IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES EQUAL EMPLOYMENT )

OPPORTUNITY COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

CONSOLIDATION RESOURCE CENTER, INC., )

)

)

Defendant.

)

)

)

__________________________________________/

CIVIL ACTION NO.:
COMPLAINT JURY TRIAL DEMAND INJUNCTIVE RELIEF SOUGHT

NATURE OF THE ACTION

This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil

Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation, and

to provide appropriate relief to Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany

Bowers, and similarly situated individuals who were adversely affected by such practices. As stated

with greater particularity in paragraph 7, the Commission alleges that Laretha Dortch-Lord, Kaymi

Elder-Manning, Aisha Larry, Tiffany Bowers, and similarly situated individuals were subjected to

sexual and gender based harassment by the alter ego of the Defendant corporation, owner Vincent

Lawrence, which was sufficiently severe and pervasive to constitute an intimidating, hostile and

offensive work environment. The Commission further alleges that Defendant retaliated against

Laretha Dortch-Lord for opposing the sexual harassment and for filing a charge with the

Commission by discharging her from her employment; that Defendant retaliated against Kaymi-Elder

1

Manning for opposing Defendant’s illegal practices by discharging her from her employment; that Defendant retaliated against Aisha Larry for complaining internally of sexual harassment and for filing a charge with the Commission by forcing her to resign from her position; and that Defendant retaliated against Tiffany Bowers for opposing Defendant’s illegal practices by discharging her from her employment.
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 Florida.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, a Florida corporation, has continuously been doing business in Pinellas County, Florida and has continuously had at least 15 employees. 5. At all relevant times, Defendant 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).
2

STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry and Tiffany Bowers, filed charges with the Commission alleging violations of Title VII by the Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least February of 2002, Defendant Employer engaged in unlawful employment practices in violation of Section 703(a) and Section 704(a) of Title VII, 42 U.S.C. §2000e-2(a) and §2000e-3(a).
a. Defendant subjected Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers, and similarly situated individuals to an intimidating, offensive and hostile work environment permeated with sexual favoritism towards female employees who succumbed to owner and President Vincent Lawrence’s sexual advances. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is liable for the sexually hostile work environment created towards female employees.
b. Laretha Dortch-Lord was subjected to sexual harassment by Defendant’s owner and President Vincent Lawrence in the form of unwelcome physical and verbal conduct of a sexual nature which was sufficiently severe and pervasive to constitute an intimidating, hostile and offensive work environment. The conduct included, but was not limited to, inappropriate sexual and gender based comments, and touching of her breasts. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is liable for the
3

sexual harassment. c. Defendant terminated Laretha Dortch-Lord for her refusal to submit to
Vincent Lawrence’s unlawful sexual advances and also in retaliation for filing a charge with the Commission alleging sexual harassment. d. Kaymi Elder-Manning was subjected to sexual harassment by Defendant’s owner and President Vincent Lawrence in the form of unwelcome physical and verbal conduct of a sexual nature which was sufficiently severe and pervasive to constitute an intimidating, hostile and offensive work environment. The conduct included, but was not limited to, inappropriate sexual and gender based comments such as “what I would not do to have those legs wrapped around me”, “girl, being with you would make me feel 10 ten years younger”and “if you were my woman, I would take care of you”; requests for sex; and fondling/touching of her breasts and buttocks. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is liable for the sexual harassment. e. Defendant terminated Kaymi Elder-Manning in retaliation for her opposition to and/or participation in protected activity against Defendant’s illegal practices during the pendency of another female employee’s sexual harassment charge with the EEOC against the Defendant. f. Aisha Larry was subjected to sexual harassment by Defendant’s owner and President Vincent Lawrence in the form of unwelcome physical and verbal conduct of a sexual nature which was sufficiently severe and pervasive to
4

constitute an intimidating, hostile and offensive work environment. The conduct included, but was not limited to, repeated requests for sex, inappropriate sexual and gender based comments; and fondling/touching of her breasts and body. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is liable for the sexual harassment. g. Defendant retaliated against Aisha Larry for her refusal to submit to Vincent Lawrence’s unlawful sexual advances and also for filing a charge with the Commission alleging sexual harassment by altering the terms and conditions of her employment, which resulted in Ms. Larry’s constructive discharge. h. Tiffany Bowers was subjected to sexual harassment by Defendant’s owner and President Vincent Lawrence in the form of unwelcome physical and verbal conduct of a sexual nature which was sufficiently severe and pervasive to constitute an intimidating, hostile and offensive work environment. The conduct included, but was not limited to, inappropriate sexual and gender based comments such as:, you are “looking good and thick in your jeans, “I do not lift boxes, I only know how to lift a pair of legs”; and touching of her body. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is liable for the sexual harassment. i. Defendant terminated Tiffany Bowers in retaliation for her opposition to and/ or participation in protected activity against Defendants illegal practices during the pendency of other female employee’s sexual harassment charges with EEOC against the Defendant.
5

j. Other similarly situated individuals were subjected to sexual harassment by Defendant’s owner and President Vincent Lawrence in the form of unwelcome physical and verbal conduct of a sexual nature which was sufficiently severe and pervasive to constitute an intimidating, hostile and offensive work environment. Vincent Lawrence is the Defendant’s alter ego and as such Defendant is vicariously liable for the sexual harassment.
k. Other similarly situated individuals were subjected to retaliation for their opposition to Defendant’s illegal practices
8. The effect of the conduct complained of in paragraph 7 above has been to deprive Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers and other similarly situated individuals of equal employment opportunities and otherwise adversely affect their status as employees because of their gender.
9. The effect of the conduct complained of in paragraph 7 above has been to deprive Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers and other similarly situated individuals of equal employment opportunities and otherwise adversely affect their status as employees in retaliation for opposition to unlawful employment practices.
10. The unlawful employment practices complained of in paragraph 7 above were intentional.
11. The unlawful employment practices complained of in paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Laretha DortchLord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers and other similarly situated individuals
6

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 Defendant, from engaging in sexual harassment, retaliation, and any other employment practice which discriminates on the basis of sex and/or opposition to an unlawful employment practice. B. Order Defendant, to institute and carry out policies, practices, and programs which provide equal employment opportunities for females, and which eradicate the effects of its past unlawful employment practices. C. Order Defendant to make whole Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers and other similarly situated individuals 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 Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers 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, including out of pocket losses in amounts to be determined at trial. E. Order Defendant to make whole Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry, Tiffany Bowers and other similarly situated individuals by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including emotional pain, suffering, inconvenience, humiliation, and loss of enjoyment of life, in amounts to be determined at trial.
7

F. Order Defendant to pay Laretha Dortch-Lord, Kaymi Elder-Manning, Aisha Larry,
Tiffany Bowers and other similarly situated individuals punitive damages for its malicious and
reckless conduct described in paragraph 7 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public
interest.
H. Award the Commission its costs in this action.
JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully Submitted,
JAMES L. LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
DELNER FRANKLIN-THOMAS Regional Attorney
s/Carla J. Von Greiff CARLA J. VON GREIFF Senior Trial Attorney Florida Bar No. 0110566 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 501 East Polk Street Suite 1000 Tampa, Florida 33602 Tel. (813) 228-2020 (direct) Tel. (813) 228-2310 (general) Fax (813) 228-2045
8

 
 IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISIOl'l

UNITED STATES EQUAL EMPLOYMENT OPPORTUl'IITY COMMISSION; LaRETHA DORTCH-LORD; KAYMI ELDER-MA1~NING; TIFFMI BO\VERS; and AlSHA LARRY,

Plaintiffs,

vs.

Case No. 8:05-CV-01832-T-SCB-EAJ

COl'lSOLIDATION RESOURCE CEl'ITER, INC.; and VIl'ICENT LAWRE~CE,

Defendants.
----------------------------------~/
COMPLAINT A.~D DEMMD FOR JURY TRIAL

Plaintiff/Intervenor, AISHA LARRY, sues Defendants, CONSOLIDATIO);

RESOURCE CEKTER, NC.; and VIKCE~T LAVv'RENCE, and alleges the following:

GEl'IERAL ALLEGATIONS

1. Plaintiff, Aisha Larry, resides in Pinellas County, Florida.

2. Defendant, Consolidation Resource Center, Inc. ["CRC"], is a Florida corporation, whose principal place of business is now located at 8800 49th Street North,

Suite 412, Pinellas Park, Florida 33782. 3. At all times material hereto, CRC conducted business at 6251 34th Street

Korth, Suite 201, Pinellas Park, Florida 33781.

4. At all times material hereto, Defendant, Vincent Lawrence, was either the

President or a Co-President ofCRC.

5. At all times material hereto, Defendant, Vincent Lawrence, was a Director

ofCRC.

