IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS JUDGE ALESIA

EASTERN DIVISION

~IAC-~ ISTRATE JUDGE

U.S. EQUAL EMPLOYMENT OPPORTUNITY

)

~I~ALDINE SOAT BROWN

COMMISSION,

I OOC 5488

Plaintiff,

FAIRCHILD PRINTING SERVICE, INC., Defendant.

Civil Action No. L~".~ 5:> :~
Jury Trial De~nand:; ,l/

COMPLAINT NATURE OF THE ACTION This is an action brought under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 9 2000e et seq. ("Title VII"), and Title I of the Civil Rights Act of 1991, 42 U.S.C. 9 198 Ia, to correct unlawful employment practices on the basis of retaliation and to make whole Kenneth Brown ("Brown") who has been aggrieved by Defendant’s unlawful employment practices. Defendant, Fairchild Printing Service, Inc., terminated Brown from his position as janitor in retaliation for his having complained of discrimination. JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 99 451,1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 706(0(1) and (3) of Title VII, 42 U.S.C. 9§ 2000e-5(f)(1) and (3), and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a. 2. The employment practices hereafter alleged to be unlawful were and are now being committed within the jurisdiction of the Northern District of Illinois, Eastern Division.

PARTIES 3. Plaintiff, U.S. Equal Employment Opportunity Commission ("EEOC"), 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) of Title VII, 42 U.S.C. § 2000e-5(f)(1). 4. At all relevant times, Defendant has continuously been and is now an Illinois corporation doing business in Bensenville, Illinois within the Northern District of Illinois and has continuously had and does now have at least fifteen (15) employees. 5. At all relevant times, Defendant has continuously been and is now 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, Kenneth Brown filed a Charge of Discrimination with the EEOC, alleging violations of Title VII by Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least December 1998, Defendant has engaged in unlawful employment practices in violation of Section 704(a) of Title VII, 42 U.S.C. § 2000e-3(a). These practices include, but are not limited to, terminating Brown’s employment in retaliation for his having complained of harassment and discrimination. 8. The effect of the practices complained of above has been to deprive Brown of employment in violation of Section 704(a) of Title VII, 42 U.S.C. § 2000e-3(a). 9. The unlawful employment practices complained of above in Paragraphs 7 and 8 were and are intentional.

10. The unlawful employment practices complained of above in Paragraphs 7 and 8 were and are done with malice and/or reckless indifference to Brown’s federally protected rights.
PRAYER FOR RELIEF WHEREFORE, the U.S. EquaI Employment Opportunity Commission prays that this Court: A. Grant a permanent injunction enjoining Defendant, Fairchild Printing Service, Inc., its officers, successors, assigns and all persons in active concert or participation with it from engaging in any employment practice which constitutes retaliation for activity protected by TitleVII; B. Order Defendant to institute and carry out policies, practices and programs which eradicate the effects of its past and present unlawful employment practices; C. Order Defendant to make whole Kenneth Brown by providing appropriate back pay with prejudgment interest, in amounts to be proved at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including reinstatement of Kenneth Brown; D. Order Defendant to make whole Kenneth Brown by providing compensation for past and future pecuniary losses resulting from the unlawful practices, including, but not limited to, job search expenses and relocation expenses; E. Order Defendant to make whole Kenneth Brown by providing compensation for nonpecuniary losses, including, but not limited to, emotional pain, suffering, loss of enjoyment of life and humiliation; F. Order Defendant to pay Kenneth Brown punitive damages for its malicious and/or reckless conduct, in an amount to be determined at trial; G. Grant such further relief as the Court deems necessary and proper; and H. Grant the EEOC its costs in this action.
3

JURY TRIAL DEMAND
EEOC requests a jury trial on all issues of fact raised by its Complaint.
Respectfully submitted,
C. Gregory Stewart General Counsel
Gwendolyn Young Reams Associate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 "//1’ Street, N.W.

