IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

frt1U United Statas Courtl

Southlrn

of TIXII

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
TRL GROUP, INC., and TRILEGIANT CORP.,
Defendants.

§

SEP 232004 ~

§ §

Mlcblll No Millay, Clark at ca...

§

§

§ CIVIL ACTION NO.

§

§

§

§

§ JURY TRIAL DEMAND

ORIGINAL COMPLAINT OF THE
UNITED STATES EOUAL EMPLOYMENT OPPORTUNITY COMMISSION

TO THE HONORABLE UNITED STATES DISTRICT COURT:

NATURE OF THE ACTION

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

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

appropriate relief to Starla M. Griffin and other women who were adversely affected by such

practices. As alleged with greater particularity in paragraphs 10-13 below, women employed by

Defendants at the Trilegiant Contact Center in Houston were subjected to unlawful sexual

harassment.

JURISDICTION AND VENUE

1. Jurisdiction ofthis Court is invoked pursuant to 28 D.S.C. §§451, 1331, 1337, 1343

and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(1) and (3), and Section 102 of

1

the Civil Rights Act of 1991, 42 U.S.C. § 1981 a ("Title VII"). 2. The unlawful employment practices alleged in this complaint were committed within
the jurisdiction of the United States District Court for the Southern District of Texas, Houston Division. Venue is appropriate in this court.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(I) and (3). 4. At all relevant times, Defendant TRL Group, Inc. ("TRL"), has continuously been a Delaware corporation doing business in the State of Texas and the City of Houston, and has continuously had at least 15 employees. 5. At all relevant times, TRL 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). TRL may be served with process by serving its registered agent, Corporation Service Company, d/b/a CSC-Lawyers Incorporating Service Company, which may be found at 701 Brazos Street, Suite 1050, Austin, Texas 78701. 6. Since its inception, Trilegiant Corporation has continuously been a Delaware corporation doing business in the State of Texas and the City of Houston, and has continuously had . at least 15 employees. 7. Since its inception, Trilegiant Corporation has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of
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Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h). Trilegiant Corporation may be served with process by serving its registered agent, Corporation Service Company, d/b/a CSC-Lawyers Incorporating Service Company, which may be found at 701 Brazos Street, Suite 1050, Austin, Texas 7870 l.
STATEMENT OF CLAIMS 8. More than thirty days prior to the institution of this lawsuit, Starla Griffin filed a charge with the Commission alleging violations ofTitle VII by Defendants. All conditions precedent to the institution of this lawsuit have been fulfilled. 9. Since at least March 2003, Defendants have engaged in unlawful employment practices at the Trilegiant Contact Center in Houston, Texas, in violation of Section 703(a)(l) of Title VII, 42 U.S.C. §§ 2000e-2(a). 10. While working for Defendants, Starla Griffin and other women were subjected to an unlawful, sexually hostile environment. 11. Michael Cain was the trainer and supervisor of Membership Sales Consultant trainees. Cain asked female trainees out on dates and made explicit sexual propositions to them. 12. Ms. Griffin complained to Cain's supervisor about Cain's conduct towards her. Ms. Griffin also attempted to tell Cain's supervisor what she knew about Cain's harassment of other women, but Cain's supervisor refused to listen to this evidence. Defendants took no action to prevent or correct Cain's harassment of female trainees. 13. The sexual harassment caused the constructive discharges of female trainees at the Trilegiant Contact Center. 14. The effect of the practices complained of in paragraphs 10-13 above has been to deprive Starla Griffin and other female trainees of equal employment opportunities and otherwise
3

adversely affect their status as employees, because of their sex. 15. The unlawful employment practices complained of in paragraphs 10-13 above were
intentional. 16. The unlawful employment practices complained of in paragraphs 10-13 above were
done with malice or with reckless indifference to the federally protected rights ofStarla Griffin and other female trainees.
PRA YER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants TRL Group, Inc., and Trilegiant Corporation, their officers, successors, assigns, and all persons in active concert or participation with them, from engaging in sexual harassment and any other employment practice which discriminates on the basis ofsex, and from engaging in unlawful retaliation against employees who complain about sexual harassment and other unlawful employment practices. B. Order Defendants to institute and carry out policies, practices, and programs which provide equal employment opportunities for women and employees who complain of employment practices prohibited by Title VII, and which eradicate the effects of its past and present unlawful employment practices. C. Order Defendants to make whole female trainees who lost their jobs as a result ofthe unlawful harassment by providing appropriate backpay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to their reinstatement. D. Order Defendants to make whole female trainees who lost their jobs as a result ofthe
4

unlawful harassment by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 10-13 above, including job search expenses and medical expenses not covered by Defendants' employee benefit plan, in amounts to be determined at trial.
E. Order Defendants to make whole Starla Griffin and other female trainees by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraphs 10-13 above, including emotional pain, suffering, inconvenience, loss of enjoyment of life, and humiliation, in amounts to be determined at trial.
F. Order Defendants to pay Starla Griffin and other female trainees punitive damages for its malicious and reckless conduct described in paragraphs 10-13 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.
Respectfully submitted,
Eric S. Dreiband General Counsel James L. Lee Deputy General Counsel Gwendolyn Young Reams Associate General Counsel Equal Employment Opportunity Commission 1801 L Street, N.W. 5

