UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

5 : 05 CV 0 13 9

Plaintiff, vs.

Case No. Honorable

RObert Holmes Bell Chief, U.S. District JUdge

CROWN PLAZA HOTEL

COMPLAINT AND JURY DEMAND

Defendant. ___________________________________1

NATURE OF THE ACTION This is an action brought under Title VII of the Civil Rights Act of 1964 to correct unlawful employment practices and to provide appropriate relief to Carlos Suarez ("Suarez") and similarly situated employees who were adversely affected by such practices. The Equal Employment Opportunity Commission ("The Commission"), alleges that Crown Plaza Hotel ("Defendant"), discriminated against Suarez and other similarly situated individuals, when it permitted them to be harassed and subjected to a hostile work environment because of their national origin. The Commission further alleges that the Defendant failed to take prompt, effective, remedial action to stop the harassment and correct the hostile work environment.
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 Sections
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706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, and 42 U.S.C. 2000e-5(f)(1) and (3).
2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court forthe Western District of Michigan, Southern Division.
PARTIES 3. Plaintiff, 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(f)(1) and (3) of Title VII, 42 U.S.C. §§ 2000e5(f)(1) and (3). 4. At all relevant times, Defendant Crown Plaza Hotel, has continually been a corporation doing business in the state of Michigan and the city of Grand Rapids, and has continuously had in excess of fifteen (15) employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701 (b), (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g), and (h).
STATEMENT OF CLAIMS 6. More than sixty (60) days prior to the institution of this lawsuit, Carlos Suarez filed a charge of discrimination with The Commission alleging a violation of Title VII. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least April 2003, Defendant engaged in unlawful employment practices in violation of Title VII, when it permitted Suarez and other similarly situated
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individuals to be harassed and subjected to a hostile work environment because of their national origin. The harassment included the following incidents:
a). Verbal abuse towards Suarez and other Mexicans with references to national origin including being called a dumb Mexican too stupid to do the job, a stupid Mexican and a lazy Mexican; b). Reduction of Suarez' work hours from full time to twelve hours per week; c). Forcing Suarez to perform tasks that were impossible to complete in the allotted time; d). Forcing Suarez to work overtime for which he was not paid; and e). Discharging Suarez' employment because of his national origin. 8. The effect of the conduct complained of in Paragraph 7, above, has been to deprive Suarez and other similarly situated individuals of equal employment opportunities and otherwise adversely affect their status as employees because of their national origin. 9. The unlawful conduct complained of in Paragraph 7, above, was intentional. 10. As a result of the unlawful employment practices complained of above, Suarez and other similarly situated individuals have suffered from emotional pain, suffering, inconvenience, mental anguish and loss of enjoyment of life. 11. The unlawful employment practices complained of above were and are done with malice or reckless indifference to the federally protected rights of Suarez and other similarly situated individuals.
PRAYER FOR RELIEF 3

Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in harassment and any other employment practice which discriminates based on national origin; B. Order Defendant to institute and carry out policies, practices and programs which provide equal employment opportunities for Mexicans, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant to make whole Suarez by providing 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; D. Order Defendant to make whole Suarez and other similarly situated individuals by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in Paragraph 7 above in amounts to be proven at trial; E. Order Defendant to make whole Suarez and other similarly situated individuals by providing compensation for past and future nonpecuniary losses resulting from the unlawful employment practices described in Paragraph 7 above in amounts to be proven at trial; F. Order Defendant to pay punitive damages for its malicious and reckless conduct, as described in Paragraph 7 above, in amounts to be proven at trial; G. Grant such further relief as the Court deems necessary and proper in the 4

public interest; J. Award the Commission its cost of this action.
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint.

Dated: September 30, 2005

Respectfully submitted,
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Acting Deputy General Counsel
OFFICE OF GENERAL COUNSEL Trial Services Division 1801 "L" Street, N.W. Washington, D.C. 20507
ROBERT K. DAWKINS (P38289) Supervisory Trial Attorney
OMAR WEAVER (P588861) Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION DETROIT DISTRICT OFFICE Patrick V. McNamara Bldg. 477 Michigan Avenue, Rm. 865 Detroit, Michigan 48226 Telephone: 313/226-5673
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 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,

Case No. 5:05-CV-139

v.