c:/fairehild/complaint

Reg" hal Attorney
J s~_.ff’J. BehatO "k v Supervisory Trial Attorney
all’ace Ca~sfn-- --~ Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Chicago District Office 500 West Madison Street Suite 2800 Chicago, Illinois 60661 312/353-7259
4

(Roy. tl,9‘51

CIVIL COVER SHEET

The JS-44 civil coyote.el and the information~ined herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except a

provided by Io~I rules . "rhis

roved by lhe Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the pur

initiating the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM+)

I. (a) PLAINTIFFS

DEFENDANTS

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION _

Inc.

i~rchild Printing Service,

JUDGE ALEStA
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF (EXCEPT IN U,S. PLAINTIFF CASES)
. ,..;/~,,b i 3]RAT E JUDGE (-~:RA! RIklF. ~AT RRDWN

SEP 0 "t
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

Cook

ATFORNEYS (IF KNOWN)

’/

[’"’~ C’3

"

5une Waiiaoe Carso~ (312) 353-7259 Equal Employment Opportunity Commission
500 W. Madison Street - Suite 2800 Chicago, IL 60661

548 " ’- "

]1. BASIS OF JURISDICTION
~ 1. U.S. Government Plaintiff
[] 2, U.S. Government Defendant

IV. ORtGIN

[] I. O, igina,

[]

Proceeding

(PLACE AN X IN ONE BOX ONLY}

IlL CITIZENSHIP OF PRINCIPAL PARTIES (~CEAN X~.~,~ONE BOX

(For Diversify Cases Only)

FOR PLAINTIFF ANDante BOX FO...~EFENDANT)

r-~3. Federal Q~estion (U.S. Government not a parly)
[] 4. Diversity (Indicate Citizenship of Paffies in item

PTF DEF

Cilize~ of this State [] 1 [] 1 Incorporated or Principal Place,

~2 Citizen of Another Slate r-~2

of Business in this State lnco~’pofated and Principal PIa~e
of Business in Another State

Citizen or Subject of a []3 []3Foreign Nation

Foreign Co.u.ntr

PTF DEF

(PLACE AN X IN ONE BOX ONLY}

[] 3. Remanded from Appellate Court

[] 4. Relnslaled or Reopened

Transferred from
[] .5. anolhet district (specify)

D8. Multidistrict Litigation

Appeal to District ,fudge from [] 7. Magistrate
Judgment

V. NATURE OF SUIT

CONTRACT

110

PERSONAL INJURY

120

[] 310 Aiqc, lane

1.30

[--~ 315 Airplane P¢odu~t

140

Liabil~y

~ 320 Assau~, Li~l &

Sla~ef

Judgme~ [] 151 Mode;are A~

~ 330 F~e~I Emp~ye~$

[] 152 Recovery Ot Defaulted

Uabil~y

S~u~eel Loans

~

(ex~. Velemns)

153 Re~ve~ of Ove~en~ ~

~0 345

M~ne M~ne P~

Stockinets Su~s

~ ~

350 355

M010tVehT~e MOtor Veh~e Pmd~ Liabil~y

195 ~nlt~ P~Su~ L~abilily

tnjuW

R~AL, PROPER~ 210 Land C~ndemnatlon 220 F0¢e~sur~ ~O Re~ Lease & Eje~me~ 240 Toffs ~o La~ 245 TO~ P~u~ Ll~bil~y 2~0 All ~ner Real P~dy

CIVIL RIGHTS

~ 44441~

Voting Jobs

443 Ho~in~ A~da~bns
~ 444 Welfa~

~ 440 Other Civil R~s

TORTS

PERSONAL INJUI~Y [] 362 Personal leJvcy -
M.ed. Malpr,actlce

~

3~ Paschal/nJ~P~U~ Lia~lity

~ 368 Asbestos Pe~nal InJu~ P~u~

Llablr~y

PERSONAL PR~ER~ ~ 370 ~het fra~

~

380 Other Pets0nal Pmpe~y

PRISpNER PETI~O’NS

[]

