IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

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COMMISSION,

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Plaintiff,

)

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v.

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PAPA JOHN'S USA, INC.,

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Defendant

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NATURE OF THE ACTION

CIVIL ACTION NO. COMPLAINT JURY DEMAND

This is an action under Title I of the Americans with Disabilities Act of 1990

(hereafter the "ADA") and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of disability and to provide appropriate relief to Sean Stanley, who was adversely affected by such practice. Plaintiff Equal Employment

Opportunity Commission (hereafter "Plaintiff" or "the Commission") alleges that Defendant

Papa John's USA, Inc. (hereafter "Defendant") has violated the ADA by refusing to hire Mr. Stanley because of his impairment, use of a wheelchair.
JURISDICTION AND VENUE

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

1343, and 1345. This is an action authorized and instituted pursuant to Section 107(a) of the ADA, 42 U.S.C. §12117(A), which incorporates by reference Sections 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964 ("Title VII"), 42 U.S.C. §§2000e-5(f)(1) and (3), pursuant to Section 1977A of the Civil Rights Act of 1991, 42 U.S.C. §11981(a).

Case 3:05-cv-01027 Document 1 Filed 12/05/2005 Page 1 of 6

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2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Middle District of Tennessee, Nashville Division.
PARTIES 3. Plaintiff Equal Employment Opportunity Commission (the "Commission") is the agency of the United States of America charged with the administration, interpretation and enforcement of the ADA, and is expressly authorized to bring this action by Section 107(a) of the ADA, 42 U.S.C. §12117(a), which incorporates by reference Section 706(f)(1) of Title VII, 42 U.S.C. §2000e-5(f)(1). 4. At all relevant times, Defendant Papa John's USA, Inc. ("Employer") has continuously had at least 15 employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of §101(5) of the ADA, 42 U.S.C. §12111(5), and Section 107(7) of the ADA, 42 U.S.C. §12117, which incorporates by reference Sections 701(g) and (h) of Title VII, 42 U.S.C. §2000e(g) and (h). 6. Defendant Employer has been a covered entity under Section 101(2) of the ADA, 42 U.S.C. §12111(2).
2
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n-

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STATEMENT OF CLAIMS
7. More than thirty days prior to the institution of this lawsuit, Sean Stanley filed a charge with the Commission alleging a violation of the ADA by Defendant Employer. All conditions precedent to the institution of this lawsuit have been fulfilled.
8. Since on or about May 12, 2005, Defendant Employer has engaged in unlawful employment practices at its Nashville, Tennessee, facility in violation of ADA Sections 102(a),and (b)(5), 42 U.S.C. §12112(a) and (b)(5). These unlawful practices include failure to hire Sean Stanley because of his disability.
9. On or about May 12, 2004, Sean Stanley applied for a position at the Nashville, Tennessee, location of Defendant (Store #85).
10. Mr. Stanley was interviewed by Glen Larkins, store manager. 11. Mr. Larkins gave him a tour of the facility and pointed out where Mr. Stanley would work. 12. Mr. Larkins gave Mr. Stanley a company handbook to read in order to learn how to use the computer at the store. 13. Mr. Larkins advised Mr. Stanley to call the following Monday to get his work schedule. 14. Mr. Larkins met with his district supervisor, Mr. Adams, regarding the hiring of Mr. Stanley. 15. When Mr. Adams learned of Mr. Stanley's disability, Mr. Adams told Mr. Larkins not to hire Mr. Stanley. 16. When Mr. Stanley called on or about May 17, 2004, Mr. Larkins advised Mr.
3
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Stanley that he would not be hired. 17. The reason given was that Defendant had no openings for part time employees. 18. On or about May 24, 2004, Defendant hired two part-time employees. 19. Between May 30, 2004, and November 4, 2004, Defendant hired eleven part-time employees at the Nashville location where Mr. Stanley applied.
20. The unlawful employment practices complained of in paragraphs 9 - 19
above were and are intentional.
21. The unlawful employment practices complained of in paragraphs 9 - 19
above were and are done with malice or with reckless indifference to the federally protected rights of Sean Stanley and other potential employees.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court:
A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in refusal to hire and any other employment practice which discriminates on the basis of disability.
B. Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for qualified individuals with disabilities, and which eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant to make whole Sean Stanley, by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other
4
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- - - --

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-- u -

u - -u_- - u -- -

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affirmative relief necessary to eradicate the effects of its unlawful employment practices.
D. Order Defendant to make whole Sean Stanley by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices
described in paragraphs 9 - 19 above in amounts to be determined at trial.
E. Order Defendant to make whole Sean Stanley by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 9 - 19 above, including emotional pain, suffering, inconvenience and humiliation, in amounts to be determined at trial.
F. Order Defendant to pay Sean Stanley punitive damages for its malicious and reckless conduct, as described in paragraphs 9 - 19 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 of this action.