Hon. Robert Holmes Bell

CROWN PLAZA HOTEL,

Defendant.
----------------------~/
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION LAURIE A. YOUNG DEBORAH M. BARNO (P44525) OMAR WEAVER (P-58861) Attorneys for Plaintiff Patrick V. McNamara Building 477 Michigan Ave., Room 865 Detroit, MI 48226 (313) 226-3407

BALLARD ROSENBERG GOLPER & SAVITT, LLP RlCHARD S. ROSENBERG KATHERINE A. HREN Attorneys for Defendant 10 Universal City Plaza, 16'h Floor Universal City, CA 91608- 1097 (818) 508-3700
----------------------------~/
CONSENT DECREE

This action was commenced by the Equal Employment Opportunity Commission

("EEOC"), under the authority granted to it under Section 706(f)(l) of Title VII ofthe Civil Rights

Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(l). The EEOC's action was brought to correct

338707.4

alleged unlawful employment practices on the basis of national origin. The EEOC alleged in its Complaint that Crowne Plaza Hotel (erroneously sued as Crown Plaza Hotel) permitted Carlos Suarez and a class ofMexican employees to be harassed and subjected to a hostile work environment because of their Mexican national origin. Crowne Plaza Hotel denies these and the allegations set forth in the Complaint and further denies engaging in any wrongdoing whatsoever against Carlos Suarez and/or the class of Mexican employees.
As a result of settlement discussions, the EEOC and Crowne Plaza Hotel/Sunstone Hotel Properties, Inc. have resolved their differences and have agreed that this action should be settled by entry of this Consent Decree. It is the intent of the parties that this Consent Decree be a final and binding settlement in full disposition of any and all claims alleged against Crowne Plaza Hotel or which might have been alleged against Crowne Plaza Hotel in the Complaint filed by EEOC on behalf of Charging Party Carlos Suarez and the other Mexican class members.
It is therefore the finding ofthis Court, made on the pleadings and the record as a whole, that: 1) the Court has jurisdiction over the parties and the subject matter ofthis action; 2) the purpose and provisions ofTitle VII will be promoted and effectuated by the entry ofthis Consent Decree; and 3) this Consent Decree resolves all matters in controversybetween the parties as provided in paragraphs 1 through 14 below.
MONETARY RELIEF 1. Crowne Plaza Hotel agrees to pay monetary relief to Carlos Suarez in the gross amount of
Twenty-Thousand Dollars ($20,000.00). Crowne Plaza Hotel shall issue a 1099 form for this amount in the ordinary course ofbusiness. Suarez's funds shall be paid in one lump sum and mailed via certified mail to his home address. Payment shall be made within fourteen (14)
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days after the Court has entered this Decree. A copy of the check shall be sent to Laurie Young, Regional Attorney, care of Omar Weaver, Trial Attorney, EEOC, 477 Michigan Avenue, Room 865, Detroit, Michigan 48226, within fourteen (14) days of issuance ofthe check. 2. In addition, Crowne Plaza Hotel agrees to pay monetary relief to another class member as follows: Nine-Thousand Dollars ($9,000) to Marcelina Gomez. Crowne Plaza Hotel shall issue a 1099 form for this amount in the ordinary course of business. Ms. Gomez's funds shall be paid in one lump sum and sent via certified mail to her home address. Payment shall be made within fourteen (14) days after the Court has entered this Decree. A copy of the check shall be sent to Laurie A. Young, Regional Attorney, care of Omar Weaver, Trial Attorney, EEOC, 477 Michigan Avenue, Room 865, Detroit, Michigan 48226, within fourteen (14) days of issuance of the check. 3. Crowne Plaza Hotel also agrees to make a contribution to a 50l(c)(03) non-profit charitable organization of its choice, which benefits immigrant rights, in the amount of TwentyThousand Dollars ($20,000). The amount shall be paid in one lump sum and the check shall be sent via certified mail directly to the organization, within fourteen (14) days after the Court has entered this Decree. A copy of the check shall be sent to Laurie A. Young Regional Attorney, care of Omar Weaver, Trial Attorney, EEOC, 477 Michigan Avenue, Room 865, Detroit, Michigan 48226, within fourteen (14) days of issuance of the check.
REPORTING 4. During the term ofthis Decree, Crowne Plaza Hotel agrees to provide the EEOC with semi-
annual reports ofany official complaints ofdiscrimination, harassment or intimidation based