5t0 Mseontt~ennsce(o Vacate

Ha~ ~us

530 General

535 Death Penury

~ ~

~0 M~am~ & Other ~0 CM~

FORFEITUR~PENALTY

BANKRUPTCY

~]siO e~’0 625

Agriculture Food & Dn~

’ ;C~ 4~Z A2p~pUeSaCl 158

D~g ReMaI~ SeCure of [] 423 W~hdcawe]

Pmpe~y 21 USC 881 ~OL~rlaws

28 USC 157

RR & Track Airline R~S. O~up~t~n~l Safety~ea~h
/A,BOR

PROPERTY RIGHTS
[] 820 Copyrigl’~ [] 830 P~tent [] 840 Trademark
¯ ’SOCIA.~L SECURFIr~’

I[]~’710ACt Feri’ Le~r Stand’tale [] ;’20 L~borlMomt

[] 881 H~. [] 663 DIW~elww

Ret~’ti~ &

[] 740 Rai~ay Labor ?g0 Other Labor Lit~ation

FEDERAL TA~ SUITS ~ 870 Taxes (u.S.Pte}ntiff
or Defendant,)
[] 871 IRa-Third Party 26 U$C 7~

OTHER STATUTES

B 410 430 [] 450

Reapportionment Antiti’u$l
Conks ~.nd Sacking Comrneme.qcc Rate~#etc,

[] 470 Racketeer Influenced and

[] 810 Selective SeMCe [] ,~0 Seeu~ie~ Co nu-~l~ies,’

[] 875 [] 891 [] 892

CustimerChalle~e Agr;ca~t oral ACSS EconomY= Stgbiffzatio~

[] 894 Eeelgy AIlo~t~,n Act

[] 89~

Fte~m Of

[] 890 Oth~ Statutory Actions.

VI. CAUSE O F ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE
DONOTCITEJURISDICTIONALSTATUTESUNLESSDVE,RSI~)

Re~aliati0n in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e et. seq.

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION

[] COMPLAINT: UNDER F.R.C.P. 23

VIII, RELATED CASE(S) (see in~etions):

IF ANY

JUDGE

DEMAND

DATE/.,I~/k ,

.,, ~ SIGN~E~TTORN~ORD

RECEIPT #

AMOUNT

APPLYING IFP

Check YES only if demanded in complaint:
JURY DEMAND: [] YES [] NO
DOCKET NUMBER

JUDGE

MAG JUDGE

in the Matter of

U~..~:ED STATES DISTRICT COl" "T NORTHERN DISTRICT OF ILLIN~O~S
UDGE ALEXIA

U.S.

Equal

Employment Plaintiff,

Opportunity

Commission,

DOCKETED

SEP 0 7 2000

V.

Fairchild Printing Service, Inc.

MAGISTRATE JUDGE
e, :

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEY(S) FOR: U.S. Equal Employment Opportunity Commission, Plaintiff

(B)

John C. ~i~ Equal El ~ployment Opportunity Commission

FI~ Equal Employment Opportunity Commission

: . o fi00 w. st.,

ST~ET~DgESS 500 W. Madison St., Suite 2800

Chicago, IL 60661

CITV/STArWZI~ Chicago, IL 60661

TELE~.ONE~E~ (312) 353-8551

rE~E,~O~E~E, (312) 353-7722

IDENTIFICATION NLrMBER (SEE ITEM4ONREVERSE)ARDC No. 01187589

MEMBER OF TRIAL BAR?

YES ~l

NO

[]

TRIAL ATTORNEY?

YES

[~]

NO

[]

DESIGNATED AS LOCAL COUNSEL?

YES

[]

NO

[]

(c)

IDENTIFICATION NUMBER ($EE ITEM 4 ON REVERSE) ARDC No. 06203727

MEMBER OF ’fRIAL BAR?

YES [] NO r~

DESIGNATED AS LOCAL COUNSEL?

YES

[]

NO []

SIGNATURE

~.~~u " ~))~llace Carson FI~Equal Employment Opportunity Commission SrRE~TA~RESS500 W. Madison St., Suite 2800 orwsr^r~zI~Chicago, IL 60661 TELE~.O~ Ntn~E~(312) 353-7259 NO. 620205 IDENTIFICATION nUMBER (S~E tTEM 4 ON RE~RSE)A~ C

DESIGNATED AS LOC~ COUNSEL?