5 Case 3:05-cv-01027 Document 1 Filed 12/05/2005 Page 5 of 6

JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
~wl;v;1Gl
KATHARINEW. KORES t Regional Attorney TN Bar No. 06283
0 tJ~N (k.
FAYE~ILLlAM~ Supervisory Trial Attorney TN Bar No. 11730 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1407 Union Ave., Suite 621 Memphis, TN 38104 (901) 544-0088
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 50 Vantage Way, Suite 202 Nashville, TN 37228 (615) 736-2105
6
Case 3:05-cv-01027 Document 1 Filed 12/05/2005 Page 6 of 6

 
 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE
AT NASHVILLE

UNITED STATES EQUAL EMPLOYMENT )

OPPORTUNITY COMMISSION,

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Plaintiff

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and

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SEAN STANLEY

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COMPLAINT: 3-05-1027

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Plaintiff-Intervenor

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JURY DEMAND

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-v.-

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PAPA JOHN’S USA, INC.,

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Defendant.

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________________________________________________________________________

COMPLAINT IN INTERVENTION ________________________________________________________________________

1. Plaintiff Sean Stanley, by counsel, brings this action against the Defendant Papa

John’s USA, Inc. d/b/a Papa John’s Pizza for Defendant’s intentional and unlawful

discrimination against the plaintiff resulting in failure to hire plaintiff, or in the alternative

wrongful termination of the plaintiff because of his disability. Plaintiff also brings a claim of

intentional unlawful discrimination for failure to hire, or in the alternative wrongful termination

in violation of the Tennessee Handicapped Discrimination Act and Tennessee public policy.

Plaintiff demands a jury trial as to all issues of fact raised in his Complaint.

2. This action seeks equitable relief, back pay, front pay, compensatory damages,

punitive damages, costs, expert witness fees, and attorney fees for intentional unlawful

discrimination and wrongful termination based on disability.

Case 3:05-cv-01027 Document 11 Filed 02/07/2006 Page 1 of 5

JURISDICTION AND VENUE 3. This action arises under the Americans with Disabilities Act. (“ADA”), 42 U.S.C. §12101 et seq. and the Tennessee Handicapped Discrimination Act (“THA”), T.C.A. § 8-50103(a). 4. Jurisdiction over the federal claim set forth in this complaint is invoked pursuant to 42 U.S.C. § 12117 and 28 U.S.C. §§ 1331, 1337, 1343. Jurisdiction over the state law claim set forth in this Complaint is invoked pursuant to this Court’s supplemental jurisdiction as provided in 28 U.S.C. § 1367. 5. Within 300 days of the adverse action taken against plaintiff by defendant, plaintiff filed charges of employment discrimination with the Equal Employment Opportunity Commission. Plaintiff filed this action within a timely manner. 6. Venue for this action properly lies in the United States District Court for the Middle District of Tennessee at Nashville pursuant to 28 U.S.C. § 1391 because the events giving rise to these claims occurred in this judicial district. Further, the defendant can be found and transacts business in this judicial district. 7. Equitable relief, including but not limited to back pay and front pay, is sought pursuant to 42 U.S.C. § 12117. Compensatory and punitive damages are sought pursuant to 42 U.S.C. § 1981a. Costs and attorney’s fees, and expert witness fees are sought pursuant to 42 U.S.C. § 12205.
PARTIES 8. Plaintiff is an adult male citizen of the United States who resides in Davidson County, Tennessee. Plaintiff is disabled and uses a wheelchair. Plaintiff suffers from muscular dystrophy, a degenerative nerve disease.
Case 3:05-cv-01027 Document 11 Filed 02/07/2006 Page 2 of 5

