EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

Plaintiff,

)
) crtIV -02 - 0354 JP LFll
)

v.

)

)

COMPLAINT

KEY ENERGY SERVICES, INC.,

)

)

JURY TRIAL DEMANDED

Defendant.

)

)

NATURE OF THE ACTION

This is an action under the Equal Pay Act of 1963, Title VII of the Civil Rights Act of

1964, and Title I ofthe Civil Rights Act of 1991, to restrain the unlawful payment of wages to an

employee of one sex at rates less than the rates paid to at least one employee of the opposite sex,

to correct unlawful employment practices on the bases of sex and retaliation, and to provide

appropriate relief due to Rickisue Daly as a result of such unlawful practices. The Commission

alleges that, because of her sex, female, Ms. Daly was and is paid lower wages than at least one

male employee who performed substantially equal work under similar working couditions. The

Commission also alleges that Ms. Daly was discriminated against in her wages, terms, conditions

and privileges of employment because of her sex, female, and was subjected to retaliation after

she complained about wage and gender discrimination.

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 16 (c) and 17 of the Fair Labor Standards Act of 1938 (the "FLSA"), as amended, 29 U.S.C.§§ 216 (c) and 217, to enforce the requirements of the Equal Pay Act of 1963 ("EPA"), codified as Section 6 (d) of the FLSA, 29 U.S.C. § 206 (d), and pursuant to Sections 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(1) and (3) ("Title VII"). This action is also authorized and instituted pursuant to Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.
2. The employment practices alleged to be unlawful were and are now being committed within the jurisdiction of the United States District Court for the District of New Mexico.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is an agency of the United States of America charged with the administration, interpretation and enforcement of the Equal Pay Act and Title VII, and is expressly authorized to bring this action by Sections 16 (c) and 17 of the FLSA, 29 U.S.C. §§ 216(c) and 217, as amended by Section 1 of Reorganization Plan No.1 of 1978,92 Stat. 3781, and by Public Law 98-532 (1984), 98 Stat. 2705; and by Section 706(f)(1) and (3) of Title VII, 42 U.S.c. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant Key Energy Services, Inc., ("Defendant Employer") has continuously been a Maryland Corporation doing business in the State of New Mexico and the City of Farmington, and has continuously had at least fifteen employees. 5. At all relevant times, Defendant Employer has continuously been and is now an employer engaged in an industry affecting commerce within the meaning of Section 701(b), (g)
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and (h) of Title VII, 42 U.S.C. § 2000e-(b), (g) and (h). 6. At all relevant times, Defendant Employer has acted directly or indirectly as an
employer in relation to employees and has continuously been an employer within the meaning of Section 3(d) of the FLSA, 29 U.S.c. § 203 (d).
7. At all relevant times, Defendant Employer has continuously employed employees engaged in commerce or in the production of goods for commerce within the meaning of Sections 3 (b), (i) and (j) of the FLSA, 29 U.S.C. §§ 203(b), (i) and (j) and has continuously been an enterprise engaged in commerce or in the production of goods for commerce within the meaning of Sections 3(r) and (s) of the FLSA, 29 U.S.C.§ 203(r) and (s), in that said enterprise has continuously been an enterprise whose annual gross volume of sales made or business done is not less than $500,000.00.
STATEMENT OF TITLE VII CLAIMS 8. More than thirty days prior to the institution of this lawsuit, Rickisue Daly filed a charge with the Commission alleging violations of the Equal Pay Act and Title VII by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled. 9. Since at least February 2000, Defendant Employer has engaged in unlawful employment practices at its Key Energy Services Four Corners Division facility in Farmington, New Mexico in violation of Sections 703(a) and 704(a) ofTitie VII, 42 U.S.C.§§ 2000e-2(a) and 3(a). These practices include:
a) discriminating against Rickisue Daly in the wages, terms, conditions, and privileges of her employment because of her sex, female; and b) retaliating against Ms. Daly for opposing practices made unlawful by Title VII.
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10. The effect of the unlawful employment practices complained of in Paragraph 9 above has been to deprive Rickisue Daly of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex, female, and because she had opposed practices made unlawful by Title VII.
11. The unlawful employment practices complained of in Paragraph 9 above were and are intentional.
12. The unlawful employment practices complained of in Paragraph 9 above were and are done with malice and/or reckless indifference to the federally protected rights of Rickisue Daly.
STATEMENT OF EPA CLAIMS 13. Since at least February 2000, Defendant Employer has violated Sections 6(d)(l) and 15 (a)(2) of the FLSA, 29 U.S.C. § 206 (d)(I) and 215 (a)(2), by paying wages to its female Controller in the Key Energy Services Four Corners Division facility in Farmington, New Mexico, at rates less than the rates paid to at least one male employee in the same establishment for substantially equal work on jobs, the performance of which requires equal skill, effort and responsibility, and which are performed under similar working conditions. 14. As a result of the acts complained of in Paragraph 13 above, Defendant Employer unlawfully has withheld and is continuing to withhold the payment of wages due to Rickisue Daly. 15. The unlawful practices complained of in Paragraph 13 above were and are wilful. 16. Since at least March 2000, Defendant Employer has violated Section 15(a)(3) of the FLSA, 29 U.S.c. § 215(a)(3), by retaliating and discriminating against Rickisue Daly because she complained about Defendant Employer's denial of equal pay to her and gender discrimination
4

