09-28-03 10:60m F r om...EEO~

206 2ZO 691t

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ORIGINAL

LUIS LUCERO, JR., REGIONAL ATTORNEY

~HN F. STANLEY, ACTING SUPERVISORY TRIAL ATTORNEY

ESLEY KATAHIRA, SENIOR TRIAL ATTORNEY

~UAL EMPLO~ OPPORTUNITY COMMISSION

FIRST AVENUE, SUITE 400

S:’:ATI~E, WA 98104

~L~v INTHE

F~kX: (206) 220-6911

~ NrTORNEYS FOR PLAINTIFF

SEP25 ~ ~. ~,

POKAN~_, VWt.,q~N~TON

U~TED STATES DISTRICT COURT FOR THB EASTERN DISTRICT OF WASHINGTON

LRS

12

COMPLAINT

Pl~nfiff,

/URY ~RIAL DEMAND

V.

FOODS USA,

Defendant.

17

NATURE OF ~I}I~A(~TION

This is an action under Title VII oft.he Civil Rights Act of 1964 ("Title VII")

19 Tide I of the Civil Rights Act of 1991 to correct unlawful employment practices

20

basis of sex and to provide appropriate reliefto Chanda Thomas and Marilyn

21

who w~re adversely affected by such practices. The Equal Employment

USA, Inc. I [(."~D,,epfepnodrtaunnt i)tfya,il,edCotommpirsosmioonte aMllse. gTehsomthaastanDdefMensd.aMntcNMeclClayibnecFaouosdesof:heir sex, 24 female. Plaintiff seeks injunctive and monetary relief’, including pecuniary and
25 nonpeetmiary compensatory damages mad punitive damages, on behalf of Ms.

COMPLAINT - Page I

|O:60am From-EEOC SED~

l

and Ms. McNelly.

2

_Ytn~SD~CT~O~ ~ ~

I. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§

1,1331,1337, 1343 and 1345. This action is authorized and instituted pursuant to

706(0(1) and (3) of Title

as amended, 42 U.S.C. §§ 2000e-5(f)(1) and (3). This action is also authorized

7

instituted pursuant to Section 102 of the Civil Rights Act of 1991, 42 U.S.C. §

$

9

The employment practices alleged to be unlawful were and are

10

within the jurisdiction of the United States District Court for the Eastern

1I

of Washington.

12

13

Plaintiff, the Equal Employment Opportunity Commission (the

14

is the agency of the United States of America charged with the

15

interpretation and enforcement of Title VII and is expressly

16

to bring this action by Sections 706(f)(I) and

17 of Title VII, as amended, 42 U.S.C. §§ 2000e-5(f)(1) and (3).

18

4. A¢ all relevant times, Defendant has continuously been a corporation

business in the State of Washington and has continuously had at least 15

20 ~loyees.

21

7. At all relevant times, Defendant has continuously been an employer

22

in an industry affecting commerce within the meaning of Sections and

701(b), (g) and (h) ofTitl¢ Vn, 42 U.S.C. §§ ~-000e(b), (g) and (h).

8. Prior ~o institution of this lawsuit, the Commission’s representatives

25

employment practices allegedbelow and to effect

COMPLA/NT - Page 2

fJ.S. ~QUAL EMI’t.OYMEICT OPPORT’JNITY
~t~J~, W~tngton T’~’~I~~ 12061

~

205 220 ~911

T-eD P.O0?/O08 F-~4

1

compliance with Title VII through informal methods of conciliation,

2

and persuasion within the meaning of Section 706Co) of Title VII, 42

3

§ 2000e-5Co).

4

STATEMENT OF CL.AIMS

9, More than thirty days prior to the institution of this lawsuit, Chandra

6

filed a charge of discrimination with the Commission alleging violations of

?

VII by Defendant. All conditions precedent to the institution of this lawsuit have

,,en fulfilled.

9

10. Since at least October 1, 2002, Defendant has engaged in unlawful

10

practices at its facility in Othello, Washington in violation of Section

11

of Title VII, 42 U.S.C. § 2000e-2(a). These practices included failing to

12

Ms, Thomas and Ms. McNelly because of their sex, f~male.

13

11. T~e effect of the Practice(s) complained of in paragraph 10 above has

to deprive Ms. Thomas and Ms. McNelly of equal employment opportunities

otherwise adversely affect their status as employees seeking promotion because

16

sex.