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on Mexican national origin which are reported to management pursuant to the Crowne Plaza Hotel's Anti-Harassment/Anti-Discrimination Policy. For each such reported complaint, Crowne Plaza Hotel must set forth any remedial action that was taken. Crowne PlazaHotel shall provide the EEOC with the name, ofthe alleged victim, the alleged harasser, and the members of management responsible for handling the complaint. All such reports shall be sent to Laurie Young, Regional Attorney, care ofOmar Weaver, Trial Attorney, EEOC, 477 Michigan Avenue, Room 865, Detroit, Michigan 48226, by the fifteenth day of January for all complaints made between July 1 and December 31 of the preceding year and by the fifteenth day of July for all complaints made between January 1 and June 30 of that year. Crowne Plaza Hotel will send the first of such semi-annual reports by January 15, 2007.
NON-DISCRIMINATION 5. Crowne Plaza Hotel shall endeavor to comply with Title VII's requirements to provide a
work environment free from unlawful discrimination, harassment and intimidation. NON-RETALIATION
6. Crowne Plaza Hotel shall not knowingly and intentionally take any action against any employee of the Hotel which constitutes illegal retaliation or interference with the exercise ofsuch person's rights under Title VII because such person files a charge of discrimination with the EEOC or because such person gave testimony or assistance or participated in any manner in the investigation or proceedings in connection with this case. TRAINING
7. Crowne Plaza Hotel agrees to provide training to its managers and supervisors on Title VII ofthe Civil Rights Act of 1964, as amended and its prohibitions against discrimination and
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harassment. The training shall include a discussion of what behavior constitutes "hostile work environment" harassment and what should be done when an individual believes that he/she has been subjected to such harassment. The training shall also include a discussion ofthe provisions ofCrowne Plaza Hotel's Anti-Harassment/Anti-Discrimination policy. An attendance list of each individual who completed the training shall be sent to Laurie Young, Regional Attorney, care of Omar Weaver, Trial Attorney, EEOC, 477 Michigan Avenue, Room 865, Detroit, Michigan 48226, within fifteen (15) days of the completion of the training. Crowne Plaza Hotel will provide such training twice a year, throughout the term ofthis Decree, with the first session occurring within six (6) months ofentry ofthis Decree. For all managers and supervisors hired after the initial training session, Crowne Plaza Hotel will include such individuals in the next scheduled session. All newly promoted managers and supervisors will be scheduled to attend one of the Crowne Plaza Hotel's twice yearly training sessions described above. The training for new employees shall include an overview of Crowne Plaza Hotel's Anti-Harassment/Anti-Discrimination policy and its complaint procedures.
POSTING OF NOTICE 8. Crowne Plaza Hotel agrees to post the Notice attached as Appendix A in a conspicuous place
which sets forth an employee's rights regarding the federal anti-discrimination laws. This Notice shall be posted, throughout the term of this Decree. Should the Notice become defaced, marred or otherwise made unreadable, Crowne Plaza agrees to post a readable copy of this Notice in the same manner as soon as practical thereafter.
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DURATION 9. The provisions ofthis Consent Decree shall remain in full force and effect for two (2) years
upon entry of the Decree. DISPUTE RESOLUTION AND COMPLIANCE
10. The Court shall retain jurisdiction and will have all available equitable powers, including injunctive relief, to enforce this Decree. Upon motion of either party, the Court may schedule a hearing for the purpose of reviewing compliance with this Decree. The parties shall engage in a good faith effort to resolve any dispute as to compliance prior to seeking review by the Court, and shall be required to provide written notice to each other no less than ten business (10) days before moving for such review. All parties may conduct discovery under the Federal Rules ofCivil Procedure for purposes ofdetermining compliance with this Decree or defending against a claim ofnon-compliance. MISCELLANEOUS
11. Each party will bear its own costs and fees. 12. If any provision of this Decree is found to be unenforceable by a Court, only the specific
provision in question shail be affected and the other enforceable provisions shall remain in full force. 13. This Decree constitutes the entire agreement and commitments of the Parties. Any modifications to this Decree must be mutually agreed upon in writing and signed by the Parties.
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14. The terms of this Consent Decree are, and shall be binding upon, the present and future owners, officers, directors, employees, creditors, agents, trustees, administrators, successors, representatives, and assigns of Crowne Plaza Hotel.