EXHAUSTION OF ADMNISTRATIVE REMEDIES 6. All conditions precedent have been performed or have occurred. 7. On or about January 9, 2004, Aisha Larry filed a formal charge of employment discrimination with the Equal Employment Opportunity Commission [the "EEOC"], alleging violations of Title VII of the Civil Rights Act of 1964 ["Title VII"] . 8. A tme and correct copy of said charge is attached hereto as Plaintiffs Exhibit "1". 9. On or about Febmary 4,2004, Aisha Larry filed a second formal charge of employment discrimination with the Equal Employment Opportunity Commission [the "EEOC"], alleging violations of Title VII. 10. A tme and correct copy of said charge is attached hereto as Plain6ffs Exhibit "2". 11. The EEOC issued letters of determination on both of the foregoing charges, finding reasonable cause to believed that Title VII had been violated. 12. The EEOC attempted to conciliate both of the foregoing charges both with Aisha Larry and with CRe. 13. After CRC refused to participate m conciliation, the EEOC filed this lawsuit. 14. Aisha Larry properly moved to intervene in this lawsuit within a reasonable time after it was filed, and the Court has granted intervention.
COU='iT I: SEX DISCRIMI~ATIO~ AGAINST CRC 15. Plaintiff incorporates the allegations in paragraphs 1-14 by reference.
2

16. This is a civil action for sex discrimination under 42 U.S.c. § 2000e-2(a) of Title VII.
17. This Court has subject matter jurisdiction over these federal questions under 42 V.S.c. § 2000e-5(f) of Title VII.
18. Aisha Larry is a member of the protected class, because she is female. 19. From October of 2002 until January of 2004, Aisha Larry was employed by CRC as a Loan Specialist Representative; then a Supervisor of Defaults; and then a Loan Specialist Representative. 20. During her employment, Vincent LavvTence was her ultimate supervisor, a President or Co-President of CRC, a Director of CRC, and the alter ego of CRC. 21. During her employment, Vincent La\Hence subjected Aisha Larry to the following unwelcome acts of sex discrimination:
a. Sexual advances in the form of sexual comments; sexual propositions in demanding that she have sex \\lith him; touching her breasts; touching her buttocks; putting his hand dO\vn the front of her skirt; and showing pornographic movies and/or pictures to her in the office;
b. Sexual favoritism towards other female employees who succumbed to his sexual advances;
c. Denial of perks for refusing his sexual advances; and d. Demotion from Supervisor of Defaults back to Loan Specialist Representative and the removal of fringe benefits when she did not succumb to his sexual advances.
3

22. CRC, by and through its agent and alter ego Vincent La\\Tence, is liable for the foregoing sexual harassment of Aisha Larry, because said sexual harassment was sufficiently severe and pervasive to affect the terms, conditions, and/or privileges of her employment.
23. Aisha Larry reported the sexual harassment to CRC's human resources manager, who failed to remediate the violations.
24. Vincent La\\'Tence had sexually harassed female employees at CRC before Aisha Larry.
25. CRC show·ed reckless disregard for Aisha Larry's federally-protected rights under Title VII:
a. by and through the illegal acts of its agent and alter ego Vincent La\\Tence; and
b. by permitting Vincent LawTence to engage in a practice of sexually harassing women in its workplace.
26. In permitting retaliation to occur and to escalate after detailed reports of sexual harassment by Aisha Larry and other women, CRC showed reckless disregard for Aisha Larry's federally-protected rights under Title VII.
27. As a proximate cause of CRC's sex discrimination, Aisha Lan)' has suffered both economic and non-economic damages.
\VHEREFORE, Plaintiff/Intervenor, AISHA LARRY, demands judgment against Defendant, COKSOLIDATIO)l" RESOURCE CEKTER, NC., for the following:
a. back pay under 42 V.S.c. § 2000e-5(g); b. prejudgment interest;
4

c. front pay in lieu of reinstatement;

d. compensatory damages for emotional pam, suffering,

inconvenience, humiliation, and loss of enjoyment of life under 42 U.S.c. § 1981a(a);

e. punitive damages under 42 U.S.c. § 1981a(a);

f.

expert witness fees under 42 U.S.c. § 2000e-5(k);

g. attorney's fees under 42 C.S.C. § 2000e-5(k); and

h. taxable costs.

COUNT II: RETALIATION AGAINST CRC

28. Plaintiff incorporates the allegations in paragraphs 1-14 by reference.

29. This is a civil action for retaliation under 42 V.S.c. § 2000e-3(a) of Title

VII.

30. This Court has subject matter jurisdiction over these federal questions

under 42 C.S.c. § 2000e-5(f) of Title VII.

31. From October of 2002 until January of 2004, Aisha Larry was employed

by CRC as a Loan Specialist Representative; then a Supervisor of Defaults; and then a

Loan Specialist Representative.

32. During her employment, Vincent Lawrence was her ultimate supervisor, a

President or Co-President ofCRC, a Director ofCRC, and the alter ego ofCRC.

33. On or about December 15, 2003, Aisha Larry made verbal and written

reports of sexual harassment by Vincent La\\lTence at CRC to the human resources

manager.

34. On or about January 9, 2004, Aisha Larry filed the EEOC charge at

Plaintiffs Exhibit" 1".

5

35. On or before January 20, 2004, CRC either knew of, or received said EEOC charge.
36. From December 15, 2003 through January 20, 2004, Aisha Larry continued to maintain her allegations of sexual harassment through her ongoing communications to CRC's human resources manager.
37. Aisha Larry is a member of the protected class, both because she participated in protected activity by filing a charge of employment discrimination with the EEOC, and because she opposed unlawful employment practices under Title VII by reporting sexual harassment to management.
38. In violation of 42 U.S.c. § 2000e-3(a), CRC took the following adverse employment actions against Aisha Larry because of her protected participation ami/opposition under Title VII:
a. Lowered her pay rate; and b. Changed her work schedule despite know'ing her child care responsibi lities, which resulted in her constructive discharge on or about January 19-20, 2004. 39. These allegations were memorialized in Aisha Larry's second EEOC charge for retaliation, which is attached hereto as Plaintiffs Exhibit "2". 40. In permitting the retaliation to occur and to escalate after detailed reports of sexual harassment by Aisha Larry and other ,vomen, CRC showed reckless disregard for Aisha Larry's federally-protected rights under Title VII. 41. As a proximate cause of CRC's retaliation, Aisha Larry has suffered both economic and non-economic damages.
6

WHEREFORE, Plaintiff/Intenrenor, AISHA LARRY, demands judgment

against Defendant, CONSOLIDATION RESOCRCE CE)J'TER, IKC., for the following:

a. back pay under 42 U.S.C. § 2000e-5(g);

b. prejudgment interest;

c. front pay in lieu of reinstatement;

d. compensatory damages for emotional pam, suffering,

inconvenience, humiliation, and loss of enjoyment of life under 42 C.S.C. § 1981 a(a);

e. punitive damages under 42 C.S.C. § 1981a(a);

f.

expert witness fees under 42 U.S.C. § 2000e-5(k);

g. attorney's fees under 42 C.S.c. § 2000e-5(k); and

h. taxable costs.

COUNT III: BATTERY AGAIl'"ST VIl'"CE:"l"T LAWREl'"CE

42. Plaintiff incorporates the allegations in paragraphs 1-14 by reference.

43. This is a civil action for battery under Florida common lav,·.

44. This court has subject matter jurisdiction over this pendent state claim

under 28 C.S.c. § 1367(a), because this claim arose from the same series of alleged

transactions and/or occurrences which support the federal questions above.

45. From October of 2002 until January of 2004, Aisha Larry was employed

by CRC as a Loan Specialist Representative; then a Supervisor of Defaults; and then a

Loan Specialist Representative.

46. During her employment, Aisha Larry suffered the following offensive

contacts by Vincent Lawrence:

a. Touching her breasts;

7

b. Touching her buttocks; and c. Putting his hand down the front of her skirt. 47. Vincent Lawrence intended to cause said offensive contacts. 48. In committing said batteries upon Aisha Larry, Vincent LawTence acted with malice, moral turpitude, \villfulness, and/or reckless disregard for her common law rights. 49. As a direct and proximate cause of Vincent Lawrence's offensive contacts, Aisha Larry suffered emotional pain, humiliation, and is entitled to punitive damages. \VHEREFORE, Plaintif£fIntervenor, AISHA LARRY, demands judgment against Defendant, VIKCE)J"T LA\\-'RENCE, for the following: a. compensatory damages for emotional pain and humiliation; b. punitive damages; and c. taxable costs.
DE)llAND FOR JURY TRIAL Plaintiff/Intervenor, AISHA LA.RRY, demands a trial by jury as to all issues under 42 U.S.c. § 1981a(c)(I) of the Civil Rights Act of 1991.
sl Theodore "Ted" E. Karatinos THEODORE "TED" E. KARATINOS PRCGH, HOLLIDAY & KARATINOS, P.L. 1009 West Platt Street Tampa, Florida 33606 (813) 251-3548 (Voice) (813) 251-5809 (Telefax) Florida Bar No. 0983209 tkaratinos@prughlaw.com Counsel for Intervenor, Aisha Larry
8

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 13, 2006, I electronically filed the foregoing "Complaint and Demand for Jury Trial" with the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing to the following: Carla J. Von Greiff, Esq., Senior Trial Attorney, for the United States Equal Employment Opportunity Commission, Tampa Area Office, 501 East Polk Street, Suite 1000, Tampa, Florida 33602; Christie D. Arkovich, Esq., 1520 West Cleveland Street, Tampa, FlOIida 33606; and Patrica A. Pucci, Esq., 2719 First Avenue North, St. Petersburg, Florida 33713.
sl Theodore "Ted" E. Karatinos THEODORE "TED" E. KARATIKOS
9

CHAR'- ~. DISCRIl\flNATION

- ' .-... ~E~NT~ ER C~HA~ RGE~Nil" ltffi" ER '"

.In" Tnis form is affected by the Privacy Al.. .~>/4; see Privacy Act Statement on page 2 ~

~:'

(,fJ FEPA 0401-046

comoleting this fonn.

