I, .'i. USTRfCT cunn
1'.01{ i HEl<:\ DISTRICT OF TEXAS
FILED

JUN I 2 2001

IN THE UNITED STATES DISTRICT COU T CLERK, U.S. DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TE S By _ _-::-_ _ __

DALLAS DIVISION

Deputy

EQUAL EMPLOYMENT OPPORTUNITY }

COMMISSION,

}

}

Plaintiff,

}

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v.

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ASHER INVESTMENTS, INC., DBA

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BISTRO A

}

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Defendant.

}

------------------------------}

CIVIL ACTION NO.
S c 1 () ~; V1 8 1 11. 1J) -'J
COMPLAINT
JURY TRIAL DEMAND

NATURE OF THE ACTION

This is an action under Title VII ofthe Civil Rights Act of 1964, as amended ("Title VII") and

Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex

and unlawful employment actions taken in retaliation for opposing practices made unlawful of

discrimination under Title VII and to provide relief to Gwendolyn J. Watel ("Watel"), a former

employee ofDefendant. The Defendant subjected Watel to a sexually hostile work environment and

discharged her in retaliation for her complaints of sexual harassment.

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)(3) of the Civil Rights

Act of 1964, as amended, ("Title VII"), 42 U.S.C § 2000e-5(f)(3), and Section 102 ofthe Civil Rights Act of 1991,42 U.S.C. Sec. 1981a.
2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Northern District of Texas, Dallas Division.
PARTIES 3. Plaintiff, Equal Employment Opportunity Commission (the "Commission"), is an agency of the United States of America charged with the administration, interpretation and enforcement of Title VII of the Civil Rights Act of 1964, as amended and is expressly authorized to bring this action by Section 706(a) of Title VII, 42 U.S.c. § 2000e-5(a). 4. At all relevant times, Defendant, Asher Investments, Inc. dba Bistro A ("Bistro A") has continuously been and is now doing business in the State of Texas and has continuously had at least fifteen employees. 5. At all relevant times, Defendant, Bistro A, has continuously been an employer engaged in an industry affecting commerce under 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 ofthis lawsuit, Gwendolyn J. Watel filed a charge with the Commission alleging violations of Title VII of the Civil Rights Act of 1964, as amended, by the Defendant, Bistro A. All conditions precedent to the institution ofthis lawsuit have been fulfilled.

COMPLAINT

2

7. During the employment ofWatel, the Defendant engaged in unlawful employment practices in violation of §703(a)(l) of Title VII, 42 U.S.C. § 2000e-2(a)(l), by discriminating against Watel based upon her sex (female) by subjecting her to a sexually hostile work environment.
8. Defendant further engaged in unlawful employment practices in violation of §704 (a) of Title VII, 42 U.S.C. §2000e-3(a), by terminating Watel because she had opposed employment practices made unlawful by Title VII.
9. The result of the foregoing practices has been to deprive Watel of equal employment opportunities because ofher sex, female, and to discriminate against Watel for exercising her rights under Title VII.
10. The unlawful employment practices complained of in paragraphs 7 and 8 above were intentional.
11. The unlawful employment practices complained of in paragraphs 7 and 8 above were done with malice or with reckless indifference to the federally protected rights of Watel.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendant, Asher Investments, Inc., dba Bistro A, 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 or which constitutes retaliation for opposing any practice made an unlawful employment practice under Title VII.

COMPLAINT

3

B. Order the Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for female employees, deter sexual harassment, and which eradicate the effects of its past and present unlawful employment practices.
C. Order the Defendant to make whole Watel; by providing appropriate back pay with prejudgment interest in amounts to be determined at trial, front pay, pecuniary damages, compensatory damages including out-of-pocket expenses, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to rightful place reinstatement ofWatel.
D. Order the Defendant to make Watel whole by providing compensation for past and future nonpecuniary losses resulting from the unlawful employment practices described in paragraphs 7 and 8 above, including, but not limited to, pain and suffering, humiliation, embarrassment, emotional distress, anxiety, and loss of enjoyment oflife, in amounts to be determined at trial.
E. Order the Defendant to pay Watel punitive damages for its malicious conduct or reckless indifference described and referenced in paragraphs 7 and 8 above, in an amount to be determined at trial.
F. Grant such further reliefas the Court deems necessary and proper in the public interest. G. Award the Commission its costs in this action.
JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.

