle T. Butler (hereafter "the EEOC's Designated Attorney") a copy of the payment to Rhonda J. Woodard. INJUNCTIVE RELIEF A. PERMANENT INJUNCTION 7. The Defendant shall continue to ensure that its employment practices adhere to the requirements of Title VIT. B. TITLE VII COMPLIANCE 8. The Defendant agrees to continue its employment practices aimed at complying with all requirements of Title VIT. Additionally, in furtherance of its Title VIT compliance obligations, the Defendant acknowledges it will continue its commitment to train its employees in accordance with paragraph 11 of this Decree. Further, Defendant agrees that it will not rehire Ron Franklin.
3

Case 3:06-cv-01351-RGJ-MLH Document 33 Filed 12/19/2007 Page 4 of 8
C. REPORTING 9. For the duration of this Decree the Defendant agrees to submit through Beth Bostwick and/or Defendant's attorney seroiaonual written reports to the EEOC's Designated Attorney. The initial report must be submitted within six (6) months after the entry of this Consent Decree or not later than May 1, 2008. Subsequent semiaonual reports must be submitted on the following dates: November 1, 2008; May 1, 2009; and November 1, 2009. These reports shall certify the Defendant's compliance with this Decree and further provide the following for each semiannual reporting period: (i) the identity by name, gender, social security number, last known address and last known telephone number of any employees who reported or complained about sexual harassment or gender-based hostile work environment within the prior six-month period, (ii) a description of the employee's complaint, (iii) a statement as to whether and how the Defendant responded to such report(s) or complaint(s), and (iv) a statement as to whether and how the report(s) were resolved. 10. During the term of this agreement, in the event any reports or complaints are made, the EEOC shall have access, upon advance notice of at least ten (10) days to the Defendant, to any written reports or complaints of sexual harassment and/or gender-based hostile work environment and to any investigative documents that are in the control or possession of Defendant and/or its owners, officers, managers, agents, employees, successors; and/or assigns, which the Commission deems necessary to examine in the process of evaluating the employee reports or complaints to determine whether a violation of Title VIT's prohibition against sexual harassment and gender-based hostile work environment has occurred. Further, the Defendant will maintain such reports and/or complaints for the term of this agreement. Af the
4