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
MWEAvER
Trial Attorney

CROWNE PLAZA HOTEL
By: BALLARD ROSENBERG GOLPER & SAVITT, L.L.P.
~IC~~§Si;:
KATHERINE A. HREN Attorneys for Defendant 10 Universal City Plaza, l61h Floor Universal City, CA 91608-1097 (818) 508-3700

DEBORAH M. BARNO (P44525) Supervisory Trial Attorney
OMAR WEAVER (P58861) Trial Attorney DETROIT DISTRICT OFFICE Patrick V. McNamara Federal Building 477 Michigan Ave, Room 865 Detroit, Michigan 48226 (313) 226-3407
Dated: 7 ~ 0

IT IS SO ORDERED: July 31, 2006 Date
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/s/ Robert Holmes Bell
Hon. Robert Holmes Bell United States District Judge
,
I

APPENDIX A NOTICE
This Notice is being posted to inform you ofyour rights guaranteed by the federal law under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e, et seq. ("Title VII").
Title VII prohibits discrimination and harassment in the workplace. The Equal Employment Opportunity Commission is the federal agency which investigates charges ofunlawful employment discrimination and, if necessary, brings lawsuits in federal court to enforce the employment provisions ofTitle Vll. Any employee who believes that he/she is the victim of discrimination or harassment has the legal right to file a charge of discrimination with the U.S. Equal Employment Opportunity Commission.
Crowne Plaza supports and will comply with this federal law in all respects and will not take any adverse action against any employees because they have exercised their rights under this law.
c~
Dated
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 United States District Court for the Western District of Michigan - Dock... https://ecf.miwd.uscourts.gov/cgi-bin/DktRpt.pl?962459977165059-L_...

United States District Court Western District of Michigan (Southern Division (5)) CIVIL DOCKET FOR CASE #: 5:05-cv-00139-RHB

CLOSED, VFM

Equal Employment Opportunity Commission v. Crown Plaza Hotel Assigned to: Chief Judge Robert Holmes Bell Cause: 28:451 Employment Discrimination

Date Filed: 09/30/2005 Date Terminated: 07/31/2006 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

plaintiff
Equal Employment Opportunity Commission

represented by Adele Rapport U.S. Equal Employment Opportunity Commission (MI) 865 Patrick V. McNamara Bldg. 477 Michigan Ave. Detroit, MI 48226 (313) 226-6701 Email: adele.rapport@eeoc.gov TERMINATED: 06/07/2006 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Omar Weaver U.S. Equal Employment Opportunity Commission (MI) 865 Patrick V. McNamara Bldg. 477 Michigan Ave. Detroit, MI 48226 (313) 226-3407 Email: omar.weaver@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. defendant Crown Plaza Hotel

represented by Frederic E. Champnella, II Keller Thoma PC 440 E Congress, 5th Fl. Detroit, MI 48226-2918 (313) 965-7610 Email: fec@kellerthoma.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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mediator Facilitative Mediator

Susan Diane Koval Keller Thoma PC 440 E Congress, 5th Fl. Detroit, MI 48226-2918 (313) 965-7610 Email: sdk@kellerthoma.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Katherine Anica Hren Ballard Rosenberg Golper & Savitt, LLP 10 Universal City Plaza, 16th Floor Universal City, CA 91608 (818) 508-3700 Email: khren@brgslaw.com ATTORNEY TO BE NOTICED
Richard S. Rosenberg Ballard Rosenberg Golper & Savitt, LLP 10 Universal City Plaza, 16th Floor Universal City, CA 91608 (818) 508-3700 Email: rrosenberg@brgslaw.com ATTORNEY TO BE NOTICED
represented by Jon G. March Miller Johnson PLC (Grand Rapids) 250 Monroe Ave., NW, Ste. 800 P.O. Box 306 Grand Rapids, MI 49501-0306 (616) 831-1729 Fax: (616) 988-1729 Email: marchj@millerjohnson.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Lawrence J. Murphy Varnum Riddering Schmidt & Howlett LLP (Kalamazoo) 251 N Rose St., 4th Fl. Kalamazoo, MI 49007 (269) 553-3511 Fax: (269) 382-2382 Email: ljmurphy@varnumlaw.com TERMINATED: 04/21/2006 LEAD ATTORNEY

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Date Filed 09/30/2005 09/30/2005 10/31/2005 12/07/2005 12/07/2005 12/07/2005 12/08/2005 01/06/2006 01/10/2006
02/06/2006 02/09/2006 02/13/2006
02/23/2006 03/01/2006

