IN THE UNITED STATES FOR THE MIDDLE DISTRICT

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
ROMAN KNIT, INC.,
Defendant.

)

)

)

)

CIVIL ACTION NO.

)

) COMPLAINT

)

)

JURY TRIAL DEMAND

)
) I:05CV00272
)

NATURE OF THE ACTION This is an action under Tide 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 to provide appropriate relief to Maria Lopez, who was adversely affected by such practices. As alleged with greater particularity below, the U.S. Equal Employment Opportunity Commission ("the Commission"), contends that Defendant Roman Knit, Inc. ("Defendant") discriminated against Ms. Lopez by subjecting her to a sexually hostile work environment by her immediate supervisor resulting in her discharge.
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(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"), and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Middle District of North Carolina.

PARTIES 3. Plaintiff, the Equal Employment Opportunity 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 Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant has been a North Carolina corporation doing business in the State of North Carolina and the City of Norwood, and has continuously had at least 15 employees. 5. At all relevant times, Defendant has 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 thirty days prior to the institution of this lawsuit, Maria Lopez filed a charge with the Commission alleging violations of Title VII by Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. From around May 2003 until around May 2004, Defendant engaged in unlawful employment practices at its Norwood, North Carolina facility in violation of Section 703(a)(1) of Title VII, 42 U.S.C. § 2000e-2(a)(1). Specifically, Defendant subjected Maria Lopez, a female, to sexual harassment and a sexually hostile work environment created by her male supervisor, because of her sex. The harassment included unwelcome sexual comments and sexual advances. Around May 2004, Ms. Lopez was discharged for refusing to submit to her supervisor’s sexual advances. Thereafter, around May 2004, Ms. Lopez informed Defendant about the sexual harassment and

discharge, and Defendant offered Ms. Lopez reinstatement working with the same supervisor. Defendant failed to act reasonably to prevent or promptly correct the sexual harassment. Thus, Ms. Parker felt forced to resign her position or, in the alternative, to decline Defendant’s offer of reinstatement because of the sexual harassment.
8. The effect of the practices complained of in paragraph 7 above has been to deprive Maria Lopez of equal employment opportunities and otherwise adversely affect her status as an employee, because of her sex, female.
The unlawful employment practices complained of in paragraph 7 above were intentional.
10. The unlawful employment practices complained of in paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Maria Lopez.
PRAYER FOR RELIEF 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 maintaining a sexually hostile work environment and from any other employment practice that discriminates on the basis of sex. B. Order Defendant to institute and carry out policies, practices, and programs that provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendant to make whole Maria Lopez 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 the

reinstatement of Ms. Lopez or an award of front pay. D. Order Defendant to make whole Maria Lopez, by providing compensation for past
and future pecuniary losses resulting from the unlawful employment practices described herein, including but not limited to medical expenses, in amounts to be determined at trial.
E. Order Defendant to make whole Maria Lopez by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of herein, including but not limited to emotional pain, suffering, inconvenience, loss of earning capacity, loss of enjoyment of life, humiliation, loss of self-esteem and loss of civil rights, in amounts to be determined at trial.
F. Order Defendant to pay Maria Lopez punitive damages for its malicious and reckless described herein, 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.

Dated this ~ day of March, 2005.
Respectfully submitted, ERIC S. DREIBAND General Counsel JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 L Street, N.W. Washington, D.C. 20507
Actin~ Regional Attorney
Trial Attorney -EQUAL EMPLOYMENT OPPORT~ITY COMMISSION Ch~lo~e Dis~ct Office 129 West Trade S~eet, Suite 400 Charlotte, Noah Carolina 28202 (704) 344-6875

 
 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

ROMAN KNIT, INC.

)

)

Defendant.