17

12. The unlawful employment practices complained of in paragraph 10

18

were and are intentional.

19

13. The unlawful employment practices complained of in paragraph 10

20

were and are done with malice or with reckless indifference to the federally

21

rights of Ms. Thomas and Ms. McNclly who were unlawfully denied

22

because of their sex.

23

P_RAYER FOR RELIEF

24

Wherefore, the Commission respectfuUy requests that this Court:

25

A. Grant a permanent injunction enjoining Defendant and its officers,

U,$. EUUAL rJ~PLo~ME~L’r OPPOR’I’~JNI’rY OOMMk~,ION

COMPLAINT - Page 3

~auJo, W~mln~t~ fa~lle| ~e) 220-6911

lO:Slam From-EEOC SEDO

206 220 6011

T-iT3 P,O06/OOO

1

successors., assigns, and all persons in active concert or participation with

2

engaging in referral practices that discriminate on the basis of" sex and in any

3

employment practice which discriminates on the basis of" sc×.

4

B. Order Defendant to institute and carry out poli~ies, practices and

$

which provide equal employment opportunities for women and which

6

the effects of its past and present unlawful employment practices.

7

C. Order Defendant to make whole Chandm Thomas and Marilyn McNelly

providing appropriate back pay with prejudgment interest, in amounts to bc

9

at trial, and other affirmativa relief necessary to eradicate the effects of its

10

employment practices.

11

D. Order Defendant to make whole Ms. Thomas and Ms. McNetly by

12

compensation for past and future pecuniary losses resulting from

13

employment practices described in paragraphs 10-13 above, including

14

limitation past and future out-of-pocket expenses, in amounts to bc

E. Order D~fendant to make whole Ms. Thomas and Ms. McNelly by

compensa’don for past and future non-pecuniary losses resulting from the

practices complained of in paragraphs 10-13 above, including without

emotional pain, suffering, loss of enjoyment of life and humiliation in

2~

to dctonnined at trial.

2~

F. Order Defendant to pay Ms. Thomas and Ms. McNelly punitiv~ damages

22 its malicious and/or reckless conduct described in paragraphs 10-13 above in an

to be determined at trial.

G. Orant such further relief as the Court deems necessary and proper in the

interest.

- Pag~ 4

lO:51am From-EEOC

206 220 6011

T-OT3 P.OOWO00

I

H. Award ~e Commission its costs of this action.

2

3

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

4

DATED this .Zq~( day of

o 2003.

6 LUIS LUCEI~O, YI~

~gional Attorney

7

F, STANLEY

8

Supcrvlsory Trial Attorney

ERIC $. DI~JEIBAND General Counsel
JAMES L. LEE Deputy General Counsel

~iSLEY 9

KATAHIRA

or Trial A~omey

10

GWENDOLYN YOUNG REAIVIS Associate General Counsel

11

12 ]] E~UAL EMPLOYMENT ~ qPPORTUNITY COMMISSION
~ ]] S~attl¢ Distda M 9~)9 First Avenue, Suite 400
14 B S~attle, Washington 98104
(206) 220-6851
15

Office of the General Counsel 1801 "L" Street ~VvV Washington, D.C. 20507

16

Attorneys for Plaintiff

17

18

19

2O

21

22

23

24

25

- Page 5

 
 10-Z1-04 OZ:33pm From-EEOC SEDO

206 220 6911

T-288 P.OOZ/OOB F-ZIB

SP()V.A~, . \VIt:;:'iv~i~GER &
" PROt,~ SERVICE
16:8. ,H~"nNGTqN.400
c;,rOk, Nf: 99201
2

HONORABLE LONNY R. SUKO
FtUJ) 111 THE U.S. C') rr'~: i COURT EASTER~.I Di';:. i .,<J'h\SHINGTON

3

("J('J~ ?._ 6 2004

4

,JAMES h. LI\h;)Li~, CLERK

_____.._______ DEPUlY

5

UNITED STATES DISTRICT co~'f' WASHiNGTON

6
FOR THE EASTERN DISTRICT OF WASHINGTON
7

8 EgUAL EMPLOYMENT OPPORTUNITY C MMISSION,
9
Plaintiff,
10
v.
11
MCCAIN FOODS USA, INC.,
12

Case No. CS-03-339-LRS CONSENT DECREE

13

Defendant.