~S

NO

NAME

FIRM STREET ADDRESS CITY/STATEJZIP TELEPHONE NUMBER IDENTIFICATION NI~MBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR?
T~ALA’n’OF.~’?
DESIGNATED AS LOCAL COUNSEL?

YES []

NO []

~eS [] No []

YES

[]

NO []

 
 Minute Order FOITl1 (06/97)

United States District Court, Northern District of Illinois

,

Name of Assigned Judge or Magistrate Judge

James H. Alesia

Sitting Judge if Other than Assigned Judge

CASE NUMBER

00 C 5488

DATE

8/912001

CASE TITLE

U.S. Equal Employment Opportunity Commission vs. Fairchild Printing Service, Inc.

[In the followmg box (a) mdicate the party filing the motton, e.g., plamtlff, defendant, 3rd party plamtlff, and (b) state bneflythenature

MOTION:

of the motion being presented.]

,'---------------' DOCKET ENTRY:

(I) o

Filed motion of [use listing in "Motion" box above.]

(2) o

Briefin support of motion due ___.

(3) o

Answer brief to motion due___. Reply to answer brief due___.

(4) o

RulinglHearing on ___ set for ___ at ___.

(5) o

Status bearing[heId/continued to] [set for/re-set for] on ___ set for _ _ _ at _ _ _'

(6) o

Pretrial conference[held/continued to] [set for/re-set for] on ___ set for _ _ _ at _ _ _.

(7) o

Trial[set for/re-set for] on ___ at ___.

(8) o

[Bench/Jury trial] [Hearing] held/continued to _ _ _ at ___.

(9) o

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 General Rule 21 0 FRCP41(a)(I) 0 FRCP4I(a)(2).

(10) •

[Other docket entry] Parties' agreed motion to reinstate this matter for the purpose of entering the

Consent Decree is granted. Enter Consent Decree.

• 11)

[For further detail see order attached to the

No notices required, advised in open court.

No notices required.

Notices mailed by judge's staff.

Notified counsel by telephone.

Docketing to mail notices.

Mail AO 450 fonn.

Copy to judge/magistrate judge.

minute order.]

courtroom

cw

deputy',

initials

LJ \ );lJG \ 0 Pi'l 5: 25

UG 1 3 200t
initials 8110/200]
cw
mailing deputy initials

\1

'.
DOCKETED

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

AUG 13 2001

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

)

)

FAIRCHILD PRINTING SERVICE, INC., )

) Defendant.

Civil Action No. 00 C 5488 HonorableJudge Alesia Magistrate Judge Soat Brown

CONSENT DECREE Plaintiff U.S. Equal Employment Opportunity Commission (the "EEOC" or "Plaintiff'), an agency of the United States, alleged that Defendant (defined below) discriminated against Kenneth Brown ("Brown") by tenninating his employment in retaliation for his having complained of harassment and race discrimination in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e ~~. ("Title VII") and the Civil Rights Act of 1991,42 U.S.C. §198Ia("CRA '91").
Defendant denied and continues to deny any and all claims raised by EEOC in this lawsuit. This Consent Decree is being entered into solely for the purpose of settling disputed claims, and shall not be construed as an admission by Defendant of any liability whatsoever, any wrongdoing towards Brown, or any violation of a statute, law or regulation. The parties have agreed to resolve all disputes between and among them in order to further the goals of Title VII, to avoid further litigation, to assure a discrimination-free workplace at Defendant and to make all employees of Defendant aware oftheir rights and responsibilities under law.