)

)

Civil Action No.: 1:05-CV-00272 CONSENT DECREE

The Equal Employment Opportunity Commission (the "Commission") instituted this action pursuant to Section 706(f)(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. § 1981a. The Commission’s complaint alleged that Defendant Roman Knit, Inc. (the “Defendant”), discriminated against Maria Lopez by subjecting her to a sexually hostile work environment by her immediate supervisor, resulting in her discharge. Roman Knit, Inc. filed an Answer denying the material allegations of the Complaint, including but not limited to the allegation that Maria Lopez was sexually harassed or subjected to unlawful discrimination, and raising numerous affirmative defenses to the claims asserted in the Complaint.
The Commission and the Defendant hereby stipulate to jurisdiction of the Court over the parties and agree that the subject matter of this action is properly before the Court.
The parties have advised this Court that they desire to resolve the allegations in the Complaint without the burden, expense, and delay of further litigation. It is understood and agreed that this settlement is the compromise of a disputed claim, and that the Defendant’s agreement to the terms herein are not to be construed as an admission of liability on the part of the Defendant.

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It is therefore the finding of this Court, made on the pleadings and the record as a whole, that: (1) the Court has jurisdiction over the parties and the subject matter of this action; (2) the purpose and provisions of Title VII will be promoted and effectuated by the entry of the Consent Decree; and (3) this Decree resolves all matters in controversy between the parties as provided in paragraphs 1 through 15 below.
It is therefore ORDERED, ADJUDGED AND DECREED as follows: 1. Defendant shall not discriminate against any person on the basis of sex within the meaning of Title VII. 2. Defendant shall pay Maria Lopez the sum of one thousand, five hundred dollars ($ 1,500.00), in settlement of the claims raised in this action. Defendant shall make payment by issuing a certified or cashier’s check payable to Maria Lopez. Defendants shall report such payment on an IRS Form 1099 to be issued to Ms. Lopez at the end of tax year 2006. Payment shall be made within fifteen (15) days after the Court approves this Consent Decree, and Defendant shall mail the check to Maria Lopez at an address provided by the Commission. Within ten (10) days after the check has been sent, Defendant shall mail to Lynette A. Barnes, Regional Attorney, Equal Employment Opportunity Commission, 129 W. Trade Street, Suite 400, Charlotte N.C., 28202, a copy of the check and proof of its delivery to Maria Lopez. 3. Within ten (10) days of the entry of this decree by the Court, Defendant shall eliminate from the employment records of Maria Lopez any and all documents, entries, or references of any kind relating to the facts and circumstances which led to the filing of EEOC Charge Number 146-2004-01717 and the related events that occurred thereafter. Within fifteen (15) days of the entry of this decree by the Court, Defendant shall report compliance with this provision to the EEOC. 4. Defendant will supply Maria Lopez with a neutral letter of reference, a copy of which is attached hereto, marked as Appendix A. In addition, if Defendant receives any inquiries regarding the employment of Ms. Lopez, in lieu of an oral response, Defendant shall provide a copy of the aforementioned letter. Within ten (10) days of responding to any inquiry regarding
2
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the employment of Ms. Lopez, Defendant shall report compliance to the Commission, including the name and address of the person or entity to whom the letter was provided.
5. Within ninety (90) days of the entry of this decree by the Court, Defendant shall adopt, implement, and distribute a formal, written anti-discrimination policy, which shall include but not be limited to the following: an explanation of the requirements of the federal equal employment opportunity laws, including Title VII and its prohibition against sexual harassment; procedures for reporting discrimination; and a procedure for the thorough and immediate investigation of employee complaints of discrimination. The policy shall be made available in both English and Spanish. Defendant shall distribute to each current employee a copy of the policy within the aforementioned 90 day time period. Within one hundred (100) days of the entry of this decree, Defendant shall report compliance to the Commission. During the term of this Decree, Defendant shall distribute the policy to all new employees and review it with them at the time of hire.