COMPLAINT

Respectfully submitted, Gwendolyn Young Reams Associate General Counsel
4

ROBERT A. CANINO Regional Attorney Oklahoma State Bar NO.011782

TOBY W. COSTAS

Supervisory Trial Attorney

Texas State Bar.No. 04855720

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Senio Trial Attorney Texas State Bar NO.04186600
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 South Houston, 3rd Floor Dallas, Texas 75202 (214) 655-3330 (214) 655-3331 FAX

COMPLAINT

5

 
 •

IN THE UNITED STATES DISTRICT FOR THE NORTHERN DISTRICT OF JL,""".L'~'-"
DALLAS DIVISION
- - - - BEyR_ K,_ U.S_ . D_iSTIUCT caUl{ Deputy

EQUAL EMPLOYMENT OPPORTUNITY }

COMMISSION,

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Plaintiff,

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ASHER INVESTMENTS, INC., DBA

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BISTRO A

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Defendant.

}

CIVIL ACTION NO.

3-01CVl113-N

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. NORTHERNF,D:;~';::,:('rOl<'TEXAS

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CLERK, U.s.DISTRICT COURT By ____~~______
CONSENT DECREE _ _ _ _ _ _ _D_e_p_ut_y_ _ _ _---'

This Consent Decree is made and entered into between the Plaintiff, the Equal Employment Opportunity Commission ("EEOC") and the Defendant, Asher Investments, Inc. ( referred to as "the parties").
The Equal Employment Opportunity Commission instituted a lawsuit under Title VII of the Civil Rights Act of 1964 (as amended) ("Title VII") and 42 U.S.c. § 1981a, in the United States District Court for the Northern District of Texas, Dallas Division, Civil Action Number No.3-01CVI113-N.
The parties hereto desire to compromise and settle the differences embodied in the aforementioned lawsuit, and intend that the terms and conditions be set forth in this Consent Decree.

• •
NOW, THEREFORE, in consideration of the mutual promises and agreements set forth herein, the sufficiency of which is hereby acknowledged, the parties agree as follows, the court finds appropriate, and therefore, it is ORDERED, ADJUDGED AND DECREED that:
1. This Court has jurisdiction to enforce the provisions set forth in this Consent Decree.
2. This Consent Decree resolves all issues, including all like and related issues, raised in EEOC Charge Number 310991355. The EEOC does not waive processing or litigating charges or cases other than the above-referenced charge and Complaint. It is understood that this Consent Decree does not constitute an admission by Defendant of any violation of Title VII or any of the allegations contained in the Complaint.
3. a. This Consent Decree is binding on Defendant, Asher Investments, Inc. and on any entity owned or controlled either directly or indirectly, whether through ownership of the stock of a corporation, interest in a partnership, LLC, Limited Partnership, or other means of ownership, whether held directly, indirectly, or in trust, by Celeste Samuel and/or Avner Samuel (hereinafter collectively "the Defendant").
b. Pursuant to FRCP 65 (d), this Consent Decree is further binding on the Defendant as defined in Paragraph 3 (a) above, their officers, agents, servants, employees, and attorneys, and upon those persons in active concert or participation with them who receive actual notice of this Consent Decree by personal service or otherwise.

CONSENT DECREE

2

• •
4. Celeste Samuel and Avner Samuel shall notify the EEOC within 10 days of the entry of this Consent Decree of the name and location of any presently existing entity. If no such entity currently exists, within 10 days of the opening of any entity which is subject to the terms of Paragraph 3 (a) above, Celeste Samuel and Avner Samuel shall notify the EEOC of the name and location of any such entity. In addition, Celeste Samuel and Avner Samuel, shall along with the notification required by this Paragraph, provide the EEOC with a copy of the documents forming the entity, and specify the ownership interest, whether held directly, indirectly, or in trust, by Celeste Samuel and/or Avner Samuel, and specify the title and job duties of Avner Samuel at the entity.
5. Defendant, as defined in Paragraph 3 (a) above, agrees not to discriminate on the basis of sex, including but not limited to sexual harassment, and Defendant, as defined in Paragraph 3 (a) above, further agrees not to retaliate in any way against any person because of opposition to any practice declared unlawful under Title VII or because of the filing ofa charge, giving testimony, or assisting or participating in any manner in any investigation, proceeding or hearing.
6. Defendant, as defined in Paragraph 3 (a) above, agrees to post the Notice appended hereto as Attachment "A" on the employee bulletin board at all of its facilities, as specified in Paragraph 3 (a) above, within 10 days after the entry of this Consent Decree or, if no such facility currently exists, within 10 days after the opening of any new entity. Defendant, as defined in Paragraph 3 (a) above, will report to the EEOC that it has complied with this requirement within 30 days