in the payment of wages to her. 17. The unlawful practices complained of in Paragraph 16 above were and are
intentional. 18. The unlawful practices complained of in Paragraph 16 above were done with malice
and/or reckless indifference to the federally protected rights of Rickisue Daly. PRAYER FOR RELIEF
Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of sex, in the wages, terms, conditions, and privileges of employment and any other employment practices that discriminate on the bases of sex or retaliation. B. Grant a permanent injunction enjoining the Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from discriminating within any of its establishments between employees on the basis of sex, by paying wages to employees of one sex at rates less than the rates at which it pays wages to employees of the opposite sex for substantially equal work on jobs the performance of which requires equal skill effort and responsibility, and which are performed under similar working conditions. C. Grant a permanent injunction enjoining the Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from discriminating against individuals because such individual has filed any complaint or instituted or caused to be instituted any proceeding under or related to the Equal Pay Act, or has testified or
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is about to testify in any such proceeding, or has served or is about to serve on an industry committee.
D. Order the Defendant Employer to institute and carry out policies, practices and programs which provide equal employment opportunities for women and those who participate in proceedings under the EPA or Title VII or who oppose practices made unlawful by the EPA or Title VII and which eradicate the effects of its past and present unlawful employment practices
E. Order the Defendant Employer to make whole Rickisue Daly 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, including but not limited to wage increases and front pay.
F. Order the Defendant Employer to make whole Rickisue Daly by providing compensation for past and future pecuniary losses resulting from the unlawful practices described in Paragraphs 9-12, 16-18 above, including but not limited to, vehicle purchase expenses and other out-of-pocket expenses in amounts to be determined at trial.
G. Order the Defendant Employer to make whole Rickisue Daly by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in Paragraphs 9-12, 16-18 above, including, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other non-pecuniary losses in amounts to be determined at trial.
H. Order the Defendant Employer to pay Rickisue Daly punitive damages for its malicious and/or reckless conduct described in Paragraphs 9-12, 16-18 above in an amount to be determined at trial.
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I. Grant a judgement requiring the Defendant Employer to pay appropriate back wages

in amounts to be determined at trial, and an equal sum as liquidated damages or prejudgment

interest in lieu thereof, to Rickisue Daly whose wages are being unlawfully withheld as a result

of the acts complained of above.

J.

Grant such further relief as the Court deems necessary and proper in the public

interest.

K. Award the Commission its costs in this action.

JURY TRIAL DEMANDED

The Commission requests a jury trial on all questions of fact raised by its Complaint.

DATED this 28'h day of March, 2002.

Respectfully submitted,
GWENDOLYN YOUNG REAMS Associate General Counsel Litigation Management Services
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 L Street, NW Washington, D.C. 20507

tp..n ~1't~... MARY JO O'NEILL

I

Acting Regional Attorney

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k~~o~
C. EMANUEL SMITH
Supervisory Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Phoenix District Office 3300 N. Central Ave. Suite 690 Phoenix, Arizona 85012

~~e"M.AL~

ORETTA MEDINA

....