9. Defendant Papa John’s USA, Inc. is a foreign corporation doing business in Tennessee with its principal place of business located in Louisville, Kentucky. Defendant transacts business within the Middle District of Tennessee and has several locations. Defendant is an employer as defined by the Americans with Disabilities Act, 42 U.S.C. § 12111.
CLAIMS FOR RELIEF - ADA, THA 10. Defendant, by and through its agent, engaged in unlawful policies and practices in violation of 42 U.S.C. § 12112 et seq., and T.C.A. § 8-50-103(a) by intentionally and willfully discriminating against the plaintiff because of his disability commencing in or about May 12, 2004. These unlawful practices include failure to hire Sean Stanley because of his disability, or in the alternative wrongful termination because of his disability. 11. Defendant employs over 500 employees. 12. In May 2004, plaintiff went for a job interview with the store manager, Glen Larkins, at the defendant’s Lebanon Pike location in Nashville after receiving information from a current employee of said location that defendant was hiring at that location because they were understaffed. 13. During the interview Mr. Larkins discussed the job duties with plaintiff which included “in store” work in the form of taking phone orders and folding pizza boxes. Mr. Larkins determined plaintiff could perform the essential functions of the job for “in store” work in this capacity. 14. Following the interview, Plaintiff was provided a copy of the employee handbook. Plaintiff was told to call the store at the beginning of the next week to get his work schedule. The hiring manager set up a work station toward the back of the store so that plaintiff would not be in the “flow of traffic” while performing his job duties.
Case 3:05-cv-01027 Document 11 Filed 02/07/2006 Page 3 of 5

15. Mr. Larkins met with his district supervisor, Mr. Adams, regarding the hiring of Mr. Stanley. When Mr. Adams learned of Mr. Stanley’s disability, Mr. Adams told Mr. Larkins not to hire Mr. Stanley.
16. Plaintiff called the store at the beginning of the next week as instructed by Mr. Larkins but was told by Mr. Larkins that plaintiff would not be able to work for the defendant because they were no longer hiring new employees even though they were severely understaffed.
17. When questioned as to why he was hired for the position a few days prior, Mr. Larkins told Mr. Stanley that he was sorry but the only explanation he could give was that he was instructed by his boss to tell him this information.
18. Within a few days after plaintiff was told that he would not be hired for the position, even though they were severely understaffed, the defendant hired two additional workers to perform “in store” tasks at the Lebanon Pike location. Over the next few months defendant hired several additional “in store” employees at the Lebanon Pike location.
19. Defendant intentionally do not hire Mr. Stanley, or in the alternative, wrongfully terminated Mr. Stanley because of his disability in violation of his protected rights under federal and state law.
20. As a direct and proximate result of the defendant’s intention and willful conduct, plaintiff has suffered lost income and emotional damages, including embarrassment and humiliation.
WHEREFORE, plaintiff demands judgment against Papa John’s USA, Inc. in the amount of $300,000 in actual and compensatory damages and $300,000 in punitive damages. Plaintiff requests judgment for back pay, front pay, costs incurred in this action, including a reasonable attorney’s fee and expert witness fees. Plaintiff requests that this Court enjoin defendants from
Case 3:05-cv-01027 Document 11 Filed 02/07/2006 Page 4 of 5

any further conduct constituting discrimination on the basis of disability. In addition, plaintiff requests such other and further relief as this Court may determine just and proper.
Respectfully Submitted, s/ Cody Allison
___________________________ K. CODY ALLISON, BPR 20623 Am South Center, Fifteenth Floor 315 Deaderick Street Nashville, Tennessee 37238 (615) 244-3331 Attorney for Plaintiff-Intervenor
Case 3:05-cv-01027 Document 11 Filed 02/07/2006 Page 5 of 5

 
 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMM ISSION,
Plaintiff, SEAN STANLEY,
Plaintiff Intervenor
PAPA JOHN'S USA, INC.. Defendant.

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)

)

)

CIVIL ACTION NO,

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3 :0 5-1027

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Judge Trauger!