:. :,Y (..tJ EEOC 15HA400C41

Pinellas Countv Office of Human Rights and EEOC

(Staie orL'oCal Agency, ifany)

NA.\.rIE (Indicate Mr., 1-1s" NlIs.)
l\'Iiss Aisba S. Lar
STREET ADDRESS
2175 62nd Place A t. #1

CITY, STATE A.'J) ZlP CODE
St. Petersbur ,FL 33712

i. H()ME TELEPHONE NO. ('.:ndude kea Cede)
. I 727 864-3238 . .
COUNfY
Pinellas

N..>\..MED IS THE EMPLOYER. LABOR o.RGAAlZATIo.N, EMPLOYMENT AGENCY, APi'RE~ICESHIP COMMlTIEE, STATE OR

Lo.CAL GOVERl'B-IEi'c'T AGENCY WHO. DISCRL\fiNATED AGAINST ME (Ifmore than one list below.)

NA..\dE
ConsolidatiOli.

Resource

Centei

.. " ".; .. :.;'.

;'" NO. OF EMPLOYEESIMEMBERS
15+ '

TEEPHONE NUMBER (Include Area Code)
727528-9829

STREET ADDRESS .
6251 34th St. N Suite #201

. : ~' .~

. -; ; ~ ','

'. . ,~ : ',' ~ ,. . . '

. ;. ' , ',

CITY, STATE AND ZIP CODE .
I Pinellas' Park,'FL'33712 ~~?~ ~ER(Include Area Code)

S1REET ADDRESS '

CITY, STATE AND ZIP CODE '

CAUSE OF D~TION BASED ON (Check appropriate Ix>x(es))

,. ,...

C; RACE C COLOR, J SEX ,D ~~GION . C NATION40RIGDl'

o AGE 0 RETALIATION 0 DISABILITY ,0 OTIIER (Specify)

THE PARTICULARS ARE (Ifadditional space is needed, Ilttach extra sheet(s»):

DATE MOST RECENT OR CONTINUING
DlSCRThnNATION TOOK PLACE (Month, Day, Year)
November 15, 2003

I.

STATh~l OF HARM:

I've been subjected to verbal as well as physical sexual harassment over a five-month period, My employment began at

Consolidation Resource Centeras a Loan.Specialist Representative in October 2002. .

.

11

RESPO~ENT'SREASON FOR ADVERSE ACTION:

No reasen given, .

m. .STATE\1ENT OF DISCRIMINATION:
""IT I believe that I have been discriminated against in violation of Title of the Civil Rights Act of 1964, as amended; the

Florida CivH Rights Act of 1992; Chapter 70 of the Pinellas County Code, as amended on the basis of my i l l for the

followirigreasons:

' ,

. a,' The CEO has verbally as well as physically sexually J1arassed me.

h.. I was promoted to SuperviSorciftheDefault Department at the end of August 2003, After I rejected the CEO's

advances, I was demoted to a'Loan Specialist RepreSentative, This occurred at the end of November 2003 . c. After reporting the sexUal harassment, the Human Resources Manager conducted an investigation and later

informed me that nothing could be done about my claim because my harasser is the CEO.

R~.

C~

CCi 1-.

\~ !

En :J

l~ =; 'r'

JAN 0 9 [ b. ~

OFPICE OF HUM.t..N RlGHTS

PLAINTIFF'S
E\\XHIIB1IT'/

LEANN MCALVERT Notary Public, State of Florida ... '. My comm. expires 04/30/2007
.No. DD 207821

,f, "". )': .r I also v..1Ultthis cbarge.tiloo,withthe.EEOC.: ; ~

! ,.;: .,; ·1 ·. ••~. ~ ',": ', NO.

I will .uJ\.ise the agencies ifI change my address or telephone number and I will ____~~

cooperate fully with thet!l in the processing of my charge in accordance with their ~"L-.~'/.-L~;=-H~o-~=;-,~4.c.c::~~b7':;-~:-:--:--:-~-;---:-I

procedures.

I declare under penalty ofpetjury that the foregoing is true and correct

Date
EEOC FOR..'v{ 5

CHAR(' .! "'CRThflNAnON

{

CHARGE NUMBER

This ferm is affected by the Privacy Act OFi~74;':~J~ Privacy Act Statement on page 2 befoiJ~: ;, : (,fJ FEPA 0402-D55

. this form.

-

-.: (J) EEOC ] 5HA.4D0049

Pinelias Countv Offi~e of Human Rights and EEOC

(State or Local Agency, ifany)

NO. [include Area

STREET ADDRESS

2175 62ml Place

#1

Pinellas
COMl\UTTEE, STATE OR

I.

STATE~:IENl OF HA&\.f:

I was subjected to verbal as well as physical sexual harassment over a five-month period. My employment began at

Consolidation Resource Center as a Loan Specialist Representative in October 2002 and I was forced to resign on

January 20, 2004.

.

.

.

II .

RESPONl)E1'I1'S REASON FOR ADVERSE ACTION:

No reaSon given.

ill. STATEMENT OF DISCRIMJNATION:

I believe that I have been discriminated against in violation of Title VII of the Civil Rights Act of 1964, as amended; the

Florida Civil Rights Act of 1992; Chapter 70 of the Pinellas County Code, as amended on the basis..9~ fQr the

.. following reasoris: .

. '.

.:

.

.L etallatlon

a. .. Women who were willing to participate in the CEO'sadvancemeotswere given better jobs at a higher rate of

pay: .
was b. Because I didn't accept the advances, I demoted, which therefore resulted in a pay cut.

c. After reporting the sexual harassment in December 2003 with my Human Resources Department, I was forced

to resign on January 2.0, 2004 due to the retaliatory change hI my work schedule.

'H,,-{:-:

C;"•:.l"Iv!

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Dr

FEB 0 {; '.'.(,.-,

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J EXHIBIT \\ 2. //
I

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charge

. i ~ .. ::' ' :, '.. : : '.:; . . '. " ,

,,,ill r wil1 ad....~se the agencies if I change" my add!-css or tel~hOt!e numOef and I

cooperate fully with them in the processing of my charge in accordance with their

p.ocedures.

r declere under

15 In!e and correct.

2-4-0Lj
Datil
EEOC FO&\;15

JENNIFER MAGGARD MY COMMISS:CN II DO G€6954
EXPIRES: ~ober23, 2005
and Local Requirements)
..' -.' ::: .
charge and that it is true to the best

 
 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

LARETHA DORTCH-LORD, an individual, KAYMI ELDER-MANNING, an individual, AND TIFFANI BOWERS, an individual,
Intervening Plaintiffs, v.

CIVIL ACTION NO: 8:05-CV-01832-SCB-EAJ

CONSOLIDATION RESOURCE DEMANDED CENTER, INC., and SOUGHT VINCENT LAWRENCE, an individual,

JURY TRIAL INJUNCTIVE RELIEF

Defendants. /

COMPLAINT OF INTERVENTION BY LARETHA DORTCH-LORD, KAYMI ELDER-MANNING, AND TIFFANI BOWERS

JURISDICTION AND VENUE 1. This is an action for monetary damages, declaratory and injunctive relief, and for other equitable and ancillary relief. Jurisdiction of this Court is invoked pursuant to 28 USC §§451, 1331, 1337,1343, 1345 and 1367. 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 USC §2000e-5(f)(1) and (3) (“Title VII”) and Section 102 of the Civil Rights Act of 1991, 42 USC §1981A; under the Florida Civil Rights Act of 1992, §§760.01 to 760.11 Fla. Stats.; and under the common law of Florida.

1

2. All actions alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Middle District of Florida.
PARTIES 3. Plaintiff, LaRetha Dortch-Lord, is a female resident of Pinellas County,
Florida. 4. Plaintiff, Kaymi Elder-Manning, is a female resident of Pinellas County,
Florida. 5. Plaintiff, Tiffani Bowers, is a female resident of Pinellas County,
Florida. 6. At all times relevant to this Complaint, Defendant, CRC, a Florida corporation, has continuously been doing business in Pinellas County, Florida and has continuously employed at least 15 employees. 7. At all times relevant to this Complaint, Defendant CRC has continuously been an employer engaged in an industry affecting commerce within the meaning of §§ 701(b), (g) and (h) of Title VII, 42 USC §§2000e(b), (g) and (h). 8. Defendant, Vincent Lawrence, is a male resident of Pinellas County, Florida.
STATEMENT OF CLAIMS GENERAL ALLEGATIONS 9. Plaintiff, Kaymi Elder-Manning, was hired as an employee by CRC in February 2002. 10. Plaintiff, Kaymi Elder-Manning, was a college loan processor at CRC in July 2003.
2