14 --------------------------,)

I. INTRODUCTION

15

1. This action originated with a charge of employment discrimination

16

filed with the Equal Employment Opportunity Commission ("the Commission")

17

on November 13, 2002 by Chanda Thomas. The Charge alleged that McCain

18
Foods, Inc. ("the Company") discriminated against Ms. Thomas on the basis of her

19
sex, female, in violation of Title VII of the Civil Rights Act of 1964,42 U.S.C. §

20

2000e (''Title VII") by denying her a promotion to a Waste Disposal Operator

21

position for which she was qualified. During EEOC's investigation, EEOC

22
identified Marilyn McNelly, a similarly situated class member, who was also

23

denied an earlier promotion to the same position on the basis of her sex, female, in

24

violation of Title VII. The Company denies that Ms. McNelly and Ms. Thomas

25

are similarly situated class members or that it discriminated against Ms. Thomas

26

and Ms. McNelly in any manner.

27

2. Following the issuance of Letters of Determination and the failure of

28

CONSENT DECREE - PAGE 1
OR\G\NAL

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I

T-288 P.003/008 F-218

1 conciliation efforts, the Commission filed a lawsuit under under Title VII against

2 the Company on September 25,2003.

3

3. The parties want to conclude the claims arising out of the charge, the

4 Commission's determination with regard to the charge, and the lawsuit arising

5 from the charge, without expending further resources in contested litigation.

6

II. NONADMISSION OF LIABILITY AND

7

NONDETERMINATION BY THE COURT

8

4. This Consent Decree is not an adjudication or finding on the merits of

9 this case and shall not be construed as an admission by the Company of a violation

10 of any law.

11

III. SETTLEMENT SCOPE

12

5. This Consent Decree is the final and complete resolution of all

13 allegations of unlawful employment practices included in the Charge, in the

14 Commission's Letter of Deterrnination and in the Commission's complaint filed in

15 the case that were or could have been brought based on the administrative charge,

16 as well as claims by the parties andlor class members for attorney fees and costs.

17 The injunctive relief provisions of this Consent Decree apply to all of the

18 Company's facilities in the State of Washington and is final and binding as to all

19 such issues and claims.

20

IV. MONETARYRELIEF

21

6. In settlement of this suit, the Company agrees to pay Nine Thousand

22 Dollars and No Cents ($9,000.00) to the class members in settlement and

23 satisfaction of all claims for monetary relief which were or could have been

24 asserted in the case by Ms. Thomas and/or Ms. McNelly. Ms. Thomas and Ms.

25 McNelly will each receive $3,500 in backpay and $1,000 in compensatory

26 damages.

27

a. Ms. Thomas and Ms. McNelly will be required to sign a

28

separate "General Release" in order to receive the monetary

CONSENT DECREE - PAGE 2

10-21-04 02:33pm From-EEOC SEOO

206 220 6911

- ~~

---.---,-,."~-

T-288 P.004/008 F-218

- "-
1
2
3 4 5
6
7
8
9
10 11
12 13 14 15 16 17
18 19 20
21
22 23
24
25 26
27
28

benefits provided by this Decree. Ms. Thomas and Ms. McNelly shall have the right to seek the advice of an attorney of their choice before executing the General Release. c. Upon receipt by the Company of the executed "General Release," the Company shall, within either fourteen days or the next date payroll checks are nonnally issued by the Company, whichever is later, issue a payroll check in an amount representing back pay, reduced by all payroll withholdings and FICA contributions required by law. The Company will also timely issue to each recipient an IRS W-2 ,Form representing back pay payments. At the same time that the checks for the back pay portion of the settlement are issued, the Company will also issue the checks for the portion of the settlement allocated to emotional distress. Checks shall be mailed by first class mail to class members at their last !mown address as provided by the Commission. d. Within five (5) days of mailing the checks, the Company will verify the mailing by providing to the EEOC copies of the checks and a Declaration of an appropriate company official attesting that the Company mailed the checks in compliance with the Decree. e. If any check is returned as Wldeliverable, the Company will notify the EEOC within seven (7) days. The EEOC will notify the Company within seven (7) days of the Company's notice of any new contact information.
V. INJUNCTIVE RELIEF A. General Provisions
7. The Company reaffinns its commitment to continue to comply with

CONSENT DECREE - PAGE 3

10-21-04 02:34pm From-EEOC SEOO

206 220 S911

T-288 P.005/008 F-218

1 the requirements of Title vn and all other federal laws against discrimination in

2 its employment decisions. To further this commitment, it shall monitor its

3 affirmative obligations under this Consent Decree.