Senior Trial Attorney

VERONICA A. MOLINA Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Albuquerque District Office 505 Marquette NW, Suite 900 Albuquerque, New Mexico 87102 (505) 248-5230

Attorneys for Plaintiff

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 il'ILED

IN THE UNITED STATES DISTRIC\.fN:p'U~yTESDISTAI?!ee?U~l

FOR THE DISTRICT OF NEW MEXICO

co

,)u:. 'I 4 2002

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

KEY FOUR CORNERS, INC., d/b/a

)

KEY ENERGY SERVICES, INC.,

)

FOUR CORNERS DIVISION

)

)

Defendant.

)

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

CIV 02-0354 JP/LFG CONSENT DECREE

The United States Equal Employment Opportunity Commission (the "Commission" or

"EEOC") filed this action against Key Four Corners, Inc., d/b/a Key Energy Services, Inc.,

Four Corners Division ("Defendant"), to enforce the Equal Pay Act of 1963, Title VII of the

Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991. In the Complaint, the

Commission alleged that Rickisue Daly, an employee of Defendant, was and is paid lower

wages than at least one male employee who performed substantially equal work under similar

working conditions. The Commission also alleged that Ms. Daly was discriminated against in

her wages, terms, conditions and privileges of employment because of her sex, female, and

was subjected to retaliation after she complained about wage and gender discrimination.

Defendant denied the allegations brought by the Commission as alleged in the

Complaint filed in this Civil Action, and specifically denies it discriminated against any

individual on the basis of gender or that it engaged in retaliation or any other unlawful practice

under Title VII or the Equal Pay Act. This Consent Decree does not constitute, and shall not

be construed as, an admission by Defendant of any violation of any federal, state or local statute, law or regulation.
The parties to this Consent Decree do not object to the jurisdiction of the Court over this action and waive their rights to a hearing and the entry of findings of fact and conclusions of law.
It is hereby ORDERED, ADJUDGED AND DECREED: 1. This decree resolves all claims of the Commission and Rickisue Daly against Defendant, including claims for back pay, liquidated damages, compensatory and punitive damages, interest, injunctive relief, attorneys' fees and costs arising out of the issues in this lawsuit.
INJUNCTION 2. For the duration of this Consent Decree, Defendant's' Four Corner's Division, its managers, officers, agents, successors, assigns and all persons in active concert or participation with them, shall not discriminate against any employee because of his or her sex, including paying lower wages to females who perform substantially equal work under similar working conditions as their male counterparts and discriminating in the wages, terms, conditions and privileges of employment because of an individual's sex, unless it is established that such differential is pursuant to a seniority system, a merit system, and/or a system which measures earnings by quantity or quality of production, or some other factor other than sex. 3. For the duration of this Consent Decree, Defendant's Four Corner's Division, its managers, officers, agents, successors, assigns, and all those in active concert or participation with them, or any of them, shall not engage in reprisal or retaliation of any kind against Rickisue Daly, any witness who testified, assisted, or participated in any manner in this case or
2

any person because such person:

A. opposed any practice made unlawful under Title VII;

B. filed a charge of discrimination with the Commission or a state agency

or testified or participated in any manner in any investigation, proceeding or

hearing under the Title VII;

C. requested and/or received relief in accordance with this Consent Decree; or

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

this action.

RELIEF TO CHARGING PARTY

4. Within ten (10) days after this Consent Decree is approved by the Court, Key

Energy Services, Inc., shall provide Rickisue Daly an increase in her annual salary to a rate of

$80,000.00 per year with all attendant employment benefits, but not to include a monetary car

allowance.

5.

Within fifteen (IS) days after this Consent Decree is approved by the Court,

Key Energy Services, Inc., shall make payment in the form of business checks in the amounts

listed below:

A. $44,000.00 for back pay retroactive to February 2000 to date at an annual rate

of $80,000.00, less only any applicable deductions for the employee's portion of

FICA, Medicare and applicable federal and state income tax withholding, in a

check made payable to Rickisue Daly. This retroactive raise shall be reflected

and recorded within Rickisue Daly's official personnel file. Defendant shall be

responsible for reporting the amount paid to the Internal Revenue Service and

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shall be responsible for paying the employer's share of FUTA and FICA on any amounts designated as back pay. B. $81,000.00 for attorney's fees, emotional distress, and any other compensatory damages in a check made payable to Rickisue Daly and her attorney, Thomas J. Griego, Bill Gordon & Associates, 2501 Yale SE, Suite 204, Albuquerque, New Mexico 87106,. Defendant will issue a United States Internal Revenue Service Form 1099 for this amount. 6. Within five (5) days of issuance ofthe checks required by paragraph 5 above, Defendant shall submit a copy of the checks and related correspondence to the Regional Attorney, Equal Employment Opportunity Commission, Albuquerque District Office, 505 Marquette NW, Suite 900, Albuquerque, New Mexico 87102-2189. 7. In response to any employment inquiries or reference checks concerning Rickisue Daly, Defendant shall provide a neutral reference for Ms. Daly providing Ms.Daly's dates of employment, each position held, job duties and salary. Defendant acknowledges that Ms. Daly's performance as Controller since February 2000 has been satisfactory and should such satisfactory performance continue throughout her employment, Defendant will provide a positive reference for Ms. Daly. This provision shall remain in force for so long as Ms. Daly uses the Defendant as a reference and is not limited to the two-year duration of this decree.
DEFENDANT'S POLICIES AND PRACTICES 8. Defendant shall institute and carry out policies and practices that foster work environments free from sex discrimination, including policies and practices related to the payment of equal wages to women and men who perform substantially equal work under similar working conditions, unless it is established that such differential is pursuant to a
4

seniority system, a merit system, and/or a system which measure earnings by quantity or quality of production, or some other factor other than sex. To assist Defendant in its effort to foster a work environment free of wage and sex discrimination, Defendant shall take the actions provided for in Paragraphs 9 through II.
9. The Defendant shall review its existing policies on wages, terms, conditions and privileges of employment as well as sex discrimination and make any changes necessary so that its policies comply with the Equal Pay Act and Title VII. Defendant shall ensure its written policies include a statement that employees have a right to complain directly to the U.S. Equal Employment Opportunity Commission or any state equal opportunity agency. After reviewing and making any necessary revisions to its policies, Defendant shall distribute the revised policies to each of its current full and part-time employees in Defendant's Four Corners Division, to each new employee hired in Defendant's Four Corners Division for the duration of this decree, to each corporate manager or official involved in setting Ms. Daly's wage in the year 2000, and to each corporate manager or official with responsibility, during the duration of this Decree, for setting or evaluating wages in the Four Corners Division.
10. Defendants shall post within thirty (30) days of the entry of this Consent Decree, for a period of twenty-four (24) months in a prominent place frequented by its employees in the Four Corners Division, the Notice attached to this Decree as Exhibit A. This Notice shall be the same type, style and size as in Exhibit A.
11. Defendants shall provide training on wage and sex discrimination according to the following terms:
A. Defendant shall provide at least three training sessions during the term of this
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Consent Decree. All employees, including managers and supervisors, at all Four Corners Division facilities shall attend the training. Also, all corporate managers or officials involved in setting Ms. Daly's wage in the year 2000 and all corporate managers or officials with responsibility, during the duration of this Decree, for setting or evaluating wages in the Four Corner Division will be required to attend the training sessions held pursuant to this Decree. Duplicative sessions may be held to accommodate staffing needs. Defendant shall be responsible for all costs associated with this training. B. The training shall be conducted within four (4) months of the entry of this decree. Additional training shall be conducted at least once in the second year of this Consent Decree. C. Defendant shall select a trainer qualified to conduct training on the subjects of the equal pay act and sex discrimination and shall submit the trainer's name, resume, training agenda and the date(s) of the proposed training to the Regional Attorney of the Albuquerque office of the Equal Employment Opportunity Commission within sixty (60) days of the entry of this Consent Decree. The Commission shall have thirty (30) days from the date of the receipt of the information described above to accept or reject the proposed consultant/lecturer and/or the contents of the seminar. In the event the Commission does not approve of the designated consultant/lecturer proposed by Defendant the Commission shall designate the consultant/lecturer at a cost not to exceed $1,000.00 per seminar-training session, which shall be paid by Defendant.
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During the second year of the Consent Decree, the above information concerning the proposed training session shall be submitted to the Regional Attorney at least ninety (90) days prior to the seminar-training session. D. The training shall include a minimum of two hours of instruction. All personnel designated in Paragraph A shall both register and attend the training. The registry of attendance shall be retained by Defendant at least for the duration of the Consent Decree. E. The training, at a minium, shall include the subjects of: what constitutes unlawful discrimination and unlawful retaliation under the Equal Pay Act and Title VII, including compensation discrimination based on sex; that wage disparity between women and men who perform substantially equal work under similar working conditions violates the Equal Pay Act; that sex discrimination in compensation, hiring, firing, assignment or other terms, conditions or privileges of employment violates Title VII; how to prevent sex discrimination and violations of the Equal Pay Act; how to provide a work environment free from sex discrimination, including wage discrimination; and to whom and by what means employees may complain if they feel they have been subjected to sex discrimination or wage discrimination. F. Immediately following the training sessions, Defendant's highest ranking managerial official(s) for the Four Corners Division shall speak to the employees about: (1) potential discipline that can be taken against supervisors, managers and employees who commit acts of sex or wage discrimination and retaliation or who allow sex or wage discrimination and retaliation to occur in
7