11. Plaintiff, LaRetha Dortch-Lord, was hired as an employee by CRC in April 2002.
12. Plaintiff, LaRetha Dortch-Lord, was a loan specialist at CRC in July 2003.
13. Plaintiff, Tiffani Bowers, was hired as an employee by CRC in June 2002.
14. Plaintiff, Tiffani Bowers, performed services for CRC as a receptionist and a loan officer.
15. Dortch-Lord, Elder-Manning and Bowers personally worked at the CRC offices with CRC’s owner, chief executive officer and President, Vincent Lawrence.
16. Dortch-Lord, Elder-Manning and Bowers and other female employees at CRC were personally subjected to and/or personally witnessed ongoing sex discrimination and sexual harassment by CRC’s chief executive officer, Vincent Lawrence, toward CRC’s female employees including Lawrence’s:
a) unwelcome hugging, b) asking female employees to spend time with him outside the office, c) asking female employees to go out on dates with him, d) touching and brushing against female employees’ breasts including
Ms. Dortch-Lord and Ms. Elder-Manning, e) grabbing female employee’s bottoms, f) asking Ms. Dortch-Lord if he could see her pregnant stomach, g) telling Ms. Dortch-Lord that they could “go out” after she “dropped
the load” (had her baby), h) telling Ms. Dortch-Lord that she had a “pretty ass voice” and “pretty
ass eyes”,
3

i) looking at Ms. Dortch-Lord’s breasts and asking if her baby was nursing, saying that he was sure that her baby wouldn’t mind if he shared with the baby – that he “could be on one and the baby on the other”,
j) asking Ms. Dortch-Lord if she was going to get her “tubes tied” after her child was born,
k) responding to Ms. Dortch-Lord that she needed to be “home with your kids” and that her husband should “work extra hours” when asked if she could work extra hours and visit colleges to promote CRC’s business,
l) telling Ms. Elder-Manning if she were “his woman” he would “take care of” her,
m) telling Ms. Elder-Manning that he wanted to feel her legs wrapped round him,
n) saying to Ms. Elder-Manning that he believed she might do “it” (referring to sex) better than his wife,
o) telling Ms. Dortch-Lord’s co-employees that he was the father of one of her children,
p) saying to female employees while walking the hall at work, “you’ve got that shaking” while he is watching their behinds,
q) commenting on Ms. Bowers underwear by asking, “Are those thong tha thong thong thongs?”,
r) telling a pregnant Ms. Bowers that he liked women who are pregnant because the “stuff” is better because it is real wet (Ms. Bowers knew he was referring to something sexual),
4

s) rubbing Ms. Bowers’ stomach and asking if she was going to “work that off”,
t) yelling at a business meeting in January 2003 that he was “sick of this shit”, he was tired of the rumors of him “screwing” women at CRC and saying “you don’t know how many women I am supposedly “screwing””,
u) commenting at work that his daughter, CRC employee Jocelyn, had a “booty” just like Jennifer Lopez,
v) saying to Ms. Bowers, “You’re looking good in those jeans.”, “You’re looking “thick” and calling her ”thicky-thick”,
w) saying to Ms. Bowers, “I don’t lift boxes, I only know how to lift a pair of legs” when Ms. Bowers asked his assistance in carrying some boxes,
x) saying a female manager had a “big donkey booty”, y) having female employees sit on his lap during working hours, and z) referring to female employees as his “whores”.
17. Plaintiff, LaRetha Dortch-Lord, dual-filed a Charge of Discrimination against CRC with the Equal Employment Opportunity Commission (“EEOC”) and the Florida Commission on Human Relations (“FCHR”) on June 23, 2003 providing information about the unlawful sex discrimination and sexual harassment which she and other female employees were being subjected to by CRC and CRC’s owner Vincent Lawrence.
18. On July 24, 2003, Plaintiff, Kaymi Elder-Manning, was called into a meeting with CRC’s Human Resources representative Joanne Etienne and CRC supevisor Carol Lucas to talk about Vincent Lawrence.
5

19. CRC management was aware of LaRetha Dortch-Lord’s EEOC Charge as of July 24, 2003.
20. At the July 24, 2003 meeting, Kaymi Elder-Manning was asked to sign a document regarding discrimination. The wording in the document indicated that Ms. Elder-Manning felt everything was “okay” at CRC.
21. Ms. Elder-Manning was told that her job was safe and she would not be fired for not signing the document presented to her.
22. Ms. Elder-Manning refused to sign the document offered to her by Etienne telling CRC management that she did not agree that everything was “okay” at CRC.
23. Ms. Elder-Manning told CRC management that she wanted to talk to the EEOC and that she wanted to tell the EEOC the truth about Lawrence.
24. Approximately 9 employees were “laid off” by CRC on Friday, July 25, 2003 including Raymon Anderson, Chuck Youngren, Sheldon Gibson, Shirley Presley, Deondra Sanchez, Ann Mendleson, Craig Hester, Demetrius Lowe, and LaRetha Dortch-Lord.
25. Kaymi Elder Manning was not at work on July 25, 2003. She returned to work on Monday, July 28th. Ms. Elder-Manning was “laid off” on July 28, 2003.
26. Sheldon Gibson, Deondra Sanchez, Ann Mendleson, Raymon Anderson, Shirley Presley and Chuck Youngren returned to work for CRC after Ms. ElderManning left, and before the end of the work day, on July 28, 2003.
27. Ann Mendleson and Raymon Anderson went to work at CRC on July 28, 2003 to work the night shift.
28. On January 12, 2004, CRC’s HR representative Joanne Etienne asked to see Tiffani Bowers.
6

29. As part of the investigation and response to Ms. Dortch-Lord’s EEOC Charge, Etienne asked Ms. Bowers to sign a document indicating that she had been through sexual harassment training at CRC in 2003.
30. Ms. Bowers stated that she remembered attending only one session in 2002 and Ms. Bowers agreed to sign a statement regarding this but to properly date it as being given in 2002.
31. Etienne tried to convince Ms. Bowers she had been in training on a specific date in 2003. Ms. Bowers pointed out to Etienne that Bowers had been on maternity leave on the date given by Etienne.
32. Ms. Bowers continued to refuse to fraudulently misrepresent her participation in any harassment training in 2003.
33. On January 12, 2004, Etienne told Ms. Bowers that she could attend another sexual harassment class at a later date.
34. Ms. Bowers was fired on January 13, 2004. 35. Lawrence and CRC’s HR Director, Joanne Etienne, were friends outside of work. They talked about inappropriate subjects while at the CRC offices and with other CRC employees. 36. Lawrence and Etienne would walk through the halls arm in arm. 37. Etienne had commented once that she wouldn’t accept any discrimination complaints from CRC employees. 38. Many CRC employees were not comfortable going to Etienne with any claims of harassment. 39. At all times material to this Complaint, Plaintiffs were qualified for the positions they held. 40. Female employees at CRC who returned Lawrence’s advances and
7

allowed him to touch them were promoted and had their pay increased. 41. At all times relevant to this Complaint, Defendant, Lawrence, served as
CRC’s owner, chief executive officer and President. COUNT I
Title VII Discrimination and Harassment Based on Sex Against CRC
42. Plaintiffs repeat and reallege paragraphs 1 through 41 as though fully set forth here.
43. Plaintiff, LaRetha Dortch-Lord, timely filed a Charge of Discrimination against CRC with the EEOC on June 23, 2003 alleging harassment and discrimination based on sex. A copy of the Charge is attached as Exhibit “A”.
44. Plaintiff, LaRetha Dortch-Lord, timely filed a second Charge of Discrimination against CRC with the EEOC on August 6, 2003 alleging retaliation. A copy of the Charge is attached as Exhibit “B”.
45. Plaintiff, Kaymi Elder-Manning, timely filed a Charge of Discrimination against CRC with the EEOC through the Pinellas County Office of Human Rights on September 11, 2003 alleging harassment and discrimination based on sex and retaliation. A copy of the Charge is attached as Exhibit “C”.
46. Plaintiff, Tiffani Bowers, timely filed a Charge of Discrimination against CRC with the EEOC through the Pinellas County Office of Human Rights on April 23, 2004 alleging harassment and discrimination based on sex and retaliation. A copy of the Charge is attached as Exhibit “D”.
8

47. The EEOC issued Determinations on all of Plaintiffs’ Charges stating that the Commission “finds reasonable cause to believe that [CRC] violated TitleVII of the Civil Rights Act of 1964”.
48. On August 11 and 25, 2005, the EEOC issued letters to the Plaintiffs notifying them that their Charges had been referred to the EEOC’s Legal Unit, and that the Plaintiffs could intervene in any civil action brought by the EEOC based on Plaintiffs’ Charges.
49. The EEOC filed a lawsuit with the court based on the Plaintiffs Charges on September 30, 2005.
50. The Plaintiff’s filed a Motion to Intervene in the EEOC action. 51. Since at least February 2002, Defendant CRC engaged in unlawful employment practices in violation of Title VII. 52. The unlawful acts and employment practices complained of in paragraph 16 were done with intent, malice and with reckless indifference to the rights of Plaintiffs. 53. At all times relevant to this Complaint Lawrence acted as CRC’s alter
ego. 54. CRC and Lawrence subjected Plaintiffs to an intimidating and hostile work environment permeated with sexual favoritism toward female employees who succumbed to Lawrence’s sexual advances.
9

55. CRC and Lawrence subjected Plaintiffs to sexual harassment in the form of unwelcome physical and verbal conduct of a sexual nature which was severe and pervasive.
56. CRC and Lawrence subjected Plaintiffs to conduct including inappropriate sexual, and gender based, comments and touching.
57. Lawrence’s and CRC’s discriminatory and harassing activities were ongoing and took place on a daily basis.
58. Lawrence and CRC management engaged in a pattern and practice of discriminatory activities toward Plaintiffs.
59. CRC and Lawrence treated Plaintiffs’ adversely for their refusal to submit to Lawrence’s advances, including job termination.
60. As a proximate result of Defendants’ unlawful conduct complained of in this Complaint, Plaintiffs have been deprived of equal employment opportunities and otherwise had their status as employees adversely affected because of their gender.
61. As a proximate result of Defendants’ unlawful conduct complained of in this Complaint, Plaintiffs have suffered and continue to suffer substantial losses in seeking subsequent comparable employment, earnings, deferred compensation, earning capacity, back pay, front pay, other employment benefits, and other damages all to their detriment, in an amount to be shown according to proof.
62. As a proximate result of Defendants unlawful conduct, Plaintiffs have suffered and continue to suffer emotional pain, loss of enjoyment of life and humiliation all to their detriment, in an amount to be shown according to proof.
10