6. During the term of this Decree, Defendant shall post a copy of the policy described in paragraph 5, supra, in both English and Spanish, in all of its facilities in a place where it is visible to employees. If the policy becomes defaced or unreadable, Defendant shall replace it by posting another copy of the policy. Within ten (10) days after the Consent Decree is entered, Defendant will post the policy and notify the EEOC that it has been posted.
7. During the term of this Decree, Defendant shall provide an annual training program to all of its managers, supervisors and employees. Each training program shall include an explanation of the requirements of Title VII of the Civil Rights Act of 1964, and its prohibition against sexual harassment. Each training program shall also include an explanation of Defendant’s policy referenced in paragraph 5 above, and an explanation of the rights and responsibilities of employees and managers under the policy.
The first training program shall be completed within one hundred (100) days after entry of this Decree by the Court. Each subsequent training program shall be conducted at approximately one-year intervals. At least fifteen (15) days prior to each program, Defendant
3
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shall provide the Commission with an agenda for the training program. Within ten (10) days after completion of each training program, Defendant shall certify to the Commission the specific training which was undertaken and shall provide the Commission with a roster of all employees in attendance.
8. Beginning within thirty (30) days after the entry of this Decree by the Court, and continuing throughout the term of this Decree, Defendant shall conspicuously post the attached Employee Notice, marked Appendix B, hereby made a part of this Decree, in a place where it is visible to employees. If the Notice becomes defaced or unreadable, Defendant shall replace it by posting another copy of the Notice. Within forty-five (45) days after entry of this Decree, Defendant shall notify the Commission that the Notice has been posted pursuant to this provision.
9. During the term of this Consent Decree, Defendant shall provide the Commission with reports at six (6) month intervals, with the first being due four (4) months after approval by the Court of this Decree. The reports shall include the following information:
A. The identities of all individuals who reported or complained of sexual harassment or unwelcome verbal comments or physical sexual advances. Including by way of identification each person’s name, last known telephone number and address, social security number, and job title;
B. For each individual identified in 9.A. above, provide a detailed description of the individual’s report/complaint, including the name and title of the individual the report/complaint was about;
C. For each individual identified in 9.A. above, provide a detailed description of what action, if any, Defendant took in response to the report/complaint.
In the event there is no activity to report pursuant to this paragraph, Defendant shall send EEOC a “negative” report indicating no activity.
4
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10. During the term of this Decree, the Commission may inspect Defendant’s facilities in order to insure compliance with paragraph 6 (posting of sexual harassment policy) and paragraph 8 (posting of Employee Notice).
11. If anytime during the term of this Decree, the Commission believes that
Defendant is in violation of the Decree, the Commission shall conduct an initial review wherein it may inspect Defendant’s facilities, interview employees, supervisors and managers and examine and copy documents. If after the initial review the Commission continues to believe that Defendant is in violation of the Decree, the Commission shall give notice of the alleged violation to Defendant. Defendant shall have twenty (20) days in which to investigate and respond to the allegations. Thereafter, the parties shall then have a period of twenty (20) days or such additional period as may be agreed upon by them, in which to engage in negotiation regarding such allegations before the Commission exercises any remedy provided by law.
12. The term of this Decree shall be for three (3) years from its entry by the Court. 13. All reports or other documents sent to the Commission by Defendant pursuant to this Decree shall be sent to: Lynette A. Barnes, Regional Attorney, Equal Employment Opportunity Commission, 129 W. Trade Street, Suite 400, Charlotte N.C., 28202. 14. Each party shall bear its own costs and attorney’s fees. However, Defendant shall pay one hundred fifty ($150) dollars attorney’s fees to Maria Lopez for her to retain counsel for the purpose of reviewing Defendant’s proposed General Release. 15. This Court shall retain jurisdiction of this cause for purposes of monitoring compliance with this Decree and entry of such further orders as may be necessary or appropriate.