the workplace; (2) the importance of maintaining an environment free of sex or wage discrimination and retaliation; and (3) the employer's policies regarding wage and sex discrimination and retaliation. This time shall not be counted toward the two-hour minimum training required in Paragraph 11 D. In the event of the need for duplicative or make-up training sessions, the Defendant may present the managerial official's remarks by video presentation. All such video presentations shall be copied and supplied to the Commission in accord with Paragraph 13 of this Consent Decree. G. For the duration of this decree, at or around the time of hire, employees hired after the annual training is presented shall view a video tape of the training and/or a professional training tape which covers the topics set forth in Paragraph liE, and shall be given any written material disseminated at the training. 12. In accordance with this Consent Decree, the Commission, at its discretion, may designate Commission representatives to attend and participate in the training sessions held pursuant to Paragraph 11 of this Decree. REPORTING OF COMPLIANCE AND ACCESS BY EEOC 13. Defendant shall report in writing and in affidavit form c/o the Regional Attorney of the Equal Employment Opportunity Commission's Albuquerque District Office at 505 Marquette NW, Suite 900, Albuquerque, New Mexico 87102-2189, beginning six months after the date of the Entry of this Consent Decree, and thereafter every six months for the duration of the Consent Decree the following information: A. Any substantive changes, modifications, revocations, or revisions to its sex
B

discrimination and equal pay policies and procedures pursuant to Paragraph 9. B. The registries of persons attending each of the seminar-training sessions
required in Paragraph 11 and a list of current employees for all Four Corners Division facilities and corporate managers or officials involved in wage setting on the day of the seminar-training session(s). C. An affidavit from Defendant's highest ranking official(s) in the Four Corners Division stating: (1) the Notice required in Paragraph 10 was posted and the locations where it was posted and (2) it has complied with Paragraphs 2-11 of this Consent Decree. 14. The Commission shall have the right, after written notice is served on Defendant giving 5 days notice, to enter and inspect the facilities of Defendant in the Four Corners Division to ensure compliance with this decree and federal anti-discrimination laws.
COSTS AND DURATION 15. Each party shall bear its costs and attorneys' fees incurred as a result of this action through the entry of this Consent Decree. 16. The duration of this Consent Decree shall be two (2) years from the date of its entry. This Court shall retain jurisdiction of this action for the duration of the Consent Decree, during which the Commission may petition this Court for compliance with this Consent Decree. Should the Court determine that Defendant has not complied with this Consent Decree, appropriate relief, including extension of this Consent Decree for such period as may be necessary to remedy its noncompliance, may be ordered. 17. Without further action by the parties, this Consent Decree shall expire by its
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~~--~--------~~----

own terms at the end of two (2) years after the date of entry.

18. The parties agree to entry of this Consent Decree subject to final approval by

the Court.

ENTERED AND ORDERED this __ day of

,2002.

