UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

04-7 4I

Plaintiff,

Civil Action No.:

go

Honorable t ~-~{- D. BO~~

VICTORY LANE,

MAGISTRATE VIR6 IA M. MORGAN

Defendant. /

COMPLAINT AND JURY

TRIAL DEMAND

FILED

MAY 2 8 2004 NATURE OF THE ACTION
CLERK’S OFFICE, OETROIT-PSG U.S. DISTRI6T COU.R’["
This is an action under Title VII of the Civil Rights Act of 1964, and Title I of the Czvilt~ights

Act of 1991, to correct unlawful employment practices on the basis of sex, and to provide appropriate

relief to Anna Brooks, who was adversely affected by such practices. The EEOC alleges that

Defendant, Victory Lane, ("Defendant" or "Victory") subjected Brooks to a sexually hostile work

environment and that the Defendant, despite knowledge of the harassment, failed to take prompt and

effective action to correct and prevent the harassment.

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451,1331, 1337, 1343,

and 1345. This action is authorized and instituted pursuant to Sections 706(t)(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, 28 U.S.C. §§ 451, 1331, 1337, 1343

and 1345. 2.

The employment practices alleged to be unlawful were and are now being committed

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

Southern Division.

3. Plaintiff, the Equal Employment Opportunity Commission, ("EEOC" or 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(0(1) and (3) of Title VII, 42 U.S.C. §§ 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant, Victory Lane, has continuously been a corporation

doing business in Ypsilanti, Michigan, and has continuously had at least 101-200 employees.

5. At all relevant times, Defendant Employer 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).

STATEMENT OF CLAIMS

6.

More than thirty (30) days prior to the institution of this lawsuit, Anna Brooks, filed

a charge with the Commission alleging violations of Title VLI by Defendant Employer. All conditions

precedent to the institution of this lawsuit have been fulfilled.

7. Since at least May of 2003, Defendant Employer has engaged in unlawful employment

practices at its Ypsilanti, Michigan facility, in violation of Section 703(a), 42 U.S.C. § 2000e-2(a).

The unlawful employment practices include, but are not limited to, the following five incidents

during the month of May 2003:

a.

Will Roberts created a hostile work environment for Brooks beginning in May

2

2003. On or about May 2003, Roberts came up behind her and tickled her back and sides. Brooks told him to stop and tried to leave but Roberts blocked the doorway, wrapped his arms around her and tried to kiss her neck. Roberts then put his face between Brook’s breasts. b. On or about May 2003, Brooks was in the office at closing time and Roberts asked her for a kiss. Brooks said no and tried to leave but Roberts grabbed her, pushed her back into a comer and tried to put his face in her breasts. c. On another occasion in 2003, Roberts moved his hands from Brooks arms to herbreasts and she told him to stop. Roberts tl~en pushed his body against her and started rubbing the front of her pants. d. On or about May 2003, Roberts pushed Brooks into the back wall of the bathroom and started grabbing her breasts and groping her butt. Brooks yelled for him to stop. e. Defendants, having knowledge of the harassment by Roberts, failed to take effective corrective action to end the harassment and prevent if from recurring. 8. The effect of the unlawful conduct complained of in paragraph 7, above, has been to deprive the Brooks ofequai employment opportunities and otherwise adversely affect her status as an employee because of her sex, female. 9. The unlawful employment practices complained of in paragraph 7, above, were and are intentional. 10. The unlawful employment practices complained of in paragraph 7, above, were done with malice or with reckless indifference to the federally protected rights of Brooks.
3

PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. GRANT a permanent injunction enjoining Defendant Employer, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in sexual ’harassment and any other employment practice wl~ieh discriminates on the basis of sex; B. ORDER Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices; C. ORDER. Defendant Employer to provide training on Title VII of the Civil Rights Act of 1964, as amended, and its prohibitions against sexual harassment to all of its employees at its Victory Lane of Ypsilanti, Michigan facility and its human resources department;. D. ORDER. Defendant Employer to make whole Anna Brooks by providing appropriate monetary relief, in the form of compensatory damages in the amounts to be proven at trial; E. ORDER Defendant Employer to pay Anna Brooks punitive damages for its malicious or reckless conduct described in paragraph 7, above, in amounts to be proven at trial;
GRANT such further rclief as the Court deems necessary and proper in the public interest; and
I. AWARD the Commission its costs for tl~is action.
4

JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint.
Rcspectfully submitted,

ERIC S. DILEIBAND General Counsel
JAMES N. LEE Deputy General Counsel

DATED: May 28, 2004

ADELE RAPPORT ~/P~4833) Regional Attorney
ROBERT K. DAWIed’NS (P38289) Supervisory Trial Attomey
TRINA MENGESHA (P59458) Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION DETROIT DISTRICT OFFICE Patrick V. McNamara Building 477 Michigan Avenue, Room 865 Detroit, Michigan 48226 Telephone: (313)226-5673

JS 44 11/99 CIVIL COVER SHEET COUNW W. C. T.tS ACnON AROSe: Washtnaw

The JS~44 civil cover sheet and the Information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. except as provided by local rules of court. This form, approved by the Judicial Conforanc.~h~lntted States ~n September 1974, Is required

foruseoftheClerkofCourtforthepurposoofinit~afingthecivildocketsheet;ENDAN’I~W ,,I;--K’="

I. (a) PLAINTIFFS

DEI

-- ’72041

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

VICTORY LANE

PAUL D. BORMAN

(b) County of Residence of Rmt Listed (C) Attorney’s (Firm Name, Address, and Telephone Number)

NOTE:IN ~D CONDEMNATION ~E~, M~E THE LO~TION OF THE ~ND INVOLVED.
AUorneys (If Kno~)

TRINA MENGESHA (P59458) (313) 226-4620
U.S. EEOC, Detroit District OlYiee 477 Michigan Ave.. Rm 865. Detroit. MI 48226 I1. BASIS OF JURISDICTION (F,=ace an’X* =n One Box Only)

C~-~=2, Government Plaintiff

[] 3 Federal Question (U.$. Government Not a Party)

Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Place an’X" in One 8ox foe P[alnliff

(For Diversity Cases O~ly)

and One Box Io~ Defendant)

PLA DEF

PLA DEF

Citizen of This Stata [] I [] t incorporated or Princip-~l Piaca [] 4 [] 4 of Business In This State

[] 2 U.S. Government Defendant

[] 4 Diversity (Indicate Citizenship of PaNes in Item 111)

CitizenofAnother [] 2 [] 2 Incorporated andPdncipal [] ,5 [] 5 of Bus]hess In Another State
Citizen or Subject of a [] 3 [] 3 Foreign Nation

Forolon Coun~w

IV. NATURE OF SUIT
CONTP,~CT

(Place nn "X" in One [],ox.Only) TORTS

FORPF~TTURE/PENALTY.

BANKRUPTCY

OTHER STAT~TE~

1 1 0 Insunmce [] 120 Medea [] 130 Miller Act [3 t40 Negotiable Instrument
150 Recovery of Overpayment and Enfoccemen| of Judgment
0 151 Msdicam Act

PERSONAL INJURY PERSONAL INJURY

f’l ,31 0 Akpla~a

I"I 362 Personal InJuw.

0 315 Aiq}lane Product

Mad. MalprsatJce

Liability r-i

0 3 6 5 ~eoc~uOc~%lan~F ¯

320 Assault Libel And Slander

0 368 Asheslos Personal

Injury Product

[] 330Federal Employee

Liability

[] 610 Agriculture [] 620 Other Food & Drug
625 Dn~g R~.at~:l Seizure of Properly 21:881
[] 630 Liquor Laws
[] 640 R,R. & TnJck r’l 650 Ndine Rags,

0 152 Recovery of Defaulted Student Loans

Uibl|i~
I"I 340 Madne

{F.Jc¢I. Valamns)

I~ 345 Madne Product

153 R~co~e/of Oveq:,ayment

U,mbil~ty

of Vetsrsn’s Benefits Cl 350 MotarVehic~e

0 160 Stockholders’ Suits [] 355 MotarVahlde

190 Olher Contract

Pmducl Liability

[] 660 Ocoupalionsl

PERSONAL PROPeRlY’