Date

United States District Judge

Middle District of North Carolina

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The parties jointly request that the Court approve and enter the Consent Decree: EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
/s/ Lynette A. Barnes Lynette A. Barnes Regional Attorney 129 West Trade Street, Suite 400 Charlotte, N.C. 28202 Lynette.Barnes@eeoc.gov
/s/ Jessica L. Dixon Jessica L. Dixon Trial Attorney 129 West Trade Street, Suite 400 Charlotte, N.C. 28202 Jessica.Dixon@eeoc.gov
ROMAN KNIT, INC., Defendant /s/ G. Bryan Adams, III
G. Bryan Adams, III Van Hoy, Reutlinger, Adams & Dunn 737 East Boulevard Charlotte, NC 28203 badams-vrad@carolina.rr.com
6
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[Defendant letterhead] [insert date] TO WHOM IT MAY CONCERN: We are pleased to provide the following reference on behalf of our former employee, Maria Lopez. Ms. Lopez was employed by us from August 1998 until May 2004. During her tenure with us, Ms. Lopez held the positions of Knitter and Inspector. A copy of her job description for each position is attached. Although our reference policy generally limits our comments to the foregoing information, we are willing in Ms. Lopez’s situation to provide this reference letter. We valued Ms. Lopez’s services to our organization and wish her well in her future endeavors. We hope that this information about Ms. Lopez is helpful to you in considering her application. Sincerely, _________________________ Ted Mauldin Plant Manager, Roman Knit, Inc.
APPENDIX A
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IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

EQUAL EMPLOYMENT

)

OPPORTUNITY COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

ROMAN KNIT, INC.

)

)

Defendant.

)

_____________________________________ )

Civil Action No.: 1:05-CV-00272 EMPLOYEE NOTICE

1. This Notice is posted pursuant to a settlement between the U.S. Equal Employment Opportunity Commission and Roman Knit, Inc., in a case alleging sexual harassment. Specifically, the EEOC alleged that Roman Knit, Inc. discriminated against Maria Lopez by subjecting her to a sexually hostile work environment by her immediate supervisor, resulting in her discharge, in violation of Title VII of the Civil Rights Act of 1964. Roman Knit, Inc. filed an Answer denying the material allegations of the Complaint, including but not limited to the allegation that Maria Lopez was sexually harassed or subjected to unlawful discrimination, and raising numerous affirmative defenses to the claims asserted in the Complaint. As part of the settlement, Roman Knit, Inc. agreed to take all action set out in the Consent Decree resolving this matter. The parties have decided to resolve this lawsuit to avoid the burden, expense and delay of further litigation. The settlement of this case does not constitute an admission of liability by the Defendant.
2. Federal law requires that employers not discriminate against any employee or applicant for employment because of the individual’s race, color, religion, sex, national origin, age (40 or older) or disability. Title VII specifically prohibits discrimination based on sex.
3. Roman Knit, Inc. will comply with such federal law in all respects. Furthermore, Roman Knit, Inc. will not take any actions against employees because they have exercised their rights, reported an alleged violation under the law or given testimony, assistance or participation in any investigation, proceeding or hearing conducted by the U. S. Equal Employment Opportunity Commission.
An employee has the right to report allegations of employment discrimination in the workplace. An employee may contact their local U. S. Equal Employment Opportunity Commission field office for the purpose of filing a charge of employment discrimination. To locate the nearest field office, contact:
Equal Employment Opportunity Commission 1801 L Street, N.W.
Washington, DC 20507 TEL: 1-800-669-4000 TTY: 1-800-669-6820
This Notice will remain posted for at least three (3) by agreement with the U.S. Equal Employment Opportunity Commission.
DO NOT REMOVE THIS NOTICE UNTIL: ____________________________, 2009.
APPENDIX B

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18AG, CLOSED
U.S. District Court North Carolina Middle District (Durham) CIVIL DOCKET FOR CASE #: 1:05-cv-00272-WLO-RAE

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Date Filed: 03/29/2005

v. ROMAN KNIT, INC.