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Magistrate Judge Brown

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JURY DEMAND

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CONSENT DECREE INTRODUCTION
This action was instituted by the Equal Employment Opportunity Commission (hereinafter the "Commission") on December 5, 2005, against Defendant, Papa John's USA, Inc" pursuant to Section 107(a) of the Americans With Disabilities Act of 1990 ("ADA"), 42 U.S_C §12117(a), which incorporates by reference Sections 706(f)(1) and (3) of Tille VII of the Civil Rights Act of 1964 ("Title VII"), 42 U.S,C. §§2000e-5{f)(1) and (3), and pursuant to Section 102 of the Civil Rights Act of 1991 . 42 U _S.C_ §1981 {al _ The Complaint alleged thai Defendant fa iled to hire Sean Stanley for an in-store part-time poSition because of hiS impairment, use of a wheelchair. Mr. Stanley intervened in this action on December 14, 2005,
ThiS Consent Decree does not constitute an admission by the Defendant of the allegations of the Complaint. The Defendant maintains that the actions of its officials

Case 3:05-cv-01027 Document 35 Filed 12/04/2006 Page 1 of 5

were proper and lawful in all regards. However. all parties to this action desire to avoid the additional expense and delay in this litigalion of this case.
This Consent Decree constitutes the complete and exclusive agreement between the Commission, Mr. Stanley, and Papa John·s USA, Inc. No waiver, modification or amendment of any provision of this Decree shall be effective unless made in writing. No representations or inducements to compromise this action have been made. other than those recited or referenced in this Decree. In the event this proposed Consent Decree is not approved or does not become final, it shall not be admissible in evidence in any subsequent proceeding in this action.
The Court has reviewed the terms of the proposed Consent Decree in light of the applicable laws and regulations. the statements and representations of counsel for all parties. and hereby approves the Consent Decree.
tt is hereby ORDERED, ADJUDGED AND DECREED:
I. JURISDICTION The United States District Court for the Middle District of Tennessee. Nashville Division. has jurisd iction over the parties and subject matter of this litigation.
II. SCOPE AND DURATION OF DECREE A. This Consent Decree resolves all issues and claims arising out of the Commission'S and Intervenor's Complaints in th is cause. alleging unlawful employment policies and practices maintained by the Defendant and arising out of Charge No. 253·
, 2005·00279 filed by the Charging Party. Sean Stanley, with the Commission
Case 3:05-cv-01027 Document 35 Filed 12/04/2006 Page 2 of 5

Notwithstanding any provisions contained in Ihis Decree. this agreemenl shall not be considered in any manner 10 be dispositive of any charge now pending before any office of the CommiSSion other than Charge No. 253-2005-00279.
B The provisions of this Consent Decree shall continue to be effective and binding upon the parties to this action for one year
III. INJUNCTION PROVISIONS A. The Defendant, its officers, agents, employees, and all persons acting in concert with the Defendant shall not discriminate against a qualified individual with a disability because of the disability of such individual in regard to hiring and other terms. cond itions. and privileges of employment. B. The Defendant. its officers. agents. employees. and all persons acting in concert with the Defendant shall not engage in any employment practice which has the purpose or effect of discriminating against any individual on the basis of a disability under the Americans With Disabilities Act of 1990.
IV. NON-RETALIATION PROVISION The Defendant, its officers, agents, employees, and all persons acting in concert with the Defendan t shall not discriminate against any individual because such individual has opposed any act or practice made unlawful by the Americans With Disabilities Act of
1990 or because such individual made a charge, testified, assisted, or participated in any
manner In an Investigation. proceeding. or hearing under the Americans With Disabilities Act.
3
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V. TRAINING Defendant shall provide training in the worKplace for its management staff involved in the hiring process, including the Director of Operations and General Manger at its store #85, tocated at 2745 Lebanon Road, Nashville, Tennessee regarding the Americans With Disabilities Act of t990.
(a) The training session will include at least two (2) hours of instruction. (b) The training wi ll include the following topics: what constitutes employment discrimination in violation of Americans With Disabilities Act of 1990; how to preven t. identify and remedy disability discrimination; what constitutes reasonable accommodation under the Americans With Disabilities Act of 1990, what constitutes retaliation in viola tion of ADA; Defendant's policy against disability d iscrimination and retaliation; and implementation of Defendant's policy against employment discrimination. including procedures and responsibilities for reporting, investigating and remedying conduct an employee believes may constitute employment discrimination under the Americans With Disabilities Act of 1990. {c} The training will be conducted within 120 days after entry of the Decree by the Clerk of the Court. (d) Defendant will notify Faye Wil liams, Reg ional Attorney, within ten days after the training has been completed
VI. NOTICE POSTING The Defendant shall continue to conspicuously post at its store #85. 2745 Lebanon
4
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Road, Nashville, Tennessee, the notice (posters) required to be posted pursuant to the
Americans With Disabilities Act of 1990. furthermore, the Defendant shall conspicuously post the notice at Append ix A of this Decree at its Nashville, Tennessee facilities for six months commencing within ten (10) days after entry of this Decree by the Court.
VII. INDIVIDUAL RELIEF The Defendant shall pay Sean Stanl ey $36,000.00 in full and fina l settJement of this lawsuit.
VIII. COSTS Each of the parties shall bear its own costs, including attomeys' fees.