Safely~Health

I-I 370 Other Fraud r-1 371 Truthln Landing rl 380 Other Personal

[] 690 Other I.,A~OR

Properly Damsge [3 385 Properly Damage

710 Fak Lsbo¢ Sl=~dards

0

lg5 Contract Pn;~luct Uablllty

O 360 Othar Personal Inju~

Pmducl Liabilily

720 Labor/Mgmt, Relations

REAL PROPERTY

CIVIL RI’GHTS

PRISONER PETITIONS 730 ~mL R~

[] 210 Land Condemnation.,.. 1~&41 Voting

C] 51 0 Motions to Vacate

220 Foreclosure / 230 R~t Laale & Ejectment/

.O~(j4~4:32

HEomupsloinygm/ ent

SentenCe Habeas Corpus:

[] []

240 Teals la Land 245 Ted Product Liability 290/Ul Other Real Prop~

/ Ac:commodBtlont Q 444 Walf~tte [] 440 OtherCivll Rights

r’l 530 General I-I 535 Dealh Penalty I’~ 540 Ma!qd~lIBgl

0 $50 Civil Rights

& Olmdomu~ ~ 740 Railway ~r ~t
79~ O~er Ls~r U~g~tion
79I EmpL Rel. I~. S~udty ACt

r~ 555 P~on Condition

[] 422 Appeal 28 USC 158
I"1 423 Withdrawal 28 USC 157
PROPER’tY RIGH’FS
fl 820 Copyrights [] 830 Palent [] 840 Trademark
.... 8OCIAL SECURITY
[] 861H IA (1395tl) f’l 862 Black Lung (923) [] 863 D~Nc/or~v¢ [3 864 SS[O Title XVi [] 865 RSt(405(g)}
FEDERAL TAX SUITS 870 Taxes (U.S. Plaintiff
or Dalandant)
[] 871 IRS.Thltd Pan’y 26 USC 7609

~ 400,Slate Reapportionment [3 41 0Anti,usa r-I 430 Banks and Banking ~1 450 CommerCe/ICC [] 460 Depodatio~
[] 470 Racketeer Influ~"w~d & ComJpt
r’l 8~OSaiact~va Service [] 850 ~.~ou
Exchange r-I 875 Customer Cha~tsnge
12 LISC 3410 r’l 891 Agricultural Acts
[] 892 Economlo
[] 803 Envb’onm~ta~
C] 894 Energy Allocation Act m 895 Freedom of
Informal~on Act r~
D~,|e~mln~ltatt Equal
O 950 Constitutiocmlity of Slate Statulas
[] 890 Olhar Statu|ory

ORIGIN
/~....~
P~lng

(PLACE AN "X" IN ONE BOX ONLY)

2 State Coud

3 Ap~llate ~d

4 Relnstato¢~ ~nod

TaRnS famed from

another dlslrict

5 (speofy)

[] 6 M,L~ilttigl adtiisotnrict

Appeal to District 7 Judge from [] Magistrate

This is an action under Title VII of the Civil Rights Act of 1964, and Title I of the Civil Rights Act o£ 1991, to correct unlawful employment

.~r~tlr-a~ ,nn the hn~i~

VII. REQUESTED IN [] CHECK IF THIS IS A CLASS ACTION $DEMAND

CHECK YES only if~doma~ed In complaint:

COMPLAINT: UNDER F.R.C.P, 23

JURY DEMAN~ No

(See
Vlll. RELATED CASE(S) instructions): IF ANY

JUDGE

DOCKET NUMBER

DATE \ ~

.~"~’-~..._~,,..~"~rl’~T= URE, OF A’I~’ORNEY OF RECORD ~

PURSUANT TO LOCAL RULE 83.11 1. Is this a ease that has been previously dismissed?
If yes, give tile following information:
Courti .Case No.: Judge:. Other th:m stated above, are there any pending or previously discontinucd-_._.~Ycs
or dismissed companion cases in this or any other court, including s[’atc/..---~"~ court? (Companion cases arc matters in which it appears substa,ntiall~. [8_l N~) similar evidence will be offered or the same or related parties are prc~ and tile cases arise out of the same transaction or occurrence.) If yes, give the following information:
Court: Case No.: Judge:.
Notes:
DI:LIB:2511027.1\125280-00001

 
 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

J F Il E ~ IJ.. ~a~ I ®~N1A~5 CLERK'S OFFICe
U. S. DISTRICT COUf'!T EASTERN MICHIGAN

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.
Plaintiff, v.
VICTORY LANE, Defendant.