H HONORABLE JAMES A. PARKER TED STATES DISTRICT JUDGE

APPROVED AND CONSENTED TO:

GWENDOLYN YOUNG REAMS Associate General Counsel Litigation Management Services
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1801 L Street, N.W. Washington, D.C. 20507

1mJklYhp rL..~ MARY JO O'NEILL Acting Regional Attorney

~a tktfuQ
C.EMANUEL SMITH

~A71YLV\,

Supervisory Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
3300 N. Central Ave., Suite 690 Phoenix, Arizona 85012

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/~~k c.aJiiE co ELL v
Attorney lenkens & Gilchrist 2200 One American Center 600 Congress Avenue Austin, Texas 78701 Telephone: (512) 499-3897
~~t:#~ NlE BBS 0 Associate ounsel Key Energy Services, Inc. 6 Desta Drive, Suite 4400 Midland, Texas 79705 Telephone: 915) 571-7115

ic}rnQ~ 11~ ORETTA MEDINA Senior Trial Attorney
VERONICA A. MOLINA Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Albuquerque District Office 505 Marquette NW, Suite 900 Albuquerque, New Mexico 87102-2189 Telephone: (505) 248-5230

Attorney Modrall Sperling Roehl Harris & Sisk PA 500 4th Street NW #1000 Albuquerque, Ne Mexico 87102 Telephone: (505) 848-1830
Attorneys for Defendant

Attorneys for Plaintiff

Attorney for Rickisue Daly 11

NOTICE TO ALL EMPLOYEES OF KEY ENERGY SERVICES, INC., FOUR CORNERS DIVISION
This Notice is posted pursuant to a Consent Decree between Key Energy Services, Inc. ,Four Corners Division and the Equal Employment Opportunity Commission (EEOC).
It is unlawful under the federal law (the Equal Pay Act of 1963 and Title VII of the Civil Rights Act of 1964) and state law to discriminate against an employee on the bases of pay and or sex in compensation, hiring, firing, promotion practices or other terms, and conditions or privileges of employment.
Key Energy Services, Inc. prohibits all forms of discrimination, including sex discrimination in wages, terms, conditions and privileges of employment. Key Energy Services, Inc. does not discriminate on the basis of sex. Key Energy Services, Inc. does not retaliate against any employee who opposes a practice made unlawful under federal law, files, assists or participates in the filing of a charge of discrimination or participates in any investigation under Title VII, or who files a grievance alleging discrimination.
If you believe you are being discriminated against or retaliated against you should report this to the designated investigative officer at your workplace who may be contacted at _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~
If you believe you have been discriminated against by your Employer you have the right to seek assistance from:
I) Equal Employment Opportunity Commission (EEOC), 505 Marquette, Suite 900, Albuquerque, New Mexico 87102, (505) 248-5201 or 1-800669-4000. or
(2) The New Mexico Department of Labor, Human Rights Division, 1596 Pacheco St., Suite 103, Santa Fe, New Mexico 87505, (505) 827-6838.
You have the right to file a charge with the EEOC or the Department of Labor if you believe you are being discriminated against.
EXHIBIT A

 
 District Version v3.0.5 LIVE DB - Docket Report

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REFER, TERMED
U.S. District Court District of New Mexico - Version 3.0 (Albuquerque) CIVIL DOCKET FOR CASE #: 1:02-cv-00354-JAP-LFG

EEOC v. Key Energy Services Assigned to: District Judge James A. Parker Referred to: Magistrate Judge Lorenzo F. Garcia Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 03/28/2002 Date Terminated: 06/14/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Gwendolyn Young Reams EEOC Legal Counsel Office 1801 L Street, NW Washington, DC 20507 (202) 663-4669 Fax: 663-4639 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Mary Jo O'Neill EEOC Phoenix District Office 3300 North Central Avenue #690 Phoenix, AZ 85012-2504 (602) 640-5000 Fax: (602) 640-5009 Email: mary.oneill@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Key Energy Services Inc.
Intervenor Rickisue Daly

represented by Thomas J. Griego Bill Gordon & Associates 2501 Yale, SE #204 Albuquerque, NM 87106 (505) 265-1000 Fax: 242-1841

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LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed
03/28/2002 04/12/2002 06/14/2002

#

Docket Text

1 COMPLAINT for employment discrimination w/jury demand (referred to Magistrate Judge Lorenzo F. Garcia) (mlk) (Entered: 03/29/2002)
2 MOTION by intervenor Rickisue Daly to intervene (sl) (Entered: 04/15/2002)
3 CONSENT DECREE and ORDER by Chief Judge James A. Parker as described herein; dismissing case (cc: all counsel) (sl) Modified on 06/20/2002 (Entered: 06/14/2002)

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