#

Docket Text

1 COMPLAINT and Jury Demand against Crown Plaza Hotel filed by Equal Employment Opportunity Commission (Attachments: # 1 Civil Cover Sheet) (jlg, ) (Entered: 09/30/2005)
SUMMONS ISSUED as to Crown Plaza Hotel (jlg, ) (Entered: 09/30/2005)
2 ATTORNEY APPEARANCE of Omar Weaver on behalf of plaintiff Equal Employment Opportunity Commission (Weaver, Omar) (Entered: 10/31/2005)
3 ATTORNEY APPEARANCE of Frederic E. Champnella, II on behalf of defendant Crown Plaza Hotel with proof of service (Champnella, Frederic) Modified on 12/8/2005 to add text (gjf). (Entered: 12/07/2005)
4 ATTORNEY APPEARANCE of Susan Diane Koval on behalf of defendant Crown Plaza Hotel with proof of service (Koval, Susan) Modified on 12/8/2005 to add text (gjf). (Entered: 12/07/2005)
5 STIPULATION to Continue Defendant's Deadline to Respond to the Complaint (until January 6, 2006) with proof of service by defendant Crown Plaza Hotel (Koval, Susan) Modified on 12/8/2005 to add text (gjf). (Entered: 12/07/2005)
6 ORDER granting STIPULATION 5 to continue Defendant's deadline to respond to the complaint; signed by Chief Judge Robert Holmes Bell (Chief Judge Robert Holmes Bell, ymc) (Entered: 12/08/2005)
7 ANSWER to complaint with Affirmative Defenses and proof of service by Crown Plaza Hotel (Koval, Susan) Modified on 1/9/2006 to add text (gjf). (Entered: 01/06/2006)
8 ORDER setting Rule 16 scheduling conference: Rule 16 scheduling conference is set for 2/9/2006 at 1:30 PM at 699 Federal Building, Grand Rapids, MI before Magistrate Judge Joseph G. Scoville; status report due by 2/6/2006; signed by Chief Judge Robert Holmes Bell (Chief Judge Robert Holmes Bell, sdb) (Entered: 01/10/2006)
9 JOINT STATUS REPORT (Koval, Susan) (Entered: 02/06/2006)
10 MINUTES of Rule 16 scheduling conference held before Magistrate Judge Joseph G. Scoville; Case management Order to issue; (Proceedings Digitally Recorded) (Magistrate Judge Joseph G. Scoville, dmh) (Entered: 02/09/2006)
11 CASE MANAGEMENT ORDER: jury trial set for 5/14/2007 at 9:00 AM at 601 Federal Building, Grand Rapids, MI before Chief Judge Robert Holmes Bell; final pretrial conference set for 5/3/2007 at 1:00 PM at 601 Federal Building, Grand Rapids, MI before Chief Judge Robert Holmes Bell; signed by Magistrate Judge Joseph G. Scoville (Magistrate Judge Joseph G. Scoville, sdb) (Entered: 02/13/2006)
12 SELECTION of Lawrence J. Murphy as facilitative mediator by defendant Crown Plaza Hotel (Koval, Susan) (Entered: 02/23/2006)
13 NOTICE of appointment of Facilitative Mediator Lawrence J. Murphy; plaintiff VFM fee to be submitted by 3/13/2006; defendant VFM fee to be submitted by

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03/17/2006
03/27/2006 04/14/2006 04/21/2006 04/21/2006 04/26/2006 05/04/2006 06/07/2006 07/25/2006 07/31/2006

3/13/2006 (ADR Administrator, mjs) (Entered: 03/01/2006)
14 NOTICE regarding VFM fees that were due 3/13/06 pursuant to Notice of Appointment of Facilitative Mediator 13; plaintiff VFM fee to be submitted by 3/27/2006; defendant VFM fee to be submitted by 3/27/2006 (ADR Administrator, mjs) (Entered: 03/17/2006)
VFM FEE RECEIVED in the amount of $25.00, check number 42081 as to defendant Crown Plaza Hotel (ADR Administrator, mjs) (Entered: 03/27/2006)
15 NOTICE regarding VFM fees that were due March 13, 2006 pursuant to Notice of Appointment of Facilitative Mediator 13; plaintiff's VFM fee to be submitted by 4/24/2006 (ADR Administrator, mjs) (Entered: 04/14/2006)
16 SELECTION of Jon G. March as facilitative mediator by defendant Crown Plaza Hotel (Hren, Katherine) (Entered: 04/21/2006)
17 ATTORNEY APPEARANCE of Katherine Anica Hren on behalf of defendant Crown Plaza Hotel (Hren, Katherine) (Entered: 04/21/2006)
18 ATTORNEY APPEARANCE of Richard S. Rosenberg on behalf of defendant Crown Plaza Hotel (Rosenberg, Richard) (Entered: 04/26/2006)
VFM FEE RECEIVED in the amount of $25.00, check number 410 as to plaintiff Equal Employment Opportunity Commission (ADR Administrator, mjs) (Entered: 05/04/2006)
19 NOTICE of withdrawal of Counsel by plaintiff Equal Employment Opportunity Commission (Rapport, Adele) (Entered: 06/07/2006)
20 PROPOSED CONSENT DECREE by plaintiff Equal Employment Opportunity Commission (Weaver, Omar) (Entered: 07/25/2006)
21 ORDER granting consent decree 20; signed by Chief Judge Robert Holmes Bell (Chief Judge Robert Holmes Bell, ymc) (Entered: 07/31/2006)

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