CONSENT DECREE

3

• •
after posting the notice. 7. During the first year that this Consent Decree is in effect, Defendant, as defined in
Paragraph 3 (a) above, agrees to conduct training one time for all employees, including officers, managers, and supervisors, at all of its facilities advising them of the prohibitions of Title VII regarding sexual harassment and retaliation. The training will inform the employees of the complaint procedure for individuals who suspect that they are being discriminated against by Defendant, as defined in Paragraph 3 (a) above. This annual training will also advise managers and supervisors of the consequences imposed upon Defendant, as defined in Paragraph 3 (a) above, for violating Title VII. The training shall be at least two (2) hours in duration. The training must be conducted by an instructor who may not be a present or past employee, manager, officer, director or shareholder of Defendant, as defined in Paragraph 3 (a) above. In the second and third years of this Consent Decree, Defendant, as defined in Paragraph 3 (a) above, agrees to conduct training one time each year for all officers, managers, and supervisors, and all other employees who have not previously received the training required by this Paragraph. No less than 10 days before the training is conducted, Defendant, as defined by Paragraph 3 (a) above, agrees to give written notice to the EEOC as to the date and location of the training, the name of the person providing the training and the substance of the training. All materials used in conjunction with the training shall be forwarded to the EEOC. Within 20 days following the training, Defendant, as defined by Paragraph 3 (a) above, shall submit to the EEOC

CONSENT DECREE

4

• •

confirmation that the training was conducted, and a list of attendees. 8. Defendant, as defined by Paragraph 3 (a) above, shall within 30 days after entry
of this order provide all current employees with a written sexual harassment policy which complies with the Equal Employment Opportunity Commission Guidelines on Sexual Harassment, 29 C.F.R. §1604.11 and the EEOC Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors, issued June 18, 1999, including a complaint policy. New

employees shall be provided with a copy of the policy at the time of their hire. A

copy of policy shall be served on counsel for the Plaintiff EEOC and posted

conspicuously at all facilities of the Defendant, as defined in Paragraph 3 (a)

above.

9. IT IS FURTHER ORDERED AND ADJUDGED that the complaint procedure set

forth in the sexual harassment policy of Defendant, as defined in Paragraph 3 (a)

above, must specify that complaints be directed to an independent person, who

may not be a present or past employee, manager, officer, director or shareholder of

Defendant, as defined in Paragraph 3 (a) above, with power to conduct

investigations and make recommendations to management. In addition,

•

Defendant, as defined in Paragraph 3 (a) above, may not retain as its instructor or

investigator of complaints any attorney who represented Defendant during the

investigation of Charge No. 310991355 by the EEOC. It is understood that

current trial counsel is a permissible instructor and/or investigator.

10. Upon closing of this Agreement, Defendant shall provide Sidney B. Chesnin,

CONSENT DECREE

5

• •
Senior Trial Attorney with the EEOC, a cashier's check in the amount of $4,500 payable to Gwen Watel, representing damages under 42 U.S.C. §1981a only, pending approval of this Consent Decree by the Court. Defendant will provide Ms. Watel with an IRS Form 1099 in the normal course of business to her address at 4506 Abbott #3, Dallas, TX 75205. 11. All reports to the EEOC required by this Decree shall be sent to Sidney B. Chesnin, Senior Trial Attorney, 207 S. Houston Street, 3rd Floor, Dallas, Texas 75202. 12. The parties agree to bear their own costs associated with this action, including attorney's fees. 13. The EEOC has the right to specifically enforce the terms of this Decree. Nothing in this Consent Decree can preclude further actions by the EEOC or any other person to remedy any other alleged violations of Title VII by Defendant. 15. The effective date of this Decree shall be the date upon which it is signed for approval by the Court. 15. The term of this Decree shall be for three (3) years from the effective date. The Court shall retain jurisdiction to enforce the terms of this Decree until the expiration of the term of the Consent Decree.