Date Terminated: 02/13/2006

Assigned to: JUDGE WILLIAM L. OSTEEN

Jury Demand: Plaintiff

Referred to: MAG/JUDGE RUSSELL A. ELIASON

Nature of Suit: 442 Civil Rights: Jobs

Cause: 42:2000 Unlawful Employment Practices

Jurisdiction: U.S. Government Plaintiff

Plaintiff
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

represented by JESSICA DIXON EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 129 W. TRADE ST., STE. 400 CHARLOTTE, NC 28202 704-344-6875 Fax: 704-344-6780 LEAD ATTORNEY ATTORNEY TO BE NOTICED

LYNETTE A. BARNES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 129 W. TRADE ST., STE. 400 CHARLOTTE, NC 28202 704-344-6878 Fax: 704-344-6780 Email: lynette.barnes@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant ROMAN KNIT, INC.

represented by GEORGE BRYAN ADAMS, III VAN HOY REUTLINGER ADAMS & DUNN 737 E. BOULEVARD CHARLOTTE, NC 28203 704-375-6022 Fax: 704-375-6024 Email: badams-vrad@carolina.rr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Date Filed 03/29/2005 03/29/2005 04/26/2005 06/03/2005 06/17/2005 07/14/2005 07/15/2005 07/19/2005
08/25/2005

PHILIP MARSHALL VAN HOY VAN HOY REUTLINGER ADAMS & DUNN 737 E. BOULEVARD CHARLOTTE, NC 28203 704-375-6022 Fax: 704-375-6024 Email: pvanhoy-vrad@carolina.rr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

#

Docket Text

1 CIVIL COVER SHEET , filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.(McClain, Abby) (Entered: 03/30/2005)

2 COMPLAINT against ROMAN KNIT, INC. , filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.(McClain, Abby) (Entered: 03/30/2005)

3 WAIVER OF SERVICE upon ROMAN KINT, INC. Returned Executed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION; waiver sent on 4/13/2005; answer due 6/13/2005 (McKenzie, Keayba) (Entered: 04/27/2005)

4 ANSWER to Complaint by ROMAN KNIT, INC.(McKenzie, Keayba) (Entered: 06/08/2005)

5 NOTICE of Hearing: Initial Pretrial Conference set for 7/21/2005 09:30 AM in Winston-Salem Courtroom #3 before MAG/JUDGE RUSSELL A. ELIASON. (Williamson, Wanda) (Entered: 06/17/2005)

6 Rule 26(f) Report (Joint) filed by all parties (McKenzie, Keayba) (Entered: 07/14/2005)

MOTIONS 6 Rule 26(f) Report (Joint) filed by all parties REFERRED to Mag/Judge Eliason. (Williamson, Wanda) (Entered: 07/15/2005)

7 ORDER approving RULE 26F ORDER (JOINT): complex case mgmt.; mediation should be conducted late in the discovery period, the exact date to be set by the mediator after consultation with the parties; the parties agree that the mediator shall be Ann Anderson; parties should be allowed until 7/30/05 to request leave to join additional parties or amend pleadings; ETT 3d; JURY TRIAL; Amended Pleadings and Joinder of Parties due by 8/1/2005; Discovery due by 1/7/2006; the parties shall comply in all respects with F.R.C.P. 26(a)(3) regarding final pretrial disclosure as set out; Signed by Judge RUSSELL A. ELIASON on 7/19/05 (McKenzie, Keayba) (Entered: 07/19/2005)

8 NOTICE of Hearing: Jury Trial set for 7/10/2006 09:30 AM. Trial Briefs, etc. deadline 6/20/2006. (Winchester, Robin) (Entered: 08/25/2005)

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08/25/2005 10/14/2005
10/18/2005 10/19/2005 10/19/2005 10/20/2005
11/08/2005 11/08/2005 11/30/2005 12/13/2005 12/27/2005 01/04/2006