63. Plaintiffs are entitled to recover reasonable attorneys’ fees and costs of their suit as provided by law in an amount to be shown according to proof.
COUNT II Title VII Retaliation
Against CRC
64. Plaintiffs repeat and reallege paragraphs 42 through 63 as though fully set forth here.
65. Plaintiff, LaRetha Dortch-Lord, filed her first Charge of Discrimination with the EEOC on June 23, 2003 initiating an investigation and objecting in good faith to the unlawful sex discrimination and sexual harassment which she and other female employees were being subjected to by Defendant CRC and CRC’s owner and President.
66. Plaintiff, Kaymi Elder-Manning, objected in good faith to the unlawful sex discrimination and sexual harassment at CRC and refused to misrepresent facts to the EEOC as part of an investigation of the Charge filed by Ms. Dortch-Lord.
67. Plaintiff, Tiffani Bowers, objected in good faith to the unlawful sex discrimination and sexual harassment at CRC and refused to misrepresent facts to the EEOC as part of an investigation of the Charge filed by Ms. Dortch-Lord.
68. CRC management, Joanne Etienne, Nichole Coates, Naomi Barbeau, Vincent Lawrence, and Doug Lang were present for a loan processing meeting after CRC had gotten the information about Ms. Dortch-Lord’s first Charge of Discrimination. Vincent Lawrence said to Joanne Etienne during the meeting, “I have some funny shit for you to read” referring to Ms. Dortch-Lord’s Charge.
11

69. As a result of Plaintiffs’ good faith refusal to participate in discriminatory activity, Defendant CRC engaged in unlawful retaliatory personnel actions by terminating Plaintiffs’ employment.
70. As a result of Plaintiffs’ good faith objections and complaints of sex discrimination and sexual harassment, Plaintiffs’ desire to share truthful information with the EEOC, and Plaintiffs’ refusal to create false statements, Defendant CRC engaged in unlawful retaliatory personnel actions including termination of Plaintiffs’ employment.
71. The effects of the conduct complained of in this Complaint have been to deprive Plaintiffs of equal employment opportunities and adversely affect their status as employees in retaliation for opposition to unlawful employment practices and participation in an investigation of such practices.
COUNT III Florida Civil Rights Act Discrimination and Harassment Based on Sex
Against CRC
71. Plaintiffs repeat and reallege paragraphs 1 through 41 above as though fully set forth here.
72. All conditions precedent to the bringing of this action have been fulfilled.
73. Plaintiffs filed Charges of Discrimination against CRC with the Equal Employment Opportunity Commission alleging harassment and discrimination based on sex and retaliation.
12

74. Plaintiffs’ Charges were timely dual-filed with the Florida Commission on Human Relations (“FCHR”) as follows: LaRetha Dortch-Lord’s Charges were filed on June 23, 2003 and August 7, 2003; Kaymi Elder-Manning’s Charge was filed on August 14, 2003; Tiffani Bowers Charge was filed on April 26, 2004. Copies of the Charges with the date stamps from the FCHR are attached as Exhibits “E”, “F”, “G”, and “H”.
75. More than 180 days have passed between the date of the Charges filed by Plaintiffs with the FCHR and the filing of this Complaint.
76. Since at least February 2002, Defendant CRC engaged in unlawful employment practices in violation of the Florida Civil Rights Act (“FCRA”).
77. The unlawful acts and employment practices complained of in paragraph 16 were done with malice and with reckless indifference to the rights of Plaintiffs.
78. At all times relevant to this Complaint Lawrence acted as CRC’s alter ego.
79. CRC and Lawrence subjected Plaintiffs to an intimidating and hostile work environment permeated with sexual favoritism toward female employees who succumbed to Lawrence’s sexual advances.
80. CRC and Lawrence subjected Plaintiffs to sexual harassment in the form of unwelcome physical and verbal conduct of a sexual nature which was severe and pervasive.
81. CRC and Lawrence subjected Plaintiffs to conduct including inappropriate sexual, and gender based, comments and touching.
13

82. Lawrence’s and CRC’s discriminatory and harassing activities were ongoing and took place on a daily basis.
83. Lawrence and CRC management engaged in a pattern and practice of discriminatory activities toward Plaintiffs.
84. CRC and Lawrence treated Plaintiffs’ adversely for their refusal to submit to Lawrence’s advances, including job termination.
85. As a proximate result of Defendants’ unlawful conduct complained of in this Complaint, Plaintiffs have been deprived of equal employment opportunities and otherwise had their status as employees adversely affected because of their gender.
86. As a proximate result of Defendants’ unlawful conduct complained of in this Complaint, Plaintiffs have suffered and continue to suffer substantial losses in seeking subsequent comparable employment, earnings, deferred compensation, earning capacity, back pay, front pay, other employment benefits, and other damages all to their detriment, in an amount to be shown according to proof.
87. As a proximate result of Defendants unlawful conduct, Plaintiffs have suffered and continue to suffer emotional pain, loss of enjoyment of life and humiliation all to their detriment, in an amount to be shown according to proof.
88. Plaintiffs are entitled to recover reasonable attorneys’ fees and costs of their suit as provided by law in an amount to be shown according to proof.
COUNT IV Florida Civil Rights Act Retaliation
Against CRC
14

89. Plaintiffs repeat and reallege paragraphs 71 through 88 as though fully set forth here.
90. Plaintiff, LaRetha Dortch-Lord, dual-filed her first Charge of Discrimination with the EEOC and FCHR on June 23, 2003 initiating an investigation and objecting in good faith to the unlawful sex discrimination and sexual harassment which she and other female employees were being subjected to by Defendant CRC and CRC’s owner and President.
91. Plaintiff, Kaymi Elder-Manning, objected in good faith to the unlawful sex discrimination and sexual harassment at CRC and refused to misrepresent facts to the EEOC as part of an investigation of the Charge filed by Ms. Dortch-Lord.
92. Plaintiff, Tiffani Bowers, objected in good faith to the unlawful sex discrimination and sexual harassment at CRC and refused to misrepresent facts to the EEOC as part of an investigation of the Charge filed by Ms. Dortch-Lord.
93. CRC management, Joanne Etienne, Nichole Coates, Naomi Barbeau, Vincent Lawrence, and Doug Lang were present for a loan processing meeting after CRC had gotten the information about Ms. Dortch-Lord’s first Charge of Discrimination. Vincent Lawrence said to Joanne Etienne during the meeting, “I have some funny shit for you to read” referring to Ms. Dortch-Lord’s Charge.
94. As a result of Plaintiffs’ good faith refusal to participate in discriminatory activity, Defendant CRC engaged in unlawful retaliatory personnel actions by terminating Plaintiffs’ employment.
95. As a result of Plaintiffs’ good faith objections and complaints of sex
15

discrimination and sexual harassment, Plaintiffs’ desire to share truthful information with the EEOC, and Plaintiffs’ refusal to create false statements, Defendant CRC engaged in unlawful retaliatory personnel actions including termination of Plaintiffs’ employment.
96. The effects of the conduct complained of in this Complaint have been to deprive Plaintiffs of equal employment opportunities and adversely affect their status as employees in retaliation for opposition to unlawful employment practices and participation in an investigation of such practices.
COUNT V Negligent Retention and Supervision
Against CRC 97. Plaintiffs repeat and reallege paragraphs 1 through 41 as though fully set forth here. 98. CRC negligently supervised and retained its employee, Lawrence, resulting in Plaintiffs being the victim of discrimination, sexual harassment, battery, and retaliation during their employment. 99. CRC negligently supervised and retained its employee, Joanne Etienne, resulting in Plaintiffs being the victim of discrimination, sexual harassment, battery, and retaliation during their employment with no avenue to effectively report said treatment. 100. CRC breached its duty to put someone in place at the CRC workplace to effectively monitor the treatment of CRC’s employees. 101. CRC breached its duty to discipline or remove Lawrence for actions constituting discrimination, sexual harassment, battery, and retaliation under Federal
16

and Florida law, and to have effective policies, procedures, and training concerning these matters.
102. Lawrence’s unlawful activities were rampant and visible to all levels of CRC management including CRC’s co-owner Doug Lang.
103. CRC knew or should have known Lawrence was predisposed to such conduct. At least two CRC employees, other than Plaintiffs, raised issues of discrimination and harassment at CRC prior to any claims raised by Plaintiffs.
104. CRC became aware, or should have become aware, of problems with Lawrence’s treatment of female employees and his unfitness but failed to take reasonable actions to correct the situation, such as investigating issues, reassigning employees or removing Lawrence.
105. Plaintiffs have suffered damages as a direct and proximate result of CRC’s failure to properly take reasonable actions to correct the situation.
COUNT VI Battery
Against CRC and Lawrence 106. Plaintiffs repeat and reallege paragraphs 1 through 41 as though fully set forth here. 107. Lawrence intended to touch Plaintiffs’ persons. 108. Lawrence actually touched the Plaintiffs. 109. The touching by Lawrence on Plaintiffs was unwanted, harmful and offensive and done against Plaintiffs’ will. 110. Lawrence’s actions were willful, wanton and in reckless disregard of
17

Plaintiffs’ rights.
111. The contact by Lawrence directly or indirectly caused Plaintiffs to suffer
damages.
112. CRC was negligent and reckless in allowing Lawrence’s actions.
113. Lawrence’s unlawful touching of Plaintiffs was aided by an agency
relationship between Lawrence and CRC.
Prayers For Relief
WHEREFORE, Plaintiffs demand judgment for Plaintiffs and against Defendant
Consolidation Resource Center, Inc.:
(a) Enjoining discrimination in the future on the basis of an employee's protected activity;
(b) Awarding front pay; (c) Awarding back pay and other economic damages including loss of
employment-related benefits; (d) Awarding compensatory damages for emotional pain, loss of enjoyment
of life and humiliation; (e) Awarding punitive damages; (f) Awarding Plaintiffs interest, and their reasonable attorney fees, expert
fees and costs of this action; (g) Awarding such other equitable relief allowed by law, and (h) Awarding such other relief as this Court deems appropriate.
WHEREFORE, Plaintiffs demand judgment for Plaintiffs and against Defendant
Vincent Lawrence:
(a) Awarding compensatory damages for emotional pain, loss of enjoyment of life and humiliation;
(b) Awarding punitive damages; (c) Awarding costs of this action; and (d) Awarding such other relief as this Court deems appropriate.
18