CONSENT DECREE

6

•

•

APPROVED AS TO FORM AND
<~ROBECRT AA.~~AN-IN-~~---
Regional Attorney
Oklahoma State Bar NO.011782

TOBY W. COSTAS

Supervisory Trial Attorney

Te a

ar No. 04855720

SI Senior Trial Attorney Texas State Bar No. 04186600

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 South Houston, 3rd Floor Dallas, Texas 75202 (214) 655-3330 (2 4) 655-3331 FAX

exas State Bar No. 00788669 HINDS & WILLETT 51 0 West Main Street Waxahachie, Texas 75165 (972) 938-9993 (972) 937-3110 FAX

CONSENT DECREE

7

• •
SIGNED THIS _ _-..!.._----...::---_DAY OF --:--I---I.::.---f---' 2003

CONSENT DECREE

8

• •

ATTACHMENT "A"

NOTICE TO ALL EMPLOYEES

This notice is being posted as part of an Agreement between the U.S. Equal Employment

Opportunity Commission ("EEOC") and your Employer. Federal law requires that there be no discrimination against any employee or applicant for

employment because of the employee's sex, including sexual harassment, race, color, religion,

national origin, age or disability with respect to hiring, firing, promotions, pay raises or other terms, conditions or privileges of employment. Upon an employee's complaint of such treatment, employers are also required to investigate and to promptly take appropriate remedial and corrective action. The law also prohibits an employer from retaliating against employees who oppose what they believe to be unlawful employment practices.

Sexual harassment is harassment on the basis of sex. Sexual harassment includes

unwelcome sexual advances, requests for sexual favors, and other verbal or physical contact of a

sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, (2) submission to or rejection of such conduct by individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment.
This Notice is intended to inform employees of their rights under federal law and to prevent future acts of discrimination.
The employee has the right, and is encouraged to exercise the right, to report allegations

of discrimination, including but not limited to discrimination based on sexual harassment or

retaliation, in the workplace. An employee may do so by notifying the Employer's designated

representative

at._ _ _ _ _ _ _ _ _ _ _ _ __

Supervisors and managers who are informed of an employee's complaint must immediately notify _________

Any report of such an allegation will be thoroughly investigated, and, if substantiated, appropriate disciplinary action will be taken against any person(s) found to have engaged in discriminatory conduct.

A person either alternatively, or in addition to reporting such an allegation to company

officials, may contact the Equal Employment Opportunity Commission for the purposes of filing

a charge of employment discrimination. The Dallas District Office of the Equal Employment Opportunity Commission is located at 207 S. Houston, 3rd Floor, Dallas, Texas 75202. Information about your rights and how to file a charge is also available on the Internet at www.eeoc.gov.

DATE

FOR THE EMPLOYER

THIS NOTICE SHALL REMAIN POSTED UNTIL -------------------

• •

NOTICE TO ALL EMPLOYEES

This notice is being posted as part of an Agreement between the U.S. Equal Employment

Opportunity Commission ("EEOC") and your Employer.

Federal law requires that there be no discrimination against any employee or applicant for

employment because of the employee's sex, including sexual harassment, race, color, religion,

national origin, age or disability with respect to hiring, firing, promotions, pay raises or other

terms, conditions or privileges of employment. Upon an employee's complaint of such

treatment, employers are also required to investigate and to promptly take appropriate remedial

and corrective action. The law also prohibits an employer from retaliating against employees

who oppose what they believe to be unlawful employment practices.

Sexual harassment is harassment on the basis of sex. Sexual harassment includes

unwelcome sexual advances, requests for sexual favors, and other verbal or physical contact of a

sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term

or condition of an individual's employment, (2) submission to or rejection of such conduct by

individual is used as the basis for employment decisions affecting such individual, or (3) such

conduct has the purpose or effect of unreasonably interfering with an individual's work

performance or creating an intimidating, hostile, or offensive working environment.

This Notice is intended to inform employees of their rights under federal law and to

prevent future acts of discrimination.

The employee has the right, and is encouraged to exercise the right, to report allegations

of discrimination, including but not limited to discrimination based on sexual harassment or

retaliation, in the workplace. An employee may do so by notifying the Employer's designated

representative

at_ _ _ _ _ _ _ _ _ _ _ _ __

Supervisors and managers who are informed of an employee's complaint must immediately notify _________

Any report of such an allegation will be thoroughly investigated, and, if substantiated, appropriate disciplinary action will be taken against any person(s) found to have engaged in discriminatory conduct.
A person either alternatively, or in addition to reporting such an allegation to company officials, may contact the Equal Employment Opportunity Commission for the purposes of filing a charge of employment discrimination. The Dallas District Office of the Equal Employment Opportunity Commission is located at 207 S. Houston, 3rd Floor, Dallas, Texas 75202. Information about your rights and how to file a charge is also available on the Internet at www.eeoc.gov.