IT IS SO ORDERED THIS DAY OF _ _ _---;,,-'

TRICTJUDGE

5
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 CM/ECF - DC V2.5 (October 2005) - Docket Report

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BROWN, CASE-CLOSED
U.S. District Court Middle District of Tennessee (Nashville) CIVIL DOCKET FOR CASE #: 3:05-cv-01027

Equal Employment Opportunity Commission v. Papa John's USA, Inc. Assigned to: District Judge Aleta A. Trauger Cause: 28:451 Employment Discrimination

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

Plaintiff
Equal Employment Opportunity Commission

represented by Faye A. Williams Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0088 Email: faye.williams@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Katharine W. Kores Equal Employment Opportunity Commission 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0116 Email: katharine.kores@eeoc.gov TERMINATED: 03/30/2006 LEAD ATTORNEY

Sally Ramsey Equal Employment Opportunity Commission 50 Vantage Way Suite 202 Nashville, TN 37228 usa (615) 736-2105 Fax: (615) 736-2107 Email: sally.ramsey@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Adele Rapport Equal Employment Opportunity

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CM/ECF - DC V2.5 (October 2005) - Docket Report
V. Intervenor Plaintiff Sean Stanley
V. Defendant Papa John's USA, Inc.
V. Intervenor Defendant Papa John's USA, Inc.
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https://ecf.tnmd.uscourts.gov/cgi-bin/DktRpt.pl?710786420114099-L_9...
Commission 1407 Union Avenue Suite 621 Memphis, TN 38104 (901) 544-0113 Fax: (901) 544-0111 TERMINATED: 09/11/2006
represented by K. Cody Allison 315 Deaderick Street Suite 1550 Nashville, TN 37238 (615) 244-3331 Email: codytnlaw@yahoo.com ATTORNEY TO BE NOTICED
represented by Edwin S. Hopson Wyatt, Tarrant & Combs 2600 Citizen Plaza Louisville, KY 40202 (502) 589-5235 Email: ehopson@wyattfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
James C. Bradshaw, III Wyatt, Tarrant & Combs 2525 West End Avenue Suite 1500 Nashville, TN 37203-1423 (615) 244-0020 Email: jbradshaw@wyattfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by James C. Bradshaw, III (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
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CM/ECF - DC V2.5 (October 2005) - Docket Report

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Date Filed 12/05/2005 12/05/2005 12/14/2005 12/15/2005 12/15/2005 01/23/2006 01/26/2006 01/27/2006 02/01/2006
02/01/2006 02/07/2006 02/07/2006 02/07/2006 02/08/2006 02/08/2006
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#