CIVIL ACTION NO. 04-72041
HONORABLE PAUL D. BORMAN
~lE C lE ~ 'X1lE~
JAN - 3 2005
CLERK'S OFFICE. DETftOIT·PSG U.S.DISTRICT COURT

"",.i
.)

ADELE RAPPORT (P44833)

DAVID E. KEMPNER (P23329)

ROBERT K. DAWKINS (P38289)

PEAR SPERLING EGGAN &

TRlNA MENGESHA (P59458)

DANIELS, P.C,

EQUAL EMPLOYMENT OPPORTUNITY

Attorneys for Defendant

COMMISSION

24 Frank Lloyd Wright Drive

Attorneys for Plaintiff

Ann Arbor, Ml481 05

477 Michigan Ave., Room 865

(734) 665-4441

Detroit, Ml. 48226

(313) 226-4620

... - - - - - - - - - --- ..... --------~--------------

....

CONSENT DECREE

I. Plaintiff, the United States Equal Employment Opportunity Commission (the "Commission"), conullcnced this action in the United States District Court for the Eastern District of Michigan. alleging that the Defendant, Victory Lane, ("Defendant"). subjected the Charging Party. Anna Brooks, to sexual harassment in violation ofTitlc VII of the Civil Rights Act ("Title VII") of 1990 and Title I of the Civil Rights Act of 1991.
2. As a result of settlement discussions, the Commission and the Defendant have resolved their differences and have agreed that this action should be settled by entry of this Consent Decree. It is the intent of the parties that this Consent Decree be a final and binding

settlement in full disposition of any and all claims alleged against the Defendant or which might have been alleged against the Defendant in the Complaint.
STIPULATED FACTS 3. The Commission is the agency of the United States government authorized by Title VII to investigate allegations of unlawful employment discrimination against women and to bring civil actions to prohibit unlawful practices, and to seek relief for individuals affected by such practices. 4. Pursuant to Title Vll, the parties acknowledge the jurisdiction of the United States District Court for the Eastern District of Michigan, over the subject matter and the parties to this case for the purpose of entering this Consent Decree and, if necessary, for enforcing this Consent
Decree. 5. Venue is appropriate in the Eastern District of Michigan. For purposes of this
Consent Decree and any proceedings related to this Consent Decree only, the Defendant agrees lh~t all statutury conditions precedent to the institnrion of this lawsuit against it have has been fulfilled.
FINDINGS 6. Having examined the terms and provisions of the Consent Decree and based on the pleadings, records, and stipulations of the parties, the Court finds the following:
a. The COUrl has jurisdiction over the subject matter of the action and the
parties to this action. b. The terms and provisions of this Consent Decree ,Ire fair, reasonable, and
just. The rights of the Defendant and the Commission are protected adequately by this Con~ent Decree.
2

c. This Consent Decree conforms with the Federal Rules of Civil Procedure and Title VII. and is not in derogation of the rights and privileges of any person. Th", entry of this Consent Decree will further the objectives of Title VlI and other applicable law and will be in the best interests of the parties and those for whom the Commission seeks relief. NOW, TifEREt'ORE, IT IS HEREBY ORDERED. ADJUDGED AND DECREED AS FOLLOWS:
NON-ADMISl'!ION 7. This Consent Decree, being entered with the consent of the Commission and the Defendant, ~hal1 not constitute an adjudication or finding on the merits ofthe case and shall not be construed as an admission by the Defendant of any violation of Title VII or any other law, rule or regulation dealing with or in connection with equal employment opportunities. Similarly. consent to performance under this Consent Decree by the Commission does not constimte an admission that any claim asserted by it in this lawsuit was not valid or that any defense of the Defendant was
valid.
NON.DISCRIMINATION 8, The Defendant, its officers, agents, employees, S<lccessors, assigns and all persons in active concert or participation with them or any of them shall comply with the provisions of Title VII, 42 USC § 12101 et seq., with regard to sex discrimination and sexual harassment.
NON-RETALIATION 9. The Defendant shall not take any action against any person which constitutes intimidation, retaliatiun, harassment or intcrfcrence with the exercise of such person's rights under Title VII because of the tiling of Charge No. 230-2003-02098 with the Commission, which forms
3