9 AMENDED NOTICE of Hearing: Jury Trial set for 7/10/2006 09:30 AM. Trial Briefs, etc. deadline 6/20/2006. (Winchester, Robin) (Entered: 08/25/2005)
10 MOTION, with consent, for Extension of Time for disclosing expert witness(es) and expert witness report(s) from 10/15/05 to thirty (30) days after Defendant produces financial information sought by EEOC in discovery by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (McKenzie, Keayba) (Entered: 10/18/2005)
Telephonic Notice on 10/18/2005: voice message left for atty. Jessica Dixon requesting a certificate of service for 10 Motion (McKenzie, Keayba) (Entered: 10/18/2005)
MOTIONS REFERRED to Mag/Jd Eliason 10 MOTION for Extension of Time. (Winchester, Robin) (Entered: 10/19/2005)
12 CERTIFICATE OF SERVICE for 10 Motion by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (McKenzie, Keayba) (Entered: 10/24/2005)
11 ORDER Granting [Doc #10] that the Plaintiff EEOC's deadline for disclosing expert witness (es) and expert witness report(s) concerning Defendant's financial status is extended for thirty (30)days from the date Defendant produces the financial information and records sought by EEOC; Signed by Judge RUSSELL A. ELIASON on 10/20/05 (Simmonds, Lisa); Modified on 10/21/2005 to correct typo (McKenzie, Keayba). (Entered: 10/20/2005)
13 MOTION for Protective Order by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION; Response due by 12/1/2005 (McKenzie, Keayba) (Entered: 11/09/2005)
14 MEMORANDUM filed by Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION in support of 13 MOTION for Protective Order (Attachments: # 1 Exhibit A# 2 Exhibit B)(McKenzie, Keayba) (Entered: 11/09/2005)
15 RESPONSE IN OPPOSITION filed by Defendant ROMAN KNIT, INC. to 13 MOTION for Protective Order filed by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION; Reply due by 12/14/2005. (McKenzie, Keayba) (Entered: 12/02/2005)
16 REPLY, filed by Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, to Defendant's Response to 13 MOTION for Protective Order (Attachments: # 1 Exhibit A# 2 Exhibit B)(McKenzie, Keayba) (Entered: 12/13/2005)
17 JOINT MOTION for Extension of Time to Complete Discovery from 1/7/06 to 2/6/06 by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION and ROMAN KNIT, INC. (McKenzie, Keayba) (Entered: 12/28/2005)
MOTIONS REFERRED to Mag/Jd Eliason 13 MOTION for Protective

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01/04/2006 01/04/2006
01/04/2006 01/10/2006 01/25/2006
01/26/2006
01/26/2006 01/26/2006 01/26/2006 01/31/2006
02/02/2006