DATE

FOR THE EMPLOYER

THIS NOTICE SHALL REMAIN POSTED UNTIL _ _ _ _ _ _ __

 
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CLOSED, JURY, KAPLAN
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:01-cv-01113

EEOC v. Asher Investments Assigned to: Judge David C Godbey Demand: $0 Cause: 42:2000 Job Discrimination (Sex)
Plaintiff Equal Employment Opportunity Commission
V. Defendant Asher Investments, Inc. doing business as Bistro A

Date Filed: 06/12/2001 Date Terminated: 05/12/2003 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Sidney B Chesnin Law Office of Sidney Chesnin 4841 Tremont Street #9 Dallas, TX 75246 972/503-6338 Email: schesnin@hotmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Jason Michael Willett Hinds & Willett 510 W Main St Waxahachie, TX 75165 972/938-9993 Fax: 972/937-3110 FAX LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joel W Reese Winstead Sechrest & Minick - Dallas 5400 Renaissance Tower 1201 Elm St Dallas, TX 75270 214/745-5400 Fax: 214/745-5390 FAX Email: jreese@winstead.com TERMINATED: 05/29/2002 LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Date Filed 06/12/2001 06/12/2001 06/12/2001 06/12/2001 06/12/2001 07/13/2001 07/20/2001
08/16/2001 08/17/2001
08/20/2001
01/09/2002 05/28/2002
05/28/2002
08/12/2002

#

Docket Text

1 COMPLAINT filed (5) (djd) (Entered: 06/14/2001)
1 DEMAND for jury trial by plaintiff EEOC (djd) (Entered: 06/14/2001)
2 CERTIFICATE OF INTERESTED PERSONS by plaintiff EEOC (2) (djd) (Entered: 06/14/2001)
3 SUMMONS(ES) issued for defendant Asher Investments (issued 1) (djd) (Entered: 06/14/2001)
PRELIMINARY ASSIGNMENT TO Magistrate Judge Jeff Kaplan (djd) (Entered: 06/14/2001)
4 ANSWER to Complaint by defendant Asher Investments (Attorney Joel W Reese) and Jury Demand (3) (djd) (Entered: 07/16/2001)
5 ORDER REQUIRING PROPOSAL for Contents of Scheduling Order. Proposed scheduling order due 8/20/01 ( signed by Judge Sidney A. Fitzwater) Copies to counsel: 7/20/01 Page(s): 3 (djd) (Entered: 07/20/2001)
6 Joint PROPOSAL FOR CONTENTS of scheduling and discovery order by defendant Asher Investments, plaintiff EEOC (3) (djd) (Entered: 08/17/2001)
7 SCHEDULING ORDER setting Joining of Parties on 1/1/02 ; Amending of Pleadings on 9/1/02 ; Discovery cutoff 9/1/02 ; Deadline for filing of dispositive motions 10/1/02 ; ( Signed by Judge Sidney A. Fitzwater ) Copies to counsel: 08/20/01 Page(s): 3 (cxj) (Entered: 08/20/2001)
8 RETURN OF SERVICE executed as to defendant Asher Investments 6/26/01 via personal service to registered agent. Answer due on 7/16/01 for Asher Investments. (mlh) (Entered: 08/21/2001)
9 TRIAL SETTING ORDER set docket call for 4/21/03 ( Signed by Judge Sidney A. Fitzwater ) Copies to counsel: 1/10/02 Page(s) 5 (djd) (Entered: 01/10/2002)
10 Unopposed MOTION by defendant to substitute Jason Michael Willett of Hinds & Willett for Joel W. Reese of Winstead Schrest & Minick P.C. (2) (djd) (Entered: 05/29/2002)
11 ORDER granting [10-1] motion to substitute Jason Michael Willett of Hinds & Willett for Joel W. Reese of Winstead Schrest & Minick P.C. ( Signed by Judge Sidney A. Fitzwater ) Copies to counsel: 5/29/02 Page(s) 1 (djd) (Entered: 05/29/2002)
12 ORDER REASSIGNING CASE/SPECIAL ORDER NO. 3-209 Effective 8/12/02, the cases listed on Exhibit A attached to this Order are transferred from the docket of Honorable Sidney A. Fitzwater to the docket of Honorable David C. Godbey and shall henceforth carry the suffix letter "N". The clerk of court will notify counsel by providing to each counsel a copy of this Order with attached exhibit. (Signed by Chief Judge A. Joe Fish) Copies to counsel: 8/13/02 Page(s) 2 (djd) Modified on 08/13/2002 (Entered: 08/13/2002)