Case 3:06-cv-01351-RGJ-MLH Document 33 Filed 12/19/2007 Page 5 of 8
Commission's option, iliese reports shqll be mailed, faxed or sent to the Commission electronically at ilie Defendant's expense.
D. TITLE Vll TRAnITNG 11. The Defendant agrees to conduct, for the duration of iliis decree, an annual tbree-
hour training program about Title vn and ilie Defendant's anti-harassment and complaint-
reporting policy(ies) for its C.E.O. and all its supervisors, maoagers and employees. The initial training program shall be conducted wifuin four (4) monilis after the entry of this Decree. Each training pro gram aod trainer shall be reported to ilie Co=ission's Designated Attorney in accordance wiili the reporting requirements of this Decree. CALICO will notify its personnel of the program, which will be attended by CALICO personnel.
12. Each annual training program shall include the topics of unlawful sexual harassment, gender-based hostile work environment aod retaliation against employees in violation of Title VII, and an explanation of the Defendant's anti-harassment and complaint-
reporting policies. Anyone who does not attend the Title vn and policy training program, as
maodated by this Decree, shall be required to attend a make-up training program or view a videotape of ilie entire original training program wifuin one month of the missed program. The Defendant's initial and semiannual reports to the EEOC's Designated Attorney shall provide the
identity(ties) of the Title vn and compaoy policy trainer(s); all date(s) such training occurred;
the names and positions of everyone who attended ilie training aod make-up training or videotape programs; the signatures of all these same individuals acknowledging their presence at
such training programs; and a list of ilie topics covered during all such programs, or in lieu of a
topics list, a copy of the program outlines, materials or videotapes iliat were utilized during the
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training. E. POSTING l3. The Defendant agrees to continue to post conspicuously the Commission's poster
entitled: "Equal Employment Opportunity Is The Law" in prominent and accessible places in all of its facilities or buildings where its employees work and where said poster can be readily observed by the Defendant's employees and applicants for employment.
F. TITLE VII POLICY DISSEMINATION AND POSTING 14. The Defendant agrees to revise its Non-Harassment policy and post it in a conspicuous place as well as provide a copy to each current employee. Further, it shall continue its policy of providing a copy to each new employee at the time of hire. Defendant also agrees
that it shall send to the Commission a copy of its posted policy(ies) prohibiting harassment in
violation of Title VIT, which policy(ies) shall provide: (i) contact names, addresses and telephone numbers for complaining and reporting suspected work-place harassment to one designated official or employee of Defendant who shall be the ultimate point of contact for receiving and handling alleged harassment complaints beyond the employee's direct supervisor or other individual who may be the employee's first point of contact; (ii) a statement notifying employees that they are not obligated to report suspected harassment to any supervisor in their chain-of-command who is an alleged harasser or related by blood or marriage to an alleged harasser; (iii) a requirement that harassment complaints will be investigated promptly and confidentially and that responsive action and disciplinary measures will be taken to prevent and correct harassment; and (iv) a requirement that all of the Defendant's managers and supervisors shall promptly forward all complaints or repOlts about suspected work-place harassment to the
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designated company official or employee who will serve as the primary point of contact for handling such complaints or reports and who will ensure that Defendant promptly responds to such complaints by investigation and disciplinary or other corrective action. Such posted policy(ies) shall also clearly indicate to all employees that they should contact the designated company official or employee who is identified above for confidentially reporting suspected work-place harassment to someone other than their supervisor or a relative to their supervisor in the event their supervisor or hislher relative is the suspected harasser.
The Defendant further agrees to provide all its employees with convenient access to its anti-harassment and complaint-reportiog policy(ies) that comply with this Decree, including the contact names, addresses and telephone numbers for confidentially complaining and reporting suspected work-place harassmeut, by posting same in conspicuous work-place locations in all its facilities or buildings where its employees work. Additionally, the Defendant shall disseminate all its anti-harassment and complaint-reporting policy(ies) to all of its employees (including managers, supervisors, trainees, probationary and temporary employees, and all salaried and hourly-paid employees), obtain their written, dated ac1mowledgments of their receipt and understanding of such policy(ies), and maintain all written, dated aclmowledgments of such policies in its employees' personnel files. For the duration of this Decree, the Defendant shall certifY in its initial and all semiannual reports to the EEOC's Designated Attorney that it has posted and disseminated such policy(ies) in accordance with this paragraph. DURATION
15. This Consent Decree shall remain in force for two (2) years after the date of entry of this Decree.
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VALIDITY, ENFORCEMENT AND MISCELLANEOUS PROVISIONS

16. Should any provision of this Decree be declared or be deternlined by any Court to

be illegal or invalid, the validity of the remaining parts, terms and provisions shall not be

affected thereby, and said illegal or invalid part, term or provision shall be deemed not to be a

part of this Decree.

17. This Court shall retain jurisdiction over this action for the purpose of enforcing

this Decree, if necessary; and any party is empowered to enforce this Decree through the

applicable judicial enforcement procedures.

18. This Decree sets forth the entire agreement among the Commission, the

Defendant and Intervenor, which resolves Commission Charge Number 270-2005-00587 and

this lawsuit. This Decree fully supersedes any and all prior agreements or understandings among

the parties pertaining to Commission Charge Number 270-2005-00587 and this lawsuit. This

Decree cannot be altered by oral agreement among the parties, but only by written Court-ordered

modification.

19.

The Commission and Defendant, Central American Life Insurance Company

(CALICO), will each bear their own attorney's fees and costs incurred in connection with this

litigation. CALICO will reimburse Intervenor her court costs as incurred with the Clerk of

Court, and each party is responsible for its own attorney's fees.

IT IS SO ORDERED.

Momoe, Louisiana, tiris 19th day of December 2007.