1'7

Findings Having carefully examined the tenus and provisions of this Consent Decree, the Court finds the following: 1. This Court has jurisdiction of this case 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, 42 U.S.C. §§2000e-5(f)(1) and (3), and Section 102 of the Civil Rights Act of 1991,42 U.S.C. §1981a. 2. The tenus and provisions of this Consent Decree are adequate, fair, reasonable, equitable and just. This Consent Decree resolves all claims brought by the EEOC in its Complaint against Defendant, and any claims which could have been brought based on the Charges of Discrimination filed by Kenneth Brown. The rights of all parties and the interest of the public are adequately protected by this Consent Decree. 3. This Consent Decree confonus with the Federal Rules of Civil Procedure and Title VII, and is not in derogation of the rights and privileges of any person. The entry of this Consent Decree will further the objectives of Title VII and will be in the best interest of the parties and the individuals for whom EEOC seeks relief. 4. The parties stipulate and the Court finds that EEOC filed this action against Fairchild Printing Service, Inc. only, that EEOC did not allege any violation of Title VII by the purchaser of Fairchild Printing Service, Inc., and that Stout Acquisition Company, L.L.C. a/k/a "The Graphics Group, L.L.C." is, for purposes of this action and this Consent Decree, the purchaser of Fairchild Printing Service, Inc. and is bound by this Consent Decree. (Fairchild Printing Service, Inc. and Stout Acquisition Company, L.L.C. a/k/a "The Graphics Group,
- 2-

L.L.C." (only for pUlposes of this Consent Decree and its commitment to implement provisions specified herein) being collectively referred to herein as "Defendant").
WHEREFORE, upon the consent of the parties, IT IS ORDERED, ADJUDGED AND DECREED:
Prospective Relief 5. Defendant and its managers, supervisors, officers, directors and agents, are enjoined from engaging in retaliation, including, but not limited to, taking adverse employment action against any employees, including termination, for reporting discrimination on the basis of their race or engaging in any other protected activity, in violation of Title VII. 6. Defendant and its managers, supervisors, officers, directors and agents, will not engage III reprisal or retaliation of any kind against any person because of such person's opposition to any practice made unlawful under Title VII; or because of filing a charge, testifying or participating in any manner in any investigation, proceeding or hearing under Title VII; or because an individual was identified as a possible witness for EEOC; or because of any assertion of rights under this Consent Decree.
Posting of Notice 7. Defendant shall post the Notice attached as Exhibit A continuously for the duration of this Consent Decree on bulletin boards commonly used for announcements from Defendant to its employees, and will certify in writing every six (6) months that the Notice remains posted. Defendant shall take all reasonable steps to ensure that the Notice is not altered, defaced or covered by any other material. Defendant shall permit a representative of EEOC to
-3 -

enter Defendant's premises for purposes of verifYing compliance with this Paragraph at any time during normal business hours without prior notice.
Monetary Relief 8. Within ten (10) days of the date of the entry of this Consent Decree, Defendant shall forward Charging Party, Kenneth Brown, a cashier's check for $15,000.00 for damages made payable to Kenneth Brown, by certified mail as settlement of all disputed claims and to resolve this case. Defendant will contemporaneously furnish EEOC counsel of record, June Wallace Carson, with a copy ofthe check by regular mail.
Reporting 9. Defendant will provide a 1099 form to Kenneth Brown reflecting the payment identified in Paragraph No. 8 above. Brown agrees to pay all federal, state and local taxes related to receipt of any and all income pursuant to this Consent Decree. Brown further understands that he will be solely responsible for all liability, including any penalties or tax assessed against Defendant as a result of payment received by him under this Consent Decree and will solely bear all such costs associated with any assessment. 10. Every six (6) months after the entry of this Consent Decree, on February 15, 2002, and on August 15, 2002, Defendant shall provide to the EEOC a written report listing:
(a) each retaliation complaint (formal or informal) made or filed by any employee or applicant for employment against Defendant within the past six (6) months;
-4-