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08/12/2002 08/29/2002 08/29/2002 09/03/2002 09/30/2002
10/09/2002 03/21/2003 03/21/2003 03/25/2003 04/01/2003 04/02/2003 04/02/2003 04/07/2003 04/07/2003 04/07/2003 04/07/2003

REASSIGNING CASE to Judge David C. Godbey ( Signed by Chief Judge A J. Fish ) per Special Order 3-209. (djd) (Entered: 08/13/2002)
13 UNOPPOSED MOTION by plaintiff EEOC to extend discovery cut-off for a limited purpose (2) (aat) (Entered: 08/30/2002)
14 JOINT STATUS REPORT by defendant Asher Investments, plaintiff EEOC (2) (aat) (Entered: 08/30/2002)
15 ORDER granting plaintiff's [13-1] motion to extend discovery cut-off for a limited purpose. ( Signed by Judge David C. Godbey ) Copies to counsel: 9/4/02 Page(s) 1 (aat) (Entered: 09/04/2002)
16 ORDER REGARDING TRANSITION All existing scheduling orders, trial settings and referrals to magistrate judges are adopted and remain in full force and effect. Counsel are directed to confer and file a joint status report no later than 14 days after the date of this order. See order for specifics. (Signed by Judge David C. Godbey) Copies to counsel: 10/1/02. Pages: 4 (aat) (Entered: 10/01/2002)
17 JOINT STATUS REPORT by defendant Asher Investments, plaintiff EEOC (11) (Attachment not imaged) (aat) (Entered: 10/10/2002)
18 Pretrial Disclosures pursuant to FRCP 26(a)(3)/Witness List by Equal Employment Opportunity Commission. (jrb, ) (Entered: 03/24/2003)
Pretrial Disclosures pursuant to FRCP 26(a)(3)/Exhibit List by Equal Employment Opportunity Commission. (jrb, ) (Entered: 03/24/2003)
19 PRETRIAL DISCLOSURES PURSUANT TO FRCP 26(a)(3) (Witness List, deposition desginations, exhibit list) by Asher Investments, Inc. (aat, ) (Entered: 03/26/2003)
20 OBJECTIONS re Deposition and Exhibit List filed by Asher Investments, Inc.. (aat, ) (Entered: 04/01/2003)
21 OBJECTIONS re 19 pretrial disclosures pursuant to FRCP 26(a)(3), filed by Equal Employment Opportunity Commission. (aat, ) (Entered: 04/03/2003)
22 SUPPLEMENTAL PRETRIAL DISCLOSURES pursuant to FRCP 26(a)(3)/Exhibit List by Equal Employment Opportunity Commission. (aat, ) (Entered: 04/03/2003)
23 Witness List by Equal Employment Opportunity Commission. (jaw) (Entered: 04/08/2003)
24 Proposed Jury Instructions by Equal Employment Opportunity Commission. (jaw) (Entered: 04/08/2003)
25 Proposed Voir Dire Questions by Equal Employment Opportunity Commission. (jaw) (Entered: 04/08/2003)
26 Exhibit List pursuant to LR 26.2 (b) by Equal Employment Opportunity Commission. (jaw) (Entered: 04/08/2003)

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05/08/2003 05/12/2003

27 Designation of Deposition Excerpts by Equal Employment Opportunity Commission. (jaw) (Entered: 04/08/2003)
28 AMENDMENT to Designation of Deposition Excerpts by Equal Employment Opportunity Commission. Re: 27 Designation of Deposition Excerpts. (lmr, ) (Entered: 04/10/2003)
29 JOINT MOTION for entry of consent decree by Asher Investments, Inc., Equal Employment Opportunity Commission. (aat, ) (Entered: 05/09/2003)
30 CONSENT DECREE. Upon closing of this agreement, defendant shall provide Sidney B. Chesnin, Senior Trial Attorney with the EEOC, a cashier's check of $4,500.00 payable to Gwen Watel, representing damages under USC 42 Section 1981 only. Defendant will provide Ms. Watel with an IRS Form 1099 in the normal course of busiess to her address. All reports to the EEOC required by this decree shall be sent to Sidney B. Chesnin. The parties agree to bear their own costs with this action, including attorney's fees. See Decree for specifics. (Signed by Judge David C Godbey on 5/9/03) (aat, ) (Entered: 05/12/2003)

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