ROBERT G. JAMES UNITED STATES DISTRICT JUDGE
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U.S. District Court Western District of Louisiana (Monroe) CIVIL DOCKET FOR CASE #: 3:06-cv-01351-RGJ-MLH

CLOSED

Equal Employment Opportunity Commission v. Kilpatrick Central Date Filed: 08/09/2006

American Life Insurance Co

Date Terminated: 11/05/2007

Assigned to: Judge Robert G James

Jury Demand: Both

Referred to: Magistrate Judge Mark L Hornsby

Nature of Suit: 442 Civil Rights: Jobs

Cause: 42:2000 Job Discrimination (Sex)

Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Michelle T Butler E E O C (NO) 1555 Poydras St Ste 1900 New Orleans, LA 70112 504-589-6817 Email: michelle.butler@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jim Sacher E E O C (HOU) 1919 Smith St Ste 700 Houston, TX 77002-8049 713-209-3398 ATTORNEY TO BE NOTICED

Rudy Sustaita E E O C (HOU) 1919 Smith St Ste 700 Houston, TX 77002-8049 713-209-3400 ATTORNEY TO BE NOTICED

V.
Defendant
Kilpatrick Central American Life Insurance Co TERMINATED: 09/21/2006 agent of Kilpatrick Funeral Homes TERMINATED: 09/21/2006

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Defendant Central American Life Insurance Co
Intervenor Plaintiff Rhonda Woodard
V. Intervenor Defendant Central American Life Insurance Co

https://ecf.lawd.uscourts.gov/cgi-bin/DktRpt.pl?241150967887383-L_9...
represented by Harry M Moffett, IV Hayes Harkey et al P O Box 8032 Monroe, LA 71211-8032 318-387-2422 Fax: 318-388-5809 Email: hal@hhsclaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
John B Saye Hayes Harkey et al P O Box 8032 Monroe, LA 71211-8032 318-387-2422 Fax: 318-388-5809 Email: john@hhsclaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by J Michael Rhymes 401 Hudson Ln Monroe, LA 71201 318-388-4500 Fax: 318-361-0209 Email: hrrhymes@comcast.net LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Harry M Moffett, IV (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
John B Saye (See above for address) ATTORNEY TO BE NOTICED

Date Filed 08/09/2006

# Docket Text
1 COMPLAINT against Kilpatrick Central American Life Insurance Co with Jury Demand, filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil cover sheet)(crt,Dean, S) (Entered: 08/11/2006)

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08/28/2006 09/21/2006 09/22/2006 11/20/2006 11/27/2006 11/27/2006
11/27/2006 11/28/2006
12/07/2006 12/07/2006
12/12/2006 12/13/2006 12/15/2006 12/15/2006

2 SUMMONS ISSUED as to Kilpatrick Central American Life Insurance Co. (crt,Dean, S) (Entered: 08/28/2006)
3 FIRST AMENDED COMPLAINT against Central American Life Insurance Co with Jury Demand, filed by Equal Employment Opportunity Commission.(crt,Dean, S) (Entered: 09/22/2006)
4 SUMMONS ISSUED as to Central American Life Insurance Co. (crt,Dean, S) (Entered: 09/22/2006)
5 SUMMONS Returned Executed by Equal Employment Opportunity Commission. Central American Life Insurance Co served on 11/7/2006, answer due 11/27/2006. (crt,Alexander, E) (Entered: 11/22/2006)
6 ANSWER to Amended Complaint with Jury Demand by Central American Life Insurance Co.(aty,Saye, John) (Entered: 11/27/2006)
7 MOTION to Intervene consent sought but not obtained by Rhonda Woodard. (Attachments: # 1 Text of proposed order)(aty,Rhymes, J) Modified on 11/28/2006 to reflect submission as Deficient (Williams, L). Modified on 12/14/2006 to remove deficiency notation(s)(Williams, L). (Entered: 11/27/2006)
CASE Reassigned to Judge Mark L Hornsby as referral judge. Judge Karen L Hayes no longer assigned to the case. (crt,Williams, L) (Entered: 11/29/2006)
8 NOTICE of Deficiency to J Michael Rhymes on behalf of Rhonda Woodard regarding 7 DEFICIENT? MOTION to Intervene consent sought but not obtained. Reason: A motion for leave to file (motion to intervene) must be accompanied by the proposed pleading (i.e. Petition for Intervention). (crt,Williams, L) (Entered: 11/28/2006)
9 MOTION for Leave to File Complaint objection by Rhonda Woodard. (Attachments: # 1 Text of proposed order)(aty,Rhymes, J) (Entered: 12/07/2006)
CORRECTIVE DOCUMENT entitled Motion for Leave to File Complaint filed by Rhonda Woodard. ADMINISTRATIVE ENTRY as pleading was electronically filed in error as 9 Motion for Leave to File Complaint. Corrective Document (Motion for Leave to File Complaint) DOES NOT satisfy the Notice of Defiency issued on 11/28/06. (crt,Williams, L) (Entered: 12/11/2006)
10 NOTICE of Appearance by Harry M Moffett, IV on behalf of Central American Life Insurance Co (aty,Moffett, Harry) (Entered: 12/12/2006)
11 CORRECTIVE DOCUMENT entitled Intervenor Complaint filed by Rhonda Woodard regarding 7 MOTION to Intervene consent sought but not obtained. (aty,Rhymes, J) (Entered: 12/13/2006)
12 CORPORATE DISCLOSURE STATEMENT by Central American Life Insurance Co identifying Kilpatrick Enterprises, Inc. as Corporate Parent. (aty,Moffett, Harry) (Entered: 12/15/2006)
13 ORDER granting 7 Motion to Intervene. Signed by Judge Mark L Hornsby on 12/15/06. (crt,Alexander, E) (Entered: 12/15/2006)