Docket Text

1 COMPLAINT against Papa John's USA, Inc. , filed by Equal Employment Opportunity Commission. No summons issued.(rm) (Entered: 12/06/2005)
2 NOTICE of Initial Case Management Conference set for Monday, 2/13/2006 at 2:00 PM in Room 825 before District Judge Aleta A. Trauger. (rm) (Entered: 12/06/2005)
3 MOTION to Intervene and to Consolidate by Sean Stanley. Responses due by 1/3/2006 (Attachments: # 1 Intervenor Plaintiff Complaint# 2 Proposed Order)(Allison, K.) (Entered: 12/14/2005)
Note to Filer: Re: Document No. 3; In the future, please remember to sign the pleading or place s/K.Cody Allison on signature line. (km, ) (Entered: 12/15/2005)
4 ORDER granting 3 Motion to Intervene . Signed by Judge Aleta A. Trauger on 12/15/05. (km, ) (Entered: 12/15/2005)
5 WAIVER OF SERVICE Returned Executed by Equal Employment Opportunity Commission. Papa John's USA, Inc. waiver sent on 12/23/2005, answer due 2/21/2006. (Ramsey, Sally) (Entered: 01/23/2006)
6 NOTICE of Appearance by James C. Bradshaw, III on behalf of Papa John's USA, Inc. (Bradshaw, James) (Entered: 01/26/2006)
7 NOTICE of Case Management Conference reset for 2/13/2006 at 9:30 AM in Courtroom 873 before District Judge Aleta A. Trauger. (dt) (Entered: 01/27/2006)
8 MOTION for attorney Edwin S. Hopson to Appear Pro Hac Vice by Papa John's USA, Inc.. Responses due by 2/21/2006 (Attachments: # 1 Exhibit Certificate of Good Standing# 2 Proposed Order Order for Pro Hac Vice Admission)(Bradshaw, James) (Entered: 02/01/2006)
NOTE TO FILER: Re: Document No. 8; In the future, Certificates of Good Standing should be filed as separate entries. (km, ) (Entered: 02/01/2006)
9 ANSWER to Complaint by Papa John's USA, Inc..(Bradshaw, James) (Entered: 02/07/2006)
10 RECEIPT #100 108665 in the amount of $75.00 posted for Edwin S. Hopson by Papa John's USA, Inc. re 8 Motion to Appear Pro Hac Vice. (km, ) (Entered: 02/07/2006)
11 Intervenor COMPLAINT against Papa John's USA, Inc., filed by Sean Stanley.(Allison, K.) (Entered: 02/07/2006)
12 ANSWER to Intervenor Complaint by Papa John's USA, Inc..(Bradshaw, James) (Entered: 02/08/2006)
13 ORDER granting 8 Motion for Edwin S. Hopson to Appear Pro Hac Vice . Signed by Judge Aleta A. Trauger on 2/8/06. (km, ) (Entered: 02/08/2006)

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CM/ECF - DC V2.5 (October 2005) - Docket Report

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02/08/2006 02/08/2006 02/13/2006 02/13/2006 02/21/2006
03/28/2006 03/30/2006 06/15/2006 08/01/2006 09/11/2006 09/21/2006 09/22/2006

14 (DOCKETED IN ERROR-Not Signed-Atty Refiled See Docket Entry No. 15)PROPOSED CASE MANAGEMENT ORDER filed by Equal Employment Opportunity Commission. (Ramsey, Sally) Modified on 2/9/2006 (km, ). (Entered: 02/08/2006)
15 PROPOSED CASE MANAGEMENT ORDER filed by Equal Employment Opportunity Commission. (Ramsey, Sally) (Entered: 02/08/2006)
16 Minute Entry for proceedings held before Judge Aleta A. Trauger : Case Management Conference held on 2/13/2006. (km, ) (Entered: 02/13/2006)
17 INITIAL CASE MANAGEMENT ORDER: Deadline for filing amendments 5/8/06. Joint Mediation report to be filed by 6/15/06. Written Discovery due by 8/18/2006. Motions due by 12/20/2006. Signed by Judge Aleta A. Trauger on 2/13/06. (km, ) (Entered: 02/13/2006)
18 ORDER: Jury Trial set for 5/8/2007 at 9:00 AM in Courtroom 873 before District Judge Aleta A. Trauger. Pretrial Conference set for 4/30/2007 at 1:30 PM in Courtroom 873 before District Judge Aleta A. Trauger. Proposed Pretrial Order due by 4/25/2007. Parties shall also submit to the Court, by 4/25/07, the following: witness lists; exhibit lists; stipulations; and expert witness statements. Signed by Judge Aleta A. Trauger on 2/21/06. (dt) (Entered: 02/21/2006)
19 MOTION to Substitute Attorney by Equal Employment Opportunity Commission. Responses due by 4/14/2006 (Attachments: # 1 Proposed Order)(Rapport, Adele) (Entered: 03/28/2006)
20 ORDER granting 19 Motion to Substitute Attorney. Added attorney Adele Rapport for Equal Employment Opportunity Commission. Attorney Katharine W. Kores terminated. Signed by Judge Aleta A. Trauger on 3/30/06. (dt) (Entered: 03/30/2006)
21 STATUS REPORT Joint Mediation Report by Equal Employment Opportunity Commission. (Ramsey, Sally) (Entered: 06/15/2006)
22 MOTION to Withdraw as Attorney, MOTION to Substitute Attorney by Equal Employment Opportunity Commission. Responses due by 8/18/2006 Responses due by 8/18/2006 (Attachments: # 1 Proposed Order)(Ramsey, Sally) (Entered: 08/01/2006)
23 ORDER granting 22 Motion to Withdraw as Attorney and Motion to Substitute. Added attorney Faye A. Williams for Equal Employment Opportunity Commission. Attorney Adele Rapport terminated. Signed by Judge Aleta A. Trauger on 9/11/06. (km, ) (Entered: 09/11/2006)
24 Joint MOTION for Settlement Conference before Magistrate by Papa John's USA, Inc.. Responses due by 10/10/2006 (Bradshaw, James) (Entered: 09/21/2006)
25 ORDER granting 24 Joint MOTION for Settlement Conference before Magistrate filed by Papa John's USA, Inc. Case is referred to Magistrate Judge Brown to conduct a judicial settlement conference/mediation. Signed by Judge Aleta A. Trauger on 9/22/06. (km, ) (Entered: 09/22/2006)