Washington, D.C. 20507
Southern Dist. of Texas No. 20023 Equal Employment Opportunity
Commission 1919 Smith Street, 7th Floor Houston, Texas 77002 (713) 209-3395 (713) 209-3402 [facsimile]
OF COUNSEL: Jim Sacher Regional Attorney Rose Adewale-Mendes Supervisory Trial Attorney Equal Employment Opportunity Commission 1919 Smith Street, 7th Floor Houston, Texas 77002
6

JS44

~

_

(Rev. 07/89)

_

CIVIL COVER SHEET

_

The JS 44 civil cover sheet and the infonnation 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 fonn,

approved by the Judicial conferen~cUnoited Stales in Seplember 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON TH E REVERSE

OF THE FORM.)

f\t I(a) PLAINTIFFS
EQUAL EMPLOYMEN .

ORTUNITY COMMISSION

l (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF

(EXCEPT IN U.S. PLAINTIFF CASES)

DEFENDANTS
TRL Group, Inc., nnd Trilegiant Corporation
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT: Harris (IN U.S. PLAINTIFF CASES ONLy)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

NUrSuuS:'.~~,: gr- : (c) AnORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE

~imothY I EEOC-HoMu.stBonowDnies,trTicritaOl Affitctoerney

I 1919 Smith Street, 7th Floor

,~

ouston, Texas 77002

SfP

"LD
2 3 2004

.

1 _ 0 4 AnORNEYS (IF KNOWN)

-_

3v 703.
l

713 209-3395

II. BASIS OF JURISDICTION

[xl I U.S. Government Plaintiff
[] 2 U.S. Government Defendant

[) 3 Federal Question (U.S. Government Not a Party)
[) 4 Diversity (Indicale Citizenship of Parties in Item III)

II. CITIZENSHIP OF PRINCIPAL PARTIES (p1.ACIlAN,INONEBOX

(For Diversity Cases Only)

FOR PLAINTIFF AND ONI! BOX FOR DEHlNDAmj

PTF DEF

PTF DEF

Citizen of This State [ ] I [] I Incorporated or Principal Place [] 4 [] 4

of Business in This State

Citizen of Another State []2 []2 Incorporated and Principal Place [ ] 5 [] 5

of Business in Another State

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

[]6 []6

Foreign Countr

IV. CA USE 0 FACTION (CI11;nlE US CIVIL STATIITE UNDER WIIICH YOU ARE FII.INO AND WRl11l ABRIEF STAlUMENT OF CAUSE DO NOT CITE IURi'DlCTIONAL STATlITES UNLESS DIVERSITY)
Defendant has engaged In unlawful employment practices in violation of Section 703 of Title VII, and Section 102 of the Civil Rights Act of 1991. The practices include SUbjecting women' to an unlawfully hostile work environment.

V NATURE OF SUIT (PLACE AN x IN ONE BOX ONLy)

CONTRACT

TORTS

[] 110 huwun", . [] 120 M.nn,
[] 130 M,II", Aot
[] 140 Negotiable Inslrumcnl
[] ~9~:;:~;Ju~=~mcnt &
[] 151 Medlcan: Act
lJ J~~::1n::~:::~)
[] ~e~~e~~CM:tpa)TT1Ct1t of
[] 160 Stocl..holdcu' SUib
(] 190 ()th." Con"",t
[J 195 Contnact Product Liability
REAL PROPERTY
[] 210 Lund Cond..""","on [] 220 I'orecl",,,,,,
[] 230 Rent Lease & Ejectment
[] 240 T"", to Lund
[] 245 Ton Product Liability
(] 290 All Qth." R"I Proporty

PERSONAL INJURY [] 310 Aupl.n,
(] 31 S Auplzme Produ1.1 Llablhty

[] 320 Aaslluh, Libel & Slander

[] 330 Federal EmployCT'!' Liability

[] 340 M.nne
[] 345 Manne Product Liability
[J 350 Molm V,h"l,

[] 355 Molor Vehicle Product

LUlblhty

[] 360 Qth." P,~"",,llnJOUY

-

CIVIL

RIGHTS

[] 441 Vo"ng [X] 442 Employm"" [] 443 I1o""nglA~"oru [] 444 W,lr,,,, [] 440 Qth." C,,,I Righ"