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12/15/2006 12/22/2006 01/04/2007 02/15/2007 02/26/2007
07/09/2007 07/12/2007 07/26/2007
07/30/2007
08/01/2007

14 INTERVENOR COMPLAINT against Central American Life Insurance Co filed by Rhonda Woodard.(crt,Alexander, E) (Entered: 12/15/2006)
15 ANSWER to Intervenor Complaint by Central American Life Insurance Co.(aty,Moffett, Harry) (Entered: 12/22/2006)
16 CIVIL CASE MANAGEMENT ORDER for cases assigned to Judge Robert G James sent to pending counsel of record. Signed by Judge Robert G James on 01/04/07. (crt,Williams, L) (Entered: 01/04/2007)
17 RULE 26(f) Report. (aty,Moffett, Harry) (Entered: 02/15/2007)
18 SCHEDULING ORDER: Jury Trial set for 12/10/2007 at 9:00 AM in Monroe, 2nd floor before Judge Robert G James. Pretrial Conference set for 11/8/2007 at 10:30 AM before Magistrate Judge Mark L Hornsby. Pretrial Order due by 11/5/2007. Joinder of Parties and Amendment of Pleadings due by 4/27/2007. Plaintiffs Witness List due by 5/29/2007. Defendants Witness List due by 6/6/2007. Plaintiffs Expert Info/Reports due by 6/26/2007. Defendants Expert Info/Reports due by 7/26/2007. Discovery due by 6/26/2007. Discovery II due by 7/26/2007. Dispositive Motions due by 8/10/2007. Expert Depositions due by 9/19/2007. Conference/Meeting of counsel to prepare pretrial order to be held by 10/16/2007. Motions in Limine due by 10/19/2007. Trial Brief/Pretrial Submissions due by 11/30/2007. Signed by Judge Robert G James on 2/26/07. (crt,Dickerson, D) (Entered: 02/26/2007)
19 Joint MOTION for Extension of Time to Complete Discovery With consent by Central American Life Insurance Co. (Attachments: # 1 Text of proposed order)(aty,Moffett, Harry) (Entered: 07/09/2007)
20 ORDER granting 19 Joint Motion for Extension of Time to Complete Discovery. Discovery due by 8/26/2007. Signed by Magistrate Judge Mark L Hornsby on 7/12/07. (crt,Alexander, E) (Entered: 07/12/2007)
21 DEFICIENT? MOTION to Compel answers to interrogatories and responses to request for production from intervenor, Rhonda Woodard, MOTION FOR EXTENSION of deadline to file motion to compel consent sought but not obtained by Central American Life Insurance Co. (aty,Moffett, Harry) Modified on 7/30/2007 to reflect submission as Deficient and to indicate that Memorandum in Support is included within pdf of Main Document(Williams, L). (Entered: 07/26/2007)
22 NOTICE of Deficiency to Harry M Moffett, IV on behalf of Central American Life Insurance Co regarding 21 DEFICIENT? MOTION to Compel answers to interrogatories and responses to request for production from intervenor, Rhonda Woodard MOTION FOR EXTENSION of deadline to file motion to compel consent sought but not obtained. Reason: (1) This motion to compel discovery does not include the requests or responses that are the subject of this motion. (2) You do not indicate whether opposing counsel consent to the granting of this ex parte motion. (crt,Williams, L) (Entered: 07/30/2007)
23 MOTION to Withdraw 21 First MOTION to Compel answers to interrogatories and responses to request for production from intervenor, Rhonda WoodardFirst MOTION FOR EXTENSION of deadline to file motion to compel consent sought