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 13, 2006 , I electronically filed the foregoing COMPLAINT OF INTERVENTION BY LARETHA DORTCH-LORD, KAYMI ELDER-MANNING, AND TIFFANI BOWERS with DEMAND FOR JURY TRIAL and INJUNCTIONwith the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing to Carla J. Von Greiff, Esq., Senior Trial Attorney, for the United States Equal Employment Opportunity Commission, Tampa Area Office, 501 East Polk Street, Suite 1000, Tampa, Florida 33602; Christie D. Arkovich, Esq., Attorney for Consolidated Resource Center, Inc., 1520 West Cleveland Street, Tampa, FL 33606; and Theodore Karatinos, Attorney for Aisha Larry, 1009 West Platt Street, Tampa, FL 33606, and that I believe there are no non-CM/ECF participant’s involved in this lawsuit.
Demand for Jury Trial Plaintiffs demand a trial by jury on all issues so triable.
Respectfully submitted,
_s/Patrice A. Pucci_________ PATRICE A. PUCCI, Esquire Patrice A. Pucci, P. A. Florida Bar No. 521991 2719 1st Avenue North St. Petersburg, FL 33713 (727)894-4516 Telephone (727)321-2839 Facsimile
ATTORNEY FOR INTERVENING PLAINTIFFS, LARETHA DORTCHLORD, KAYMI ELDER-MANNING, AND TIFFANI BOWERS
19

 
 IN THE UNITED STATES DISTRICT COURT FOR THE MlDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES EQUAL EMPLOYMENT )

OPPORTUNITY COMMISSION,

1

Plaintiff,

)

and

)

1

AISHA LARRY;LARETHA DORTCH LORD; )

TIFFANI BOWERS AND KAYMl

)

ELDER-MANNING,

)

Intervenor-Plaint iffs.

)

v.

1

)

CONSOLUIATION RESOURCE CENTER, INC. 1

Defendant.

1

1

AISHA LARRY;LARETHA DORTCH LORD; )

TIFFANI BOWERS AND

)

KAYMI ELDER-MANNING

1

Plaintiffs,

)

)

v.

1

)

VINCENT LAWRENCE,

)

Defendant.

1

CIVIL ACTION NO.: 8:05-CV-01832-SCB-EAJ

1. This Consent Decree (the "Decree") is made and entered into by and between Plaintiff, the Equal Employment Opportunity Commission (hereinafter referred to as the "Commission" or "EEOC"), Plaintiff-Intervenors Laretha Dortch-Lord, Kayrni Elder-Manning, Aisha Larry, Tiffini Bowers, and Defendant, Consolidation Resources Center Inc. (hereinafter referred to as the "Company or "Defendant"). The Commission, Plaintiff-Intervenors and ConsolidationResources Center h c . are collectively referred to herein as "the Parties."

2. On September 30, 2005, EEOC initiated this action by filing its Complaint in the United States District Court fbr the Middle District of Florida, Civil Action No.8:05-CV-01832SCB-EAJ,based upon chargesfiledby Laretha Dortch-Lord(EEOCChargesNo.'s 150-2003-01564; 150-2003-01816), (EEOC ChargeNo. 15H-A4-00025),Aisha Larry (EEOC ChargeNo.'s 15H-A400041;15H-A4-00049),and Tiffani Bowers(EE0CChargeNo.15H-A4-00079). EEOC's Complaint allegesthat Defendant violatedTitle VIl of the Civil Rights Act of 1964,as amended, including but not limited to, amendments authorized by the Civil Rights Act of 1991,42 U.S.C. Section 2000e
et seq. ("Title VIP') by subjectingMs. Dortch-Lord, Ms. Elder Manning, Ms. Lanyand Ms. Bowers
to sexual harassment by the co-owner and co-President of the Defendant corporation which was sufficiently seveR and pervasive to constitute a hostile, intimidating work environment. The Complaintfurtherallegesthat Defendant subjectedMs. Dortch-Lord,Ms. Elder Manning, Ms. Larry and Ms. Bowers to retaliation for engaging in protected activity by discharging them fiom their employment.
3. On January 8,2006, Laretha Dortch-Lord, Kaymi Elder-Manning,Aisha Lany and Tiffani Bowers intervened in this action and brought claims of sexual harassment and retaliation under Title VII and under the Florida Civil Rights Act of 1992, Section 760.01 el. seq., Fla. Stat. (1997) ("FCRA);and also brought several other state causes of action.
4. Defendant denies the allegations raised in the Complaints filed by EEOC and Plainti ff-Intervenors.
5. In the interests of resolving this matter and as a result of having engaged in comprehensive settlement negotiations, the Parties have agreed that this action should be finally resolved by entry of this Decree. ThisDecree is final and binding upon the Parties, their successors,

affiliates and assigns. 6. The Parties agree that this Decree resolves all claims alleged against the Defendant
in EEOC ChargeNumbers 150-2003-01564; 150-2003-01816; 15H-A4-00025;15H-A4-00041;15HA4-00049 and15H-A440079 and the Complaints filed in this action.
7. NOW, THEREFORE, the Court having carehllyexamined the terms and provisions of this Decree, and based on the pleadings filed by the parties, it is ORDERED, ADJUDGED AND DECREED THAT:
JURISDICTION 8. This Court has jurisdiction of the subject matter of this.action and over the Parties for the purposes of entering and enforcing this Decree. 9. No party shall contest jurisdiction of this federal court to enforce this Decree and its terms or the right of the EEOC to seek enforcement in the event Defendant breaches any of the terms of this Decree.
GENERAL PROVISIONS 10. Defendant, its officers, employees, and its successors, affiliates and assigns are hereby enjoined from engaging in conduct which violates Title VII of the Civil Rights Act of 1964, as amended, by adversely affecting the terms and conditions of any individual's employment because of their gender. 1 1 . Defendant, its officers, employees, and its successors, affiliates and assigns are hereby enjoined from discriminating against any employee who opposes any of Defendant's practices which the employee believes to be unlawfd employment discrimination, who files a charge of discrimination with the EEOC alleging violation(s) of such statute; who cooperates with

the EEOC in the investigation andlor prosecution of any charge of discrimination; or who cooperated in the investigation or prosecution of this case.
DISCRIMINATION POLICY AND TRAINING
12. Defendant will adopt a written policy against sexual harassment by November 30, 2006 to be submitted to EEOC for review and approval. If within thirty (30) days of Defendant's submission,EEOC and Defendant have not reached agreement on the policy, the parties will submit to the Court for resolution. Defendant agrees that all of its employees and managers will be provided a complete copy of its policy against sexual harassment within fifteen (15) days of final adoption of the policy. D e h d a n t also agrees that all new employees shall be given a copy of its policy against sexual harassment within their first week of employment with the Defendant.
13 In order to fkrther ensure the effective implementation of Defendant's antidiscriminationpolicy, Defendantwill conducta three (3)hour annual training for all of its managers and supervisory personnel with specific emphasis on recognizing harassment, on acts that could constitute retaliation, and on the proper procedure to be followed if they become aware of harassment in the workplace or if they receive complaints of discrimination. Defendant agrees to provide the EEOC, at least two weeks notice before it conducts its training session(s), with the date(s) and location(s) of the training, the identification of the training materials to be used at the training session, and a general description of the category of employees who will be in attendance at the training. The trainingwill be conducted by an individual selected by Defendant's counsel and approved by EEOC. Additionally, Defendant agrees that the EEOC shall, at the EEOC's discretion, be in attendance at each training session(s).
14. Defendant agrees that co-President Vincent Lawrence will be present at each and

every training conducted pursuant to this paragraph for the entire duration of the training. 15. Defendant agrees that the training described in paragraph 13 shall be conducted
within sixty (60) days of the entry of this Decree. An4 should thereafter take place annuallyin the same format, by November 30, for the duration of this Decree. Defendant further agrees that the discriminationpolicy and training materials utilized forthe trainingdescribed inparagraph 13shall be presented to and explained to all new managers and supervisors, who did not attend the annual training, within thirty (30) days of being placed in a management or supervisoryposition.
POSTING 16. Defendant will post a laminated 11 x 14 copy of the Notice, attached as Exhibit A, no later than November 30,2006. Said notice shall be posted at Defendant's Pinellas Park office for the duration of this Decree in a conspicuous location accessible to all employees such as an employee bulletin board andlor break/lunch room.
MONITORING 17. Defendantwill retain all employmentandlorinvestigativerecords relatingin anyway to any complaint or allegation of harassment for the duration of this Decree and as required under federal law.
18. Defendant will certify to the EEOC semi-annually throughout the duration of this
Decree that it is in compliance with all aspects of this Decree. The first such certification will be due no later than thirty(30) days from the first haining provided pursuant to paragraph 13. With each certification Defendant will firther provide the EEOC with the name, address, and phone number of any person who alleges they have been harassed while working for Defendant during the preceding six month period Defendant will also state the actions taken in response to each such

allegationand provide anyand alldocumentationassociatedwith such complaint. Thecertifications required to be submitted to the EEOC pursuant to this Consent Decree shall be mailed with the notation CONSOLIDATION RESOURCE CENTER, INC. to: United States Equal Employment Opportunity Commission, Attention: Office of the Regional Attorney, 1 Biscayne Tower, Suite 2700,2 South Biscayne Boulevard, Miami, F133131.
MONETARY RELIEF
19. Defendant agreesto pay a total amount of $l8O,OOO.OO to resolvethis litigation. The payments referenced herein shall issue within fifteen (15) calendar days of the Court's execution of this Decree and be distributed as set forth below in Exhibit B attached hereto.
20. If Defendant fails to tender the abovementioned payments as set forth in paragraph 19above and Exhibit B, then Defendant shall pay interest on the defaultedpayment at the rate calculated pursuant to 26 U.S.C. Section 6621(b) until the same is paid, and bear any additional costs incurred by the EEOC caused by the noncompliance or delay of the Defendant.
ENFORCEMENT OF DECREE
21. The Commission shall have independent authorityto seek the judicial enforcement of any aspect, term or provision of this Decree.
COSTS 22. Each Party shall bear its own costs associated with this litigation.
DURATION OF CONSENT DECREE
23. The duration of this Decree shall be two (2) years fiom the date of entry of the Decree.
24. The Court will take whatever measures necessary to effectuate the terms of this

Decree.
SO ORDERED, ADJUDGED AND DECREED, this ft day of November, 2006.