(b) the name, current address and phone nwnber and social security nwnber of each employee or applicant making a complaint under paragraph (a) above;
(c) the date of each complaint of retaliation made under paragraph (a) above; (d) whether or not the complaint was investigated and the outcome of any
investigation, including any action taken; and (e) the decision makers involved in making the decision in paragraph (d)
above. Enforcement
11. This Consent Decree shall be in effect for a period of one (1) year, during which time the Court shall retain jurisdiction of the EEOC and Defendant and of this action for the purpose of interpreting and enforcing the provisions of this Consent Decree, provided, however, that if, at the end of the one year period, any dispute between the parties arising from this Consent Decree remains unresolved, the term of the Consent Decree shall be automatically extended (and the Court will retain jurisdiction of this matter to enforce the Consent Decree) until such time as all such disputes have been resolved.
12. If any provision of this Consent Decree is found to be unlawful, only the specific provision in question shall be affected and all other provisions will remain in full force and effect.
13. If during the one (1) year period after entry of this Decree, the EEOC believes that Defendant is not complying with this Consent Decree, the EEOC shall notify Defendant's undersigned counsel in writing of the specific nature of the alleged violation, all within ten (10)
-5-

days of the EEOC becoming aware of the occurrence of the act(s) allegedly violative of this Consent Decree. Defendant may respond within ten (10) business days of its counsel's actual receipt of such notice. Thereafter, if EEOC continues to believe there has been noncompliance with this Consent Decree, EEOC will provide three (3) business days notice to Defendant, of any intention to file any document or motion with the Court.

14. Defendant, the EEOC and Kenneth Brown shall bear their own costs and attorneys' fees in this case.

Approved for Plaintiff:
GWENDOLYN REAMS Associate General Counsel

Approved for Defendant: Fairchild Printing Service, Inc., and its purchaser Stout Acquisition Company, L.L.C. a/k/a The Graphics Group, L.L.C.

RolJert T. Bernstein Laner, Muchin, Dombrow, Becker, Levin and Tominberg, Ltd. 5 I 5 North Statc Street Suite 2800 Chicago, Illinois 60610-4324
467-9800

Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, Illinois 60661 (312) 353-7259
-6-

·"
. " , ,

I2QDbF ENTERED AND ORDERED ~

.tIN.,kru

10;,,_,/

-7-

TO: EMPLOYEES OF FAIRCHILD PRINTING and its purchaser STOUT ACQUISITION COMPANY, L.L.C. aIkIa THE GRAPHICS GROUP, L.L.C.
RE: NOTICE OF CONSENT DECREE

United States District Judge James H. Alesia has entered a Consent Decree resolving a

case, U.S. Equal Employment OpporttuUty Commission v. Fairchild Printing Service, Inc., 00 C
lor 5488· in the United States District Court the Northern District of Illinois, Eastern Division,

brought by the United States Equal Employment Opportunity Commission ("EEOC"), on behalf of Kenneth Brown, again~ Fairchild PrintiJig, Inc. only, and not its purchaser Stout

tn Acquisition Company, CL.G. 3!kJa Thi"Craphics Group, L.L.C. EEOC alleged that
Fairchild Printing terminateifKennetn'BroWn retaliation for his having complained of race

discrimination in violation o{Tfiie VIf'Of theCiJiI Rights Act of 1964, as amended, 42 U.S.C.

•".-

. ,

>'1'~"

§2000e et~.

."" . ; , . '

•••( "\

:.,.. "1")

.;,/,tr

The Consent Decree pr6~ides that Fairchild Printing, Inc. and its purchaser Stout

Acquisition Company, L.L.C. aIkIa'The Graphics Group, L.L.C.:

a) Will not retaliate against any employee who reasonably complains of what slhe believes to be employment discrimination on the basis their race or who participates in an investigation of such a complaint;

b) Will provide monetary relief to the employee on whose behalf EEOC brought this case;

c) Make reports to EEOC for one year.

The EEOC is an agency of the United States Govemment empowered to enforce the Americans with Disabilities Act, Title VII of the Civil Rights Act, the Equal Pay Act, and the Age Discrimination in Employment Act of 1967. These laws prohibit employers from discriminating on the basis of disability, age, sex, pregnancy, race, color, religion, and national origin. These laws also prohibit retaliation against any employee because he or she reasonably opposes what he or she believes to be unlawful discrimination, complains of or files a charge of discrimination, or participates in the investigation or litigation ofa charge or suit.