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08/03/2007
10/19/2007 10/19/2007 11/02/2007 11/02/2007 11/05/2007 11/05/2007
11/05/2007 12/14/2007 12/14/2007

but not obtainedFirst MOTION FOR EXTENSION of deadline to file motion to compel consent sought but not obtained by Central American Life Insurance Co. (Attachments: # 1 Text of proposed order)(aty,Moffett, Harry) (Entered: 08/01/2007)
24 ORDER granting 23 Motion to Withdraw 21 First MOTION to Compel answers to interrogatories and responses to request for production from intervenor, Rhonda WoodardFirst MOTION FOR EXTENSION of deadline to file motion to compel consent sought but not obtained. Signed by Judge Mark L Hornsby on 08/03/07. (crt,Williams, L) (Entered: 08/03/2007)
25 MOTION in Limine by Central American Life Insurance Co. (Attachments: # 1 Memorandum / Brief # 2 Exhibits # 3 Exhibits # 4 Proposed pleading)(aty,Moffett, Harry) (Entered: 10/19/2007)
26 NOTICE of Motion Referred to Chambers to be considered at trial regarding 25 MOTION in Limine. (crt,Williams, L) (Entered: 10/19/2007)
27 MEMORANDUM in Opposition re 25 MOTION in Limine filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibits)(crt,Alexander, E) (Entered: 11/02/2007)
28 NOTICE of Privacy and Public Access directed to Michelle T Butler on behalf of Equal Employment Opportunity Commission regarding 27 Memorandum in Opposition to Motion in Limine filed in noncompliance with E-Government Act of 2002. (crt,Alexander, E) (Entered: 11/02/2007)
29 LETTER from Michelle T Butler to Honorable Robert James requesting a ninety day order of dismissal. (crt,Yocum, M) (Entered: 11/05/2007)
30 ELECTRONIC 60 DAY ORDER DISMISSING CASE: The Court having been advised by counsel that the above civil action has been settled, IT IS HEREBY ORDERED that the Clerk of Court administratively terminate this action without prejudice to the right of the parties to reopen the proceedings. All pending motions are denied as moot. IT IS FURTHER ORDERED that within 60 days of the date of this Order, the parties submit to the Court a Joint Stipulation of Dismissal signed by all parties who have appeared in this action, along with a proposed Judgment of Dismissal. Signed by Judge Robert G James on 11/05/07. (crt,Floyd, J) (Entered: 11/05/2007)
ORDER for Administrative Closure as instructed in the Electronic 60 Day Order Dismissing Case. Signed by Judge Robert G James on 11/5/07. (crt,Dickerson, D) (Entered: 11/08/2007)
31 Joint MOTION for Consent Judgment and Dismiss Action by Central American Life Insurance Co, Rhonda Woodard, Equal Employment Opportunity Commission. (Attachments: # 1 Proposed pleading Consent Decree, # 2 Proposed pleading Order)(aty,Moffett, Harry) (Entered: 12/14/2007)
31 JOINT/VOLUNTARY MOTION to Dismiss by Central American Life Insurance Co, Rhonda Woodard, Equal Employment Opportunity Commission. ADMINISTRATIVE ENTRY as 31 Joint Motion for Consent Judgment electronically filed without selecting all reliefs requested in pleading. (crt,Alexander, E) (Entered: 12/18/2007)

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12/19/2007 12/19/2007

32 ORDER granting 31 Motion for Consent Judgment. Signed by Judge Robert G James on 12/19/07. (crt,Dickerson, D) (Entered: 12/19/2007)
33 CONSENT DECREE. Signed by Judge Robert G James on 12/19/07. (crt,Dickerson, D) (Entered: 12/19/2007)

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