the basis for the present case, or because such person gave testimony or assistance or participated in any manner in any investigation or proceeding in connection with this case under Title VII.
MONETARY COMPENSATION
10. Defendant shall pay Anna Brooks the total sum of seven thousand five hundred
dollars ($7,500) This monctary compensation shall be paid in one check made payable to Anna Brooks, clo Mr. and Mrs. Brooks, 12710 Tuttle lIill, Willis, MI 48191. Defendant shall mail this payment no later than fifteen (15) days of entry of this decree wilh the court. No tax withholdings will be deducted and Defendnl1t will issue a Form 1099 to Anna Brooks for tax purposes. Defendant shall mail copies of the ch~ck (0 Adele Rapport, Regional Attorney, 477 Michigan Avenue, Suite SU5, Detroit, Michigan 48226. The Commission shall have the right (0 monitor compliance with this paragraph through inspection of all docunlents relating to said disbursement, including but not limited to, a copy ofthe check, check stub, return receipt, letters, and any other documents evincing payment hereunder.
TRAINING Al'iD/OR EDUCATIONAL PROGRAMS 11. Defendant agrees to train all managers and supervisors, including its corporate office, on the laws prohibiting employment discrimination, addr"'ssing all [onTIs of protected class discrimination, including sexual harassment. All employees, as stated ahove, will receive (his training within four (4) months of ontry of this decree. Derendant will provide all new employees with training and/or infonnation pursuant to its sexual harassment policy and complaint process which is disseminated to each newly hired employee. During the time that this Decree is in effect, Defendant shall provide the Commission with copies ofits training efforts, including but not limited lo, the dates of training, fomlat afthe (raining and the names of the attendees.
4

POSTING OF NOTICE 12. Dctcndant agrees (0 post the notice attached as exhibit A to this decree.
DURATION 13. This Consent Decree shall remain in effect for twenty-four (24) months.
DISPUTE RESOLUTION AN)) COMPLIANCE 14. The Coul1 shall retain jurisdiction and will have all available equitable powers, including injunctive relief, to enforce this Consent Decree. Upon motion ofany party, the Court may schedule a hearing for the purpose of reviewing compliance with this Consent Decree. The parties shall engage in a good faith effort to resolve lUIy dispute as to compliance prior to seeking review by th. Courl, ami shall be required to give notice to each other ten (10) days belore moving for such review. All parties may conduct expedited discovery under the Federal Rules ofCivi I Procedure for purposes ofdetennining compliance with this Consent Decree or defending against a claim of noncompliance, with fifteen (15) business days notice for depositions, entry to premises and access to documents and, with fifteen (15) business days for responses to written discovery.
MISCELLANKOUS 15. Except as expressly provided herein, all parties sltall bear th"ir own costs and expenses oflitigation. including attomey fees. 16. This Consent Decree constitutes the entry of final judgment, within the meaning of Rule 54 ofthe Federal Rules orCivil Procedure, on all claims asserted ill or which might have been asserted in this action. This couli retains jurisdiction over this matter, however, for the pUJ:pose of entering appropriate orders interpreting and enforcing this judgment. 17. If any provisiol1(s) of this Consent Decree is found to be unlawful, only the specific provisions in question shall be affected and the other provisions will remain in full force and effect.
5

The terms ofthis Consent Decree arc and shall be binding upon the present and future
owners, creditors and successors of the Defendant.
19. This Consent Decree constitutes the entire agreement and commitments of the parties.
Any modifiealiom to this Decree must be mutually agreed upon and memorialized in a writing
signed by authorized representatives of the Defendant and the Commission.
20. When this Consent Decree requires or permits the submission by the Defendant of
allY documents to the Commission, ifnot otherwise indicated in the Decree, they shall be mailed by
certified mail to: Adele Rapport, Regional Attomey, EEOC, Detroit District Office, 477 Michigan
Avenue, Suite 865, Patrick V. McNamara Building, Detroit, Michigan 48226.
SO ORDERED this the ~ day oG'-\r\l1,~ ,:m:.:::,
~-
HaN. PAUL D. BORMAN United States District Judge
WE HEREBY COKSENT:
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
/'.
ADE~P(~·±'l~f..tp""'zt=":"83:-::-:3)---­
Regiona! Attorney 477 Michigan Avenue, Suite 865 Detroit, MI 48226 (313) 226-6701
VICTORY LANE
1/~~~&0
DAVlD E. KEMPNER (P23329)
PEAR SPERLING EGGAN & DANIELS, P.C.
24 Frank Lloyd Wright Drive Ann Arbor, MI 48105
(734) 665·4441
6