4

8. The Company shall not retaliate against any current or fonner

5 employee for opposing any practice made unlawful by Title VII. Nor shall the 6 Company retaliate against any current or fonner employee for making a charge or 7 for testifying, assisting, or participating in any investigation, proceeding, or

8 hearing associated with the case.

9

B. Establishment of Policy and Procedures to Prevent

10

Discrimination

11

9. Within thirty (30) days after entry of the Decree, the Company shall

12 reaffirm its written equal employment opportunity policy which is attached hereto

13 as Exhibit A. In addition, within five (5) business days of entry of the Decree, the

14 Company shall ensure that copies of the policy are posted in common areas within

15 each plant where employees have access.

16

C. Training

17

10. To further the purposes and requirements of this Consent Decree, the

18 Company agrees to provide two (2) hours of employment discrimination training

19 within the first ninety (90) days following entry of the Decree, including training

20 on sex discrimination and its EEO policy, to all managers and supervisors in its

21 Washington facilities and will include such training as part of its new hire

22 orientation.

23

11. The Company further agrees to continue its present armual

24 employment discrimination training given to all non-management employees and

25 supervisors, including training on Title VII's prohibition against sex

26 discrimination in promotion selection decisions.

27

D. Reporting

28

12. Six (6) months after enrry of this Consent Decree and thirty (30) days

CONSENT DECREE - PAGE 4

10-21-04 02:34pm From-EEOC SEDO ~- --------20-S-22-0-69-11

T-288 P.OOS/008 F-218

1 after the conclusion of the term. of the Consent Decree, the Company shall provide

2 a report to the Commission on the Company's compliance with the Consent

3 Decree. The Compliance Report shall include the following:

4

(a) during the reporting period applicant flow data, hires, transfers

5 and promotions by sex;

6

(b) copies of the attendee lists and materials for an training required

7 by this Decree.

8

If the Company has not complied with any term of the Consent Decree, the

9 Company shall provide a statement specifying the areas of noncompliance, the

10 reason(s) for the noncompliance, and the steps taken to bring the Company into

11 ·compliance.

12

VI. ENFORCEMENT

13

13. The United States District Court for the Eastern District of

14 Washington shall retain jurisdiction over this matter for the duration of the

15 Consent Decree. lfthe Commission concludes that the Company has breached

16 any of the above provisions, it shall promptly notify the Company providing a

17 written statement of the alleged breach. The parties shall attempt to resolve the

18 dispute for a period not to exceed thirty (30) days after the Commission's

19 notification of the alleged breach. lfthe Commission is unable to resolve the

20 dispute to its satisfaction, the Commission may bring an action to enforce this

21 Decree.

22

Vll. TERMINATION OF DECREE

23

14. This Consent Decree shall be in effect for two (2) years commencing

24 with the date the Consent Decree is entered by the Court. lithe Commission peti-

25 tions the Court and the Court finds the Company to have violated the tenns of the

26 Consent Decree, the Court may extend the period of the Consent Decree and

27 award the Commission its costs in bringing an enforcement action.

28

CONSENT DECREE - PAGE 5

IU-LI-V4

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From-EEOC Z06 ZZO 6911 SEDO~--·-------~--

T-Z88 P.007/008 F-ZI8

1

DATED this ;;.1 $+ day ofcO~ ,2004.

2 A. LUIS LUCERO, JR. Regional Attorney
3
JOHN F. STANLEY 4 Acting Supervisory Trial Attorney

ERIC S. DRIEBAND General Counsel JAMES L.LEE Deputy General Counsel

5 WESLEYKATAHIRA Senior Trial Attorney
6

GWENDOLYN YOUNG REAMS Associate General Counsel

7 BY:~+-~~~~~~~

EOUALEMPLOYMENT

o 8 E; 1\L EMPLOYMENT ORTUNITY COMMISSION

OPPORTUNITY COMMISSION Office of the General Counsel

9 Seattle District Office

1801 "L" Street NW

909 First Avenue, Suite 400

Washington, D.C. 20507

10 Seattle, Washington 98104

Telephone (206) 220-6918

11

. Attorneys for Plaintiff EEOC

12

ad:· 13
14 Dated:

I g/ ~oof-

15 MORGAN, LE S & BOCKIUS, LLP PRESTON, G ES & ELLIS, LL
16

17
BY:
18

19

20

21
22 23 24 25 26 27
28

CONSENT DECREE - PAGE 6

~--TO:;ZT -04

~1'[1\"02-;-3';:=Spm::---"-F-orm--=-E=EO"""'C-"SE:-:-OO- -----------.-~.~ 206 220 6911

T-288 P 008/008 F-218

1

ORDER

2

The Court having considered the foregoing stipulated agreement of the

3 parries, IT IS HEREBY ORDERED THAT the foregoing consent decree be, and

4 the same hereby is, approved as the final decree of this Court in full settlement of

5 this action. This lawsuit js hereby dismissed with prejudice and without costs or

6 attorneys' fees to any party. The Court retains jurisdiction of this matter for

~ OcZtf~ 7 purposes of enforcing the c.ODsent decre~Rproved herein.

8

DATED this -z.e, day of

,2004.

9 10

~ LONNYR. S

11

UNITED STATES DISTRlCT JUDGE

12

13

14

15

16
PRESENTED BY:
:: wEfI~le EQUAL EJMPLOYMENT OPPORTUNITY 19 COMMISSION

20

21

22

23

24

25

26

27

28

CONSENT DECREE - PAGE 7

 
 CM/ECF LIVE - U.S. District Court:waed - Docket Report

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CLOSED, JURY, LC02, PROTO
Eastern District of Washington U.S. District Court (Spokane) CIVIL DOCKET FOR CASE #: 2:03-cv-00339-LRS

EEOC v. McCain Foods USA Inc Assigned to: Judge Lonny R. Suko Demand: $0 Cause: 28:451 Employment Discrimination Plaintiff Equal Employment Opportunity Commission
1 of 4

Date Filed: 09/25/2003 Date Terminated: 10/26/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by A Luis Lucero, Jr Equal Employment Opportunity Commission - SEA Seattle District Office 909 First Avenue Suite 400 Seattle, WA 98104 206-220-6878 Fax: 12062206911 Email: luis.lucero@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eric S Dreiband Equal Employment Opportunity Commission - DC Office of the General Counsel 1801 "L" Street NW Washington, DC 20507 202-634-6000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gwendolyn Young Reams Equal Employment Opportunity Commission - DC Office of the General Counsel 1801 L Street NW Washington, DC 20507 202-634-6000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
James L Lee Equal Employment Opportunity Commission - DC
6/1/2007 11:27 AM

CM/ECF LIVE - U.S. District Court:waed - Docket Report
V. Defendant McCain Foods USA Inc
2 of 4

https://ecf.waed.uscourts.gov/cgi-bin/DktRpt.pl?584119418860272-L_...
Office of the General Counsel 1801 L Street NW Washington, DC 20507 202-634-6000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
John F Stanley Equal Employment Opportunity Commission - SEA Seattle District Office 909 First Avenue Suite 400 Seattle, WA 98104 206-220-6896 Fax: 206-220-6911 Email: john.stanley@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Wesley Katahira Equal Employment Opportunity Commission - SEA Seattle District Office 909 First Avenue Suite 400 Seattle, WA 98104 206-220-6883 Email: wesley.katahira@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Charis Runnels Vedder Price Kaufman & Kammholz PC 222 N LaSalle Street 26th Floor Chicago, IL 60601-1003 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jerry Robert Neal Preston Gates & Ellis LLP - SPO 601 W Riverside Avenue Suite 1400 Spokane, WA 99201-0636 509-624-2100 Email: jneal@prestongates.com
6/1/2007 11:27 AM

CM/ECF LIVE - U.S. District Court:waed - Docket Report

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LEAD ATTORNEY ATTORNEY TO BE NOTICED
Nina G Stillman Vedder Price Kaufman & Kammholz PC 222 N LaSalle Street 26th Floor Chicago, IL 60601-1003 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 10/14/2000 09/25/2003 10/16/2003 10/22/2003 10/24/2003 10/24/2003 10/24/2003 10/27/2003
10/29/2003
10/31/2003
11/03/2003 11/03/2003 11/04/2003