+ ,/-)

n
G>U'

!

SUSAN BUCKLEW UNFED STATES DISTRICT JUDGE

AGREED TO: FOR THE PLAINTIFF, UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

by: s/ Gre~orvGochanour

Date: October 31,2006

Gregory Gochanow

Acting Regional Attorney

U.S.EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Miami District Office

One Biscayne Tower, Suite 2700

2 South Biscayne Boulevard

Miami, Florida 33131

Telephone: (305) 530-6001

Facsimile: (305) 536-4494

AGREED TO: FOR PLAINTIFF INTERVENORS DORTCH-LORD, ELDER-MANNING AND BOWERS

by: s/Patrice A. Pucci

Date: October 31, 2006

Patrice A. Pucci

Florida Bar No. 521991

Attorney for Intervenors Dortch-Lord, Elder-Manning and Bowers

Patrice A. Pucci, P.A.

27 19 1" Avenue North

St. Petersburg, Florida 33713

Telephone. (727) 894-4516

Facsimile: (727) 3 1-3829

AGREED TO: FOR PIAINTJFF INTERVENOR LARRY
by: S/' E. Karatinos Date: October 31,2006
Theodore ' T e d E. Karatinos Florida Bar No. 0983209 Attorney for Intervenor Larry
Holliday, Bornhoff and Karatinos. P.L.
5327 Commercial Way Suite D- 122 Spring Hill, Florida 34606 Telephone. (813) 868-1887 Facsimile: (352) 597-8600

AGREED TO: FOR THE DEFENDANT: CONSOLIDATION RESOURCES CENTER, INC.

by: sfChristieArkovich

Date: October 31,2006

Christie D. Arkovich

Florida Bar No. 963690

Attorney for Defendant

Law Offices of Christie Arkovich

1520 West Cleveland Steet

Tampa, Florida 33606

Telephone. (813) 258-2808

Facsimile: (813) 258-591 1

AGREED TO: FOR THE DEFlENDANT: CONSOLIDATION RESOURCES CENTER. INC
CO-president,ons sol hat ion Resources Center, lac.
AORIEED TO: FOR THE DEFENDANT:
CONSOLIDATION RESOURCES CENTER, INC
Co-President, Consolidation Resounxs Center, Inc.

EXHIBIT A NOTICE TO ALL EMPLOYEES POSTED PURSUANT TO A CONSENT DECREE BETWEEN THE UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION AND CONSOLIDATION RESOURCES CENTER, INC.

This notice is being posted pursuant to a Consent Decree entered by the Court in U.S. EEOC
et al. v. ConsolidationResourcesCenter.b,CivilActionNo.8:05-CV-01832-SCB-EATJh.eEEOC
allegedthat ConsolidationResourcesCenterviolated Title W of the Civil Rights Act of 1964,with respect to four employees. Consolidation Resources Center denied all allegations in the suit.

Pursuantto the ConsentDecree, ConsolidationResourcesCenter, Inc.has agreed that it will not discriminate against employees in violation of Title VII of the Civil Rights Act of 1964 ("Title VII"). TitleWprotectsindividualsfiom employmentdiscriminationbecause of their race,religion, color, national origin, or sex. Consolidation Resources Center, Inc will not condone employment discriminationof any kind as set forth in federal antidiscrimination laws.

Furthermore, Consolidation Resources Center, Inc, assures its employees that it supports Title VII and will not take any action against an individual because helshe has exercised hisher rights under the law to oppose discriminatory acts or to file charges with the EEOC. Appropriate corrective action, up to and including termination, shall be taken against any employee (including management personnel) found to violate the policies regarding discrimination, based upon the circumstances involved.

This notice shall remain posted for two (2) years from the date signed. Employees or applicantsfor ernpIoymentwho have questionsabouttheir rightsunder TitleVII oranyotherfederal anti-discrimination law may telephone the Miami District Office of the Equal Employment Opportunity Commission at 1-800-669-4000.

Signed this -day of

,2006.

CO-PRESIDENT, CONSOLIDATION RESOURCES CENTER, INC

DO NOT REMOVE BEFORE

2008

EXHIBIT B MONETARY DISTRIBUTION
In order to resolve EEOC et al. v. Consolidation Resources Center. Inq Civil Action No.8:OS-W-01832-SCB-EN, Consolidation Resources Center, Inc. shall pay the total amount of $ 180,000.00 to be distributed as follows:
(A) Defendant will pay Laretha Dortch-Lord $45,000.00, and will issue an I.R.S. form 1099 itemizing same.
(B) Defendant will pay Kayrni-ElderManning $45,000.00, and will issue an I.RS. form
1099 itemizing same.
(C) Defendant will pay Tiffani Bowers $45,000.00, and will issue an I.R.S. form 1099
itemizing same.
@) Defendant will pay Aisha Larry $ 45,000.00, and will issue an I.R.S. form 1099 itemizing same.
(E) The payments to the Plaintiff-IntervenorsDortch-Lord, Elder-Manning and Bowers shall be made by check in their individual name and to Patrice A. Pucci, P.A. their attorney and
forwarded to Patrice A. Pucci, Esq., 2719 1" Ave. N., St. Petersburg, FL 33713, by certified mail with a return receipt requested. The payments to Plaintiff-IntervenorLarry shall be made by check
in her individualname and Theodore Karatinos, her attorney and forwarded to Theodore Emanuel Karatinos, Esq., Holliday, Bomhoff& Karatinos, P.L., 5327 Commercial Way, Suite D-122, Spring Hill, FL 34606, by certified mail with a return receipt requested.
(F) A copy of the checks referenced above shall be forwarded to the attention of Carla Von Greiff,SeniorTrial Attorney, U.S. Equal EmploymentOpportunityCommission, 501 East Polk Street, Suite 1000, Tampa, Florida 3361 1.

 
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U.S. District Court Middle District of Florida (Tampa) CIVIL DOCKET FOR CASE #: 8:05-cv-01832-SCB-EAJ

CLOSED

United States Equal Employment Opportunity Commission v. Consolidation Resource Center, Inc. Assigned to: Judge Susan C Bucklew Referred to: Magistrate Judge Elizabeth A. Jenkins Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 09/30/2005 Date Terminated: 11/06/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
United States Equal Employment Opportunity Commission

represented by Carla Johanna Von Greiff Equal Employment Opportunity Commission Tampa Area Office 501 E. Polk St., Ste. 1000 Tampa, FL 33602 813/202-7903 Fax: 813/228-2045 Email: carla.vongreiff@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Intervenor Plaintiff Aisha Larry

represented by Theodore Emanuel Karatinos Holliday, Bomhoff & Karatinos, P.L. 5327 Commercial Way Suite D-122 Spring Hill, FL 34606 (352) 597-0009 Fax: (352) 597-8600 Email: tedkaratinos@hbklawfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Intervenor Plaintiff Ms. Tiffani Bowers

represented by Patrice Anne Pucci Patrice A. Pucci, P.A. 2719 1st Ave., N. St. Petersburg, FL 33713 727-894-4516 Fax: 727-321-2839 Email: papucci@mindspring.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Intervenor Plaintiff Ms. LaRetha Dortch-Lord
Intervenor Plaintiff Ms. Kaymi Elder-Manning
V. Defendant Consolidation Resource Center, Inc.
Defendant Vincent Lawrence
Mediator Walter E. Aye

represented by Patrice Anne Pucci (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Patrice Anne Pucci (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christie D. Arkovich Law Office of Christie D. Arkovich 1520 W Cleveland St Tampa, FL 33606 813/258-2808 Fax: 813/258-5911 Email: cdalaw2@tampabay.rr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christie D. Arkovich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Walter E. Aye Walter E. Aye, P.A. 610 Azeele St. Tampa, FL 33606 813/221-2112 PRO SE

Date Filed 09/30/2005 09/30/2005

#

Docket Text

1 COMPLAINT against Consolidation Resource Center, Inc. ; jury demand , filed by United States Equal Employment Opportunity Commission.(bn) (Entered: 10/03/2005)
2 Summons issued as to Consolidation Resource Center, Inc. Consent(s) issued. (bn) (Entered: 10/03/2005)

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10/07/2005 10/10/2005
12/01/2005 12/05/2005 12/05/2005 01/05/2006 01/06/2006 01/06/2006 01/08/2006
01/13/2006 01/13/2006
01/17/2006