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE

This Notice will remain posted for one year from the date shown below and must not be

altered, defaced, or covered by any other material. Any questions concerning this Notice or

compliance with its provisions may be directed to the Director of Human Resources or to the

U.S. Equal mployment Opportunity Commission, Chicago District Office, 500 West Madison

Street, Suit

, Chica 'nois 60661.

Above Sign for Defendant
£, Dated: August 2001
-8-

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?650371363928764-L_35...
BROWN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:00-cv-05488

EEOC v. Fairchild Printing Assigned to: Hon. James H. Alesia Demand: $0 Cause: 42:2000e Job Discrimination (Employment)

Date Filed: 09/06/2000 Date Terminated: 07/26/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jose Jorge Behar Hughes Socol Piers Resnick & Dym Ltd. 70 West Madison Street Suite 4000 Chicago, IL 60602 (312) 580-0100 Fax: 312-580-1994 Email: jbehar@hsplegal.com ATTORNEY TO BE NOTICED

June Wallace Calhoun United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7568 Email: june.calhoun@eeoc.gov ATTORNEY TO BE NOTICED

V. Defendant

1 of 4

5/31/2007 10:32 AM

CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?650371363928764-L_35...

Fairchild Printing Service, Inc.

represented by Jonathan David Lotsoff Sidley Austin LLP One South Dearborn Street Chicago, IL 60603 (312) 853-7000 Email: jlotsoff@sidley.com TERMINATED: 03/08/2001 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert Todd Bernstein Laner, Muchin, Dombrow, Becker, Levin & Tominberg, Ltd. 515 North State Street Suite 2800 Chicago, IL 60610-4798 (312) 467-9800 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joseph Michael Gagliardo Laner, Muchin, Dombrow, Becker, Levin & Tominberg, Ltd. 515 North State Street Suite 2800 Chicago, IL 60610-4798 (312) 467-9800 Email: jgagliardo@lanermuchin.com ATTORNEY TO BE NOTICED
Linzey D. Jones, Jr. Pugh, Jones, Johnson & Quandt,P.C. 180 North LaSalle Street Suite 3400 Chicago, IL 60601-2700 (312) 551-1002 Email: ljones@pjjq.com TERMINATED: 03/08/2001

Date Filed 09/06/2000 10/12/2000

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of June Wallace Carson, Jose Jorge Behar, John C. Hendrickson as attorney(s) for plaintiff (no summons(es) issued.) ( Documents: 1-1 through 1-3) (fce) (Entered: 09/07/2000)
2 WAIVER of service of summons as to defendant sent on 9/6/00 (hp) (Entered: 10/16/2000)

2 of 4

5/31/2007 10:32 AM

CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?650371363928764-L_35...

11/22/2000 11/22/2000 11/28/2000
12/15/2000 12/19/2000 12/19/2000 01/11/2001 01/18/2001 03/01/2001 03/08/2001
03/23/2001 03/23/2001 03/27/2001
04/05/2001 05/08/2001