#

Docket Text

3 SUMMONS/RETURN OF SERVICE executed upon defendant McCain Foods USA Inc (PP) (Entered: 10/20/2003)
1 COMPLAINT JURY TRIAL DEMAND (Summons(es) issued) Fee-status: wv Receipt #: wv (CR) (Entered: 09/26/2003)
2 Notice of APPEARANCE for defendant; Atty Jerry Robert Neal appearing (CR) Modified on 10/17/2003 (Entered: 10/17/2003)
Law Clerk assigned to case is AV (LMM) (Entered: 10/22/2003)
4 ANSWER by defendant McCain Foods USA Inc (PP) (Entered: 10/27/2003)
5 MOTION by defendant McCain Foods USA Inc for attorney Nina G Stillman to appear pro hac vice (PP) (Entered: 10/27/2003)
6 MOTION by defendant McCain Foods USA Inc for attorney Charis Runnels to appear pro hac vice (PP) (Entered: 10/27/2003)
7 PROPOSED RECEIVED Order re: motion for attorney Charis Runnels to appear pro hac vice [6-1], motion for attorney Nina G Stillman to appear pro hac vice [5-1] submitted by defendant McCain Foods USA Inc (PP) (Entered: 10/27/2003)
FAXED/MAILED GRANTING MOTION TO APPEAR PRO HAC VICE RE: Nina G. Stillman & Charis A. Runnels to all counsel (FmrEmp) (Entered: 10/29/2003)
8 ORDER by Judge Lonny R. Suko granting motion for attorney Charis Runnels to appear pro hac vice [6-1], granting motion for attorney Nina G Stillman to appear pro hac vice [5-1] (cc: all counsel) (PP) (Entered: 10/31/2003)
Sched Conference Notice ;telephonic sched conf 8:30 12/22/03 new Meet Me Line, 509 376-1330, Yakima, WA (LMM) (Entered: 11/03/2003)
FAXED/MAILED Notice Setting Court's Scheduling Conference to all counsel (LMM) (Entered: 11/03/2003)
FAXED/MAILED Notice Setting Court's Scheduling Conference telephonic, Court's conference line 509 376-1330, to all counsel (LMM) (Entered: 11/04/2003)

3 of 4

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12/10/2003 12/11/2003 12/22/2003 01/09/2004
08/12/2004 08/12/2004 08/12/2004
08/12/2004 08/23/2004 08/23/2004 10/26/2004 10/26/2004

9 Joint Status Conference Certificate filed by defendant McCain Foods USA Inc, plaintiff EEOC (PP) (Entered: 12/12/2003)
10 Discovery Plan by defendant McCain Foods USA Inc, plaintiff EEOC pur. to FRCP 26(F) (PP) (Entered: 12/12/2003)
11 MINUTES: Telephonic Scheduling Conference; Location: Yakima, WA; CR/ER: Not Reported; before Judge Lonny R. Suko (KW) (Entered: 12/24/2003)
12 Scheduling Conference Order by Judge Lonny R. Suko Disp mtn ddl: 11/9/04; Mtn in limine ddl: 1/18/05 ;discovery to be complete 10/12/04 Pretrial Conf (Tele) set 8:15 1/24/05 Yakima, WA ;proposed PTO due 1/13/05 ;Jury Trial set 9:00 2/8/05 Yakima, WA ; telephonic status conf set 8:30 12/17/04 (cc:all counsel) (PP) (Entered: 01/09/2004)
13 MOTION by defendant to expedite hearing on motion to enter agreed protective order (CV) (Entered: 08/13/2004)
14 MOTION by defendant to enter agreed protective order (CV) (Entered: 08/13/2004)
15 Notice by defendant of hearing setting motion to enter agreed protective order [14-1] (w/o oral argument 9:00 8/18/04 ), setting motion to expedite hearing on motion to enter agreed protective order [13-1] (w/o oral argument 9:00 8/18/04 ) (CV) (Entered: 08/13/2004)
16 PROPOSED RECEIVED Agreed Protective Order re: motion to enter agreed protective order [14-1] submitted by defendant (CV) (Entered: 08/13/2004)
17 ORDER by Judge Lonny R. Suko granting motion to expedite hearing on motion to enter agreed protective order [13-1] (cc: all counsel) (PP) (Entered: 08/23/2004)
18 AGREED PROTECTIVE ORDER by Judge Lonny R. Suko : granting document proposed [16-1] (cc: all counsel) (PP) (Entered: 08/23/2004)
19 CONSENT DECREE; terminating case. Signed by Judge Lonny R. Suko. (CV, Case Administrator) (Entered: 10/26/2004)
20 ORDER CLOSNG FILE. Signed by Judge Lonny R. Suko. (CV, Case Administrator) (Entered: 10/26/2004)

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