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09/22/2006 09/28/2006 10/03/2006
10/12/2006
11/28/2006 11/28/2006 11/30/2006 12/01/2006 12/04/2006 12/04/2006
12/04/2006

26 ORDER granting 24 Joint MOTION for Settlement Conference before Magistrate filed by Papa John's USA, Inc . Signed by Judge Aleta A. Trauger on 9/22/06. (km, ) (Entered: 09/22/2006)
27 ORDER: Settlement Conference set for 10/11/2006 01:00 PM before Magistrate Judge Joe Brown. Signed by Judge Joe Brown on 9/28/06. (km, ) (Entered: 09/28/2006)
28 ORDER RESETTING JURY TRIAL: Jury Trial reset for 5/15/2007 09:00 AM before District Judge Aleta A. Trauger. Final Pretrial Conference reset for 5/11/2007 01:30 PM before District Judge Aleta A. Trauger. Proposed Pretrial Order due by 5/8/2007. Signed by Judge Aleta A. Trauger on 10/2/06. (km, ) (Entered: 10/03/2006)
29 ORDER: Settlement conference held 10/11/06; Parties have reached a settlement in this case. Parties are directed to file with the District Judge, by 11/17/06, documents necessary to close this case. Clerk is directed to return the file to Judge Trauger. Judge Joe Brown no longer assigned to case. Signed by Judge Joe Brown on 10/12/06. (km, ) (Entered: 10/13/2006)
30 First MOTION for Extension of Time to File Consent Decree by Equal Employment Opportunity Commission. (Attachments: # 1 Proposed Order proposed order granting motion)(Ramsey, Sally) (Entered: 11/28/2006)
31 MEMORANDUM in Support of 30 First MOTION for Extension of Time to File Consent Decree filed by Equal Employment Opportunity Commission. (Ramsey, Sally) (Entered: 11/28/2006)
32 ORDER granting 30 Motion for Extension of Time to File consent decree. Extension to 12/1/06. Signed by Judge Aleta A. Trauger on 11/30/06. (km, ) (Entered: 11/30/2006)
33 Joint MOTION to Enter Consent Decree by Equal Employment Opportunity Commission. (Attachments: # 1 Consent Decree)(Ramsey, Sally) (Entered: 12/01/2006)
34 ORDER granting 33 Motion to enter a consent decree . Signed by Judge Aleta A. Trauger on 12/4/06. (km, ) (Entered: 12/04/2006)
35 CONSENT DECREE: Court has reviewed the terms of the proposed Consent Decree in light of the applicable laws and regulations, the stmts and representations of counsel for all parties, and approves the Consent Decree. Deft shall pay Sean Stanley $36,000.00 in full and final settlement of this lawsuit. Each of the parties shall bear its own costs, including attys' fees. Signed by Judge Aleta A. Trauger on 12/4/06. (km, ) (Entered: 12/04/2006)
36 Docket Entry number 35 is hereby entered on the docket in compliance with Rule 58 and/or Rule 79(a) of the Federal Rules of Civil Procedure on 12/4/06 by km. (km, ) (Entered: 12/04/2006)

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