ATTACHMENT A NOTICE
This Notice is being posted pursuant to a resolution of a lawsuit against Victory Lane by the Equal Employment OpportWlity Commission. This Notice is to infollll you of your rights guaranteed by Cederallaw under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e, et seg. ("Title VII"). This federal law prohibits discrimination on the basis ofrace, color, sex, religion, and national origin with regard to any term or condition of employment, hiring, layoff, recall, promotion, discharge, pay and fringe benefits, and also prohibits retaliation for opposing unlawful employment practices or because an employee has made a charge, testified, assisted or participated in any manner in an investigation or litigation conducted by the United States Equal Employment Opportunity Commission.
The United States Equal Employment Opportunity Commission ("EEOC") is the federal agency which investigates charges ofunlnwful employment discrimination and if necessary, brings lawsuits in federal court to enforce Title VII.
Victory Lane supports and will comply with Title VII in all respects and will not take any action against any employee because they have exercised their rights under this law.

DATED

VICTORY LANE CORPORATION

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

https://ecf.mied.uscourts.gov/cgi-bin/DktRpt.pl?518927971582812-L_3...

U.S. District Court Eastern District of Michigan (Detroit) CIVIL DOCKET FOR CASE #: 2:04-cv-72041-PDB-VMM

CLOSED

Equal Employment Opportunity Commission v. Victory Lane Assigned to: Honorable Paul D Borman Referred to: Honorable Virginia M Morgan Cause: No cause code entered

Date Filed: 05/28/2004 Date Terminated: 01/12/2005 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Adele Rapport Equal Employment Opportunity Commission 477 Michigan Avenue Room 865 Detroit, MI 48226 313-226-5670 Email: Adele.Rapport@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Robert K. Dawkins Equal Employment Opportunities Commission 477 Michigan Avenue Suite 865 Detroit, MI 48226 313-226-4600 Fax: 313-226-2778 Email: robert.dawkins@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Trina R. Mengesha Equal Employment Opportunities Commission 477 Michigan Avenue Suite 865 Detroit, MI 48226 313-226-4600 Fax: 313-226-2778 Email: trina.mengesha@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

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

https://ecf.mied.uscourts.gov/cgi-bin/DktRpt.pl?518927971582812-L_3...

V. Defendant Victory Lane

represented by David E. Kempner Pear, Sperling, 24 Frank Lloyd Wright Drive Suite C-200 Ann Arbor, MI 48105 734-665-4441 Email: dkempner@psedlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Francyne B. Stacey Pear, Sperling, (Ann Arbor) 24 Frank Lloyd Wright Drive Suite C-200 Ann Arbor, MI 48105 734-665-4441 Email: fstacey@psedlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 05/28/2004 06/28/2004 07/26/2004 08/06/2004
01/12/2005

#

Docket Text

1 COMPLAINT filed by Equal Employment Opportunity Commission against Victory Lane.(DHame, ) (Entered: 06/03/2004)
2 NOTICE of Appearance by Francyne B. Stacey, David E. Kempner on behalf of Victory Lane (LHack, ) (Entered: 07/02/2004)
3 ANSWER to Complaint with Affirmative Defenses, Jury Demand by Victory Lane.(DHame, ) (Entered: 07/29/2004)
4 SCHEDULING ORDER: Dispositive Motion Cut-off set for 3/3/2005 Signed by Honorable Paul D Borman. (Refer to image for additional dates)(JPar, ) (Entered: 08/12/2004)
5 CONSENT DECREE JUDGMENT Signed by Honorable Paul D Borman. (DHame, ) (Entered: 01/28/2005)

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

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