3 ATTORNEY APPEARANCE for defendant by Jonathan David Lotsoff (fce) (Entered: 11/28/2000)
4 UNOPPOSED MOTION by defendant Fairchild Printing for extension of time to file an answer or otherwise plead ; Notice. (vmj) (Entered: 11/29/2000)
5 MINUTE ORDER of 11/28/00 by Hon. James H. Alesia: Status hearing set for 12/19/00 at 9:30 a.m. Defendant's unopposed motion for extension time to 12/15/00 to file an answer or otherwise plead is granted [4-1]. Mailed notice (vmj) (Entered: 11/29/2000)
6 ANSWER by defendant to plaintiff's complaint [1-1] (yap) (Entered: 12/18/2000)
SCHEDULE set on 12/19/00 by Hon. James H. Alesia : Status hearing held and continued to 9:30 1/11/01 . Discovery ordered closed on 3/30/01 . Pretrial order to be submitted on 9:30 5/1/01 . Mailed notice (clw) (Entered: 12/19/2000)
7 ATTORNEY APPEARANCE for defendant by Linzey D. Jones Jr. (kef) (Entered: 12/20/2000)
SCHEDULE set on 1/11/01 by Hon. James H. Alesia : Status hearing reset to 9:30 1/18/01 . Mailed notice (clw) (Entered: 01/11/2001)
SCHEDULE set on 1/18/01 by Hon. James H. Alesia : Status hearing held. No notice (clw) (Entered: 01/18/2001)
8 MOTION by defendant to withdraw Linzey Jones and Jonathan Lotsoff as attorneys for defendant Fairchild Printing Service, Inc. ; Notice. (cem) (Entered: 03/09/2001)
9 MINUTE ORDER of 3/8/01 by Hon. James H. Alesia: Motion of Linzey D. Jones, Jr. and Jonathan D. Lotsoff of Sidley & Austin to withdraw as attorneys for defendant [8-1] is granted; defendant is given to 4/4/01 to retain new counsel. Status hearing set for 4/5/01 at 9:30 am . Mailed notice (cem) (Entered: 03/09/2001)
10 ATTORNEY APPEARANCE for defendant Fairchild Printing Service, Inc. by Robert Todd Bernstein and Joseph Michael Gagliardo. (cem) (Entered: 03/26/2001)
11 AGREED MOTION by defendant for extension of time for the discovery cutoff and the pre-trial order deadline ; Notice. (cem) (Entered: 03/28/2001)
12 MINUTE ORDER of 3/27/01 by Hon. James H. Alesia: Defendant's agreed motion for extension of time for the discovery cutoff and the pre-trial order deadline [11-1] is granted. Discovery cut-off date is extended to 5/22/01 which includes experts, if any. Date for submission of the final pretrial order in open court is reset to 6/21/01 at 9:30 am . These dates are final. Mailed notice (cem) (Entered: 03/28/2001)
SCHEDULE set on 4/5/01 by Hon. James H. Alesia : Status hearing stricken. No notice (clw) (Entered: 04/05/2001)
13 JOINT AND AGREED MOTION by parties for an extension of the discovery cut-off and the time for filing the pre-trial order ; Notice. (cem) (Entered: 05/11/2001)

3 of 4

5/31/2007 10:32 AM

CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?650371363928764-L_35...

05/10/2001
07/16/2001 07/26/2001 08/07/2001 08/09/2001

14 MINUTE ORDER of 5/10/01 by Hon. James H. Alesia : Joint and agreed motion for an extension of the discovery cut-off and the time for filing the pre-trial order is granted [13-1]. Discovery cut-off date is extended to 6/21/01. Date for submission of the final pretrial order in open court is reset to 7/24/01 at 9:30 am . These are again final dates. Mailed notice (cem) (Entered: 05/11/2001)
SCHEDULE set on 7/16/01 by Hon. James H. Alesia : Pretrial order due in open court is reset to 9:30 7/26/01 . Mailed notice (clw) (Entered: 07/16/2001)
15 MINUTE ORDER of 7/26/01 by Hon. James H. Alesia : This case is dismissed for want of prosecution; parties did not appear in court with the final pretrial order. Terminating case . Mailed notice (cem) (Entered: 07/27/2001)
16 AGREED MOTION by parties to reinstate this action ; Notice.(cem) Modified on 08/13/2001 (Entered: 08/13/2001)
17 MINUTE ORDER of 8/9/01 by Hon. James H. Alesia : Parties' agreed motion to reinstate this matter for the purpose of entering the consent decree is granted [16-1]. (Entered consent decree). Mailed notices by judge's staff (cem) Modified on 08/13/2001 (Entered: 08/13/2001)

PACER Service Center

Transaction Receipt

05/31/2007 10:31:00

PACER Login: hs0328

Client Code: eeoc

Description: Docket Report Search Criteria: 1:00-cv-05488

Billable Pages: 2

Cost:

0.16

4 of 4

5/31/2007 10:32 AM