Order, 17 JOINT MOTION for Extension of Time to Complete Discovery. (Winchester, Robin) (Entered: 01/04/2006)
18 MOTION to Compel Discovery by ROMAN KNIT, INC.; Response due by 1/27/2006 (McKenzie, Keayba) (Entered: 01/05/2006)
19 MEMORANDUM filed by Defendant ROMAN KNIT, INC. in support of 18 MOTION to Compel (Attachments: # 1 Appendix of Exhibits# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8# 10 Exhibit 9# 11 Exhibit 10# 12 Exhibit 11# 13 Exhibit 12# 14 Exhibit 13# 15 Exhibit 14)(McKenzie, Keayba) (Entered: 01/05/2006)
20 NOTICE of Manual Filing of Exhibits 4 & 10 re 19 Memorandum in support of 18 Motion to Compel Discovery in paper form with the Clerk's Office by Defendant ROMAN KNIT, INC. (McKenzie, Keayba) (Entered: 01/05/2006)
REPORT OF MEDIATOR M. Ann Anderson - Mediation hearing held on 1/6/2006. (Impasse)(Gammon, Cheryl) (Entered: 01/10/2006)
22 Joint MOTION for Extension of Time to Complete Discovery and for Extension of Time to File Response to Defendant's Motion to Compel Discovery by EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (Attachments: # 1 Text of Proposed Order)(DIXON, JESSICA); Modified on 1/26/2006 to amend document title (McKenzie, Keayba). (Entered: 01/25/2006)
MOTIONS REFERRED to Mag/Jd Eliason 22 Joint MOTION for Extension of Time to Complete DiscoveryJoint MOTION for Extension of Time to File Response/Reply to Defendant's Motion to Compel Discovery Joint MOTION for Extension of Time to File Response/Reply to Defendant's Motion to Compel Discovery. (Winchester, Robin) (Entered: 01/26/2006)
23 ORDER Granting 17 Joint Motion to Enlarge the Discovery Period from 1/7/06 to 1/30/06; Discovery due by 1/30/2006; Signed by Judge RUSSELL A. ELIASON on 1/26/06. (McKenzie, Keayba) (Entered: 01/27/2006)
24 CONSENT PROTECTIVE ORDER; Signed by Judge RUSSELL A. ELIASON on 1/26/06 (Attachments: # 1 Exhibit A)(McKenzie, Keayba) (Entered: 01/27/2006)
25 SUPPLEMENTAL PROTECTIVE ORDER; Signed by Judge RUSSELL A. ELIASON on 1/26/05. (McKenzie, Keayba) (Entered: 01/27/2006)
26 ORDER Granting 22 Joint Motion for Extension of Time to 3/6/06 for Plaintiff to respond to Defendant's Motion to Compel and for the completion of Discovery; Discovery due by 3/6/2006; Response due by 3/6/2006; Signed by Judge RUSSELL A. ELIASON on 1/31/06. (McKenzie, Keayba) (Entered: 01/31/2006)
27 SETTLEMENT AGREEMENT by Consent Decree by EQUAL

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02/03/2006
02/03/2006 02/13/2006
02/13/2006 02/27/2006 03/07/2006

EMPLOYMENT OPPORTUNITY COMMISSION. (DIXON, JESSICA) (Entered: 02/02/2006)
NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENT(S) Consent Decee, which was electronically filed 2/2/06 by Atty. Dixon, should not have been electronically filed without approval of the court. In the future the Consent Decree should be submitted to the court via email for approval and once the court has approved the Consent Decree it will be electronically filed at that time in the Clerk's Office. (Winchester, Robin) (Entered: 02/03/2006)
CASE REFERRED to Judge Osteen (Winchester, Robin) (Entered: 02/03/2006)
28 CONSENT DECREE with Appendices A and B as set out; the term of this Decree shall be for three (3) years from its entry by the Court; each party shall bear its own costs and attorney's fees; however, Defendant shall pay one hundred fifty ($150) dollars attorney's fees to Maria Lopez for her to retain counsel for the purpose of reviewing Defendant's proposed General Release; this Court shall retain jurisdiction of this cause for purposes of monitoring compliance with this Decree and entry of such further orders as may be necessary or appropriate; Signed by Judge WILLIAM L. OSTEEN on 2/13/06. (McKenzie, Keayba) (Entered: 02/13/2006)
Case no longer referred to Judge Osteen (McKenzie, Keayba) (Entered: 02/17/2006)
29 Exhibit Letter - Local Rule 83.5 (McKenzie, Keayba) (Entered: 02/27/2006)
Receipt of correspondence from G. Bryan Adams, III in response to 29 exhibit letter; sealed exhibits/documents are to be destroyed (McKenzie, Keayba) (Entered: 06/12/2006)

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06/06/2007 12:30:24

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Docket Report

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1:05-cv-00272-WLORAE

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https://ecf.ncmd.uscourts.gov/cgi-bin/DktRpt.pl?363777078746817-L_353_0-1

6/6/2007