3 MOTION to intervene by Aisha Larry. (Karatinos, Theodore) (Entered: 10/07/2005)
4 Unopposed MOTION to intervene and Memorandum in Support by Tiffani Bowers, LaRetha Dortch-Lord, Kaymi Elder-Manning. (Attachments: # 1 Exhibit "A"# 2 Exhibit "B"# 3 Exhibit "C" 1# 4 Exhibit "C"2# 5 Exhibit "D"# 6 Exhibit "E"# 7 Exhibit "F"# 8 Exhibit "G"# 9 Exhibit "H"# 10 Exhibit "A" 2# 11 Exhibit Compl. "A" 1# 12 Exhibit Comp. "A" 2# 13 Exhibit Comp. "B"# 14 Exhibit Comp. "C" 1# 15 Exhibit Comp. "C" 2# 16 Exhibit Comp. "D"# 17 Exhibit Comp. "E" 1# 18 Exhibit Comp. "E" 2# 19 Exhibit Comp. "F"# 20 Exhibit Comp. "G" 1# 21 Exhibit Comp. "G" 2# 22 Exhibit Comp. "H")(Pucci, Patrice) (Entered: 10/10/2005)
5 RELATED CASE ORDER AND NOTICE of designation under Local Rule 3.05 - track 2;the notice of expected deadlines and case management report is made a part here in.Signed by Judge Susan C Bucklew on 12/1/2005. (kit) (Entered: 12/01/2005)
6 ANSWER to complaint and Affirmative Defenses by Consolidation Resource Center, Inc..(Arkovich, Christie) (Entered: 12/05/2005)
7 RETURN of service executed on 11/14/2005 by United States Equal Employment Opportunity Commission as to Consolidation Resource Center, Inc. (bn) (Entered: 12/05/2005)
8 CASE MANAGEMENT REPORT. (Von Greiff, Carla) (Entered: 01/05/2006)
9 NOTICE by Aisha Larry of Amended Local Rule 3.01(g) Certification (Karatinos, Theodore) (Entered: 01/06/2006)
10 NOTICE by Tiffani Bowers, LaRetha Dortch-Lord, Kaymi Elder-Manning re 4 Unopposed MOTION to intervene and Memorandum in Support of Amended Local Rule 3.01(g) Certification (Pucci, Patrice) (Entered: 01/06/2006)
11 ORDER granting 3 Aisha Larry's Motion to intervene, granting 4 LaRetha Dortch-Lord, Kaymi Elder-Manning, and Tiffani Bowers' Motion to intervene. Interveners are directed to file their complaint in intervention on or before January 17, 2006 . Signed by Judge Susan C Bucklew on 1/8/2006. (bs) (Entered: 01/08/2006)
12 INTERVENOR'S COMPLAINT, filed by Aisha Larry.(Karatinos, Theodore) (Entered: 01/13/2006)
13 INTERVENOR'S COMPLAINT, filed by Tiffani Bowers, LaRetha Dortch-Lord, Kaymi Elder-Manning. (Attachments: # 1 Exhibit A1# 2 Exhibit A2# 3 Exhibit B# 4 Exhibit C1# 5 Exhibit C2# 6 Exhibit D# 7 Exhibit E1# 8 Exhibit E2# 9 Exhibit F# 10 Exhibit G1# 11 Exhibit G2# 12 Exhibit H)(Pucci, Patrice) (Entered: 01/13/2006)
14 CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 11/15/2006. Dispositive motions due by 12/15/2006. Pretrial Conference set for 3/15/2007 08:30 AM before Judge Susan C Bucklew. Conduct mediation hearing by 11/29/2006. Lead counsel to coordinate dates. This case is set for a jury trial on the April 2007 trial calendar.Signed by Judge Susan C Bucklew on 1/17/2006. (bs) (Entered: 01/17/2006)

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01/31/2006 01/31/2006 02/17/2006 05/30/2006 05/31/2006 06/02/2006 06/05/2006
09/06/2006 09/12/2006 09/13/2006
09/22/2006 09/28/2006 09/28/2006
10/02/2006

15 ANSWER to intervenor complaint re 13 and Affirmative Defenses by Consolidation Resource Center, Inc., and Vincent Lawrence (Arkovich, Christie) Modified on 2/1/2006 (bn). (Entered: 01/31/2006)
16 ANSWER to intervenor complaint re 12 and Affirmative Defenses by Consolidation Resource Center, Inc., and Vincent Lawrence. (Arkovich, Christie) Modified on 2/1/2006 (bn). (Entered: 01/31/2006)
17 STIPULATION Regarding Selection of Mediator by United States Equal Employment Opportunity Commission. (Von Greiff, Carla) (Entered: 02/17/2006)
18 MOTION to extend time to Add Third Parties by all defendants. (Arkovich, Christie) (Entered: 05/30/2006)
19 MOTION to extend time to Add Third Parties by all defendants. (Arkovich, Christie) (Entered: 05/31/2006)
20 RESPONSE to motion re 19 MOTION to extend time to Add Third Parties filed by Aisha Larry. (Karatinos, Theodore) (Entered: 06/02/2006)
21 ENDORSED ORDER denying as moot 18 Defendants' Motion to extend time, granting 19 Defendants' Motion for an Extension of Time to Add Third Parties. Defendants shall have an additional 45 days to add a third party.. Signed by Judge Susan C Bucklew on 6/5/2006. (bs) (Entered: 06/05/2006)
22 NOTICE by United States Equal Employment Opportunity Commission of Scheduling Mediation (Von Greiff, Carla) (Entered: 09/06/2006)
23 MOTION to substitute attorney by Aisha Larry. (Attachments: # 1 Local Rule 3.01(g) Certification)(Karatinos, Theodore) (Entered: 09/12/2006)
24 ENDORSED ORDER granting 23 Motion for substitution of counsel as to plaintiff-intervenor Aisha Larry. Holliday Bomhoff & Karantinos P.L. shall be substituted for Prugh Holliday & Karatinos P.L. . Signed by Judge Susan C Bucklew on 9/13/2006. (Bucklew, Susan) (Entered: 09/13/2006)
25 NOTICE by United States Equal Employment Opportunity Commission of Re-scheduling Mediation (Von Greiff, Carla) (Entered: 09/22/2006)
26 MOTION to amend/correct Complaints by EEOC, by Aisha Larry by Tiffani Bowers, LaRetha Dortch-Lord, Kaymi Elder-Manning. (Pucci, Patrice) (Entered: 09/28/2006)
27 NOTICE by Tiffani Bowers, LaRetha Dortch-Lord, Kaymi Elder-Manning re 26 MOTION to amend/correct Complaints by EEOC, by Aisha Larry of Filing Exhibits to Motion (Attachments: # 1 Exhibit A to Plaintiffs' Motion to Amend# 2 Exhibit B to Plaintiffs Motion to Amend# 3 Exhibit C-D to Plaintiffs Motion to Amend# 4 Exhibit E to Plaintiffs Motion to Amend# 5 Exhibit F to Plaintiffs Motion to Amend# 6 Exhibit G-I to Plaintiffs Motion to Amend)(Pucci, Patrice) (Entered: 09/28/2006)
28 NOTICE by United States Equal Employment Opportunity Commission Of Filing Deposition Transcript Of Vince Lawrence re 26 MOTION to amend/correct Complaints (Attachments: # 1 Exhibit Lawrence pgs. 1-58# 2

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10/10/2006
10/10/2006 10/17/2006
10/17/2006 11/01/2006 11/01/2006 11/06/2006 11/06/2006 11/08/2006

Exhibit Lawrence pgs. 59-117# 3 Exhibit Lawrence pgs. 118-179)(Von Greiff, Carla) Modified on 10/3/2006 (apv, ). (Entered: 10/02/2006)
29 RESPONSE in opposition re 26 MOTION to amend/correct Complaints by EEOC, by Aisha Larry to Add Parties as Defendants and Memorandum in Support filed by Consolidation Resource Center, Inc.. (Arkovich, Christie) (Entered: 10/10/2006)
30 NOTICE of filing exhibits by Consolidation Resource Center, Inc. re 29 Response in opposition to motion and Memorandum in Support (Arkovich, Christie) Modified on 10/11/2006 (bn). (Entered: 10/10/2006)
31 MOTION for protective order for Calendar Protection by all defendants. (Arkovich, Christie) Motions referred to Magistrate Judge Elizabeth A. Jenkins. COUNSEL REFILED SEE DKT. 32 MOTION. Modified on 10/18/2006 (bn). (Entered: 10/17/2006)
32 Amended MOTION for protective order for Calendar Protection by all defendants. (Arkovich, Christie) Motions referred to Magistrate Judge Elizabeth A. Jenkins. (Entered: 10/17/2006)
33 ENDORSED ORDER granting 32 Defendants' Motion for calendar protection. Signed by Judge Susan C Bucklew on 11/1/2006. (lc, ) (Entered: 11/01/2006)
34 Joint MOTION For Approval of Consent Decree by United States Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Consent Decree)(Von Greiff, Carla) (Entered: 11/01/2006)
35 ORDER: Consent Decree. See order for details. Signed by Judge Susan C Bucklew on 11/6/2006. (lc, ) (Entered: 11/06/2006)
36 ENDORSED ORDER granting 34 Joint Motion for Approval of Consent Decree. The Clerk is directed to close this case and terminate all pending motions. Signed by Judge Susan C Bucklew on 11/6/2006. (lc, ) (Entered: 11/06/2006)
37 MEDIATION REPORT Hearing held on October 31, 2006 Hearing outcome: Settled(cda) (Entered: 11/09/2006)

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