[]PERSONAL INJURY 36t:~:~~~n~t:··
[] 36t::I~nal InJwy--Product
[] 36~""'o, P""onal InJOU)'
uctLlllbllity
PERSONAL PROPERTY [] 370 Qth." I'nouJ
[] 371 Truth In lending [] 380 Other Personal Property Damage
[] t!~II~perty Damage Product
PRISONER PETITIONS
[] 510 Motions to VllcalcSentence Habeas Corpus
[] 530 Gononol [] 535 o..th P",.lty [] 540 M.ndom", &Qth." [] 550 00",

FORFEITURE/PENALTY
[] 610 Agn"I,.... [] 620 Oth" Food &Dm8
[] ~~~I~~~~8~OL"",or
[] 630 l.lquor Law~
[] 640 RR&Tru,k
[] 650 Alrhne Rcs' [] 660 Occupational SBfety/HCBlth
[] 690 00" LABOR
[] 71 0 ~lI.lf Lubor Standards Act
[] 720 LulomlMgmt Rd,""", [] 7igl~~~11 Reporting
[] 740 Rllllwlly LIlbor Act
[] 790 Qth." 1..1om L"'8'''on [] 791,~mpl Rct In, Soo""'Y

BANKRUPTCY [] 422 Appeal" USC 158 [] 423 W,thdnow,128 usc 157
PROPERTY RIGHTS
[] 820 Copynghu [] 830 P"on' [] 840 1nodemouk
SOCIAL SECURITY
[] 861 HIA (139511) [] 862 m"k Lwog (923) [] 863 DIWC/DIWW (405(g»
[] 864 SSID To", XVI
(] 865 RSI (40S(g)
FEDERAL TAX SUITS
[] ~1~~~:)C! (U S Plaintiff Of
[] 871 IRS-11unI P,uty 26 USC 7609

OTHER STATUTES
(] 400 State Reapporuonment
[] 410 An""""
[] 430 B.nn ,nd Ilonk,"t! [] 450 Co~cc Ra"'-'''' [] 460 Doportoo"on
[] 46r0ga:~:t:: Influenced Dnd Corrupt
[] 810 Sol",,,,,, &Moe [] "~~a:untlesIComrnor.htJcsJ
[] 87~2~~~4~~hallenBC [] 891 Agn,ulturol A,,,
[] 892 Econotme Stahlhzatlon Act [] 893 EnVlroruncnta\ Mutters [] 894 Energy Allocotlon Act [] 895 fn:cdom oflnfonnlltlon Act
(] 'tPJ."Appcnl or,,,, D,,,,,,",,,,,,,,"
Equal Aoocsi lo Justice [] 950 ConsmutJOJUlhty of SUile Statutes [] 890 Other Statutory ActIOns

VI. ORIGIN
[x] I Original Proceeding

(PLACE AN x IN ONE BOX ONLy)

(] 2 Removed from

[] J Remanded from

State Court

Appellate Court

Transferred from

[] 4 Reinstated or

[] 5 another district

Reopened

(specify)

Appeal to Distnct

[] 6 MultidlStrict

(] 7 Judge from

litigation

Magistrate Judgment

VII. REQUESTED IN

CHECK IF THIS IS A CLASS ACTION

COMPLAINT:

(] UNDER F.R C P. 23

DEMAND $

Check YES only if demanded in complaint:
JURV DEMAND, [X] YES (] NO

VIII. RELATED CASE(S) IF ANY (Sooi","""""",)

JUDGE

IJA~ J ;J3/UI..(

G & - SIGNATUR~:C?rq

DOCKET NUMBER

UNITED STATES DISTRICT COURT

 
 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

United States Courts Southern District of Texas
ENTERED
NOV 0 9 2004 Mlchl.1 N. Milby, Clerk of Coan

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
v.
TRL GROUP, INC., and TRILEGIANT CORP.,
Defendants.

§ § § § § § CIVIL ACTION NO. H-04-3703 § § § § §

CONSENT DECREE

The Equal Employment Opportunity Commission ("Commission" or "EEOC") alleges that

Defendants are legally responsible for unlawful sexual harassment which occurred at Defendants'

Trilegiant Contact Center in Houston. The Commission alleges that the trainer and supervisor of

Membership Sales Consultant trainees at that location subjected Starla Griffin and other women to

an unlawful, sexually hostile environment that deprived these women of equal employment

opportunities and otherwise adversely affected their status as employees, because of their sex, in
violation of Title vn of the Civil Rights Act of 1964, as amended ("Title VIT'), and Title I of the

Civil Rights Act of 1991.

The parties stipulate to the jurisdiction of the Court and waive a hearing and the entry of

findings of fact and conclusions oflaw.

It is therefore ORDERED that:

1. This Consent Decree is entered in full and complete settlement ofany and all claims

arising out of or contained in this lawsuit, Civil Action No. H-04-3703, and in EEOC Charge No.

(

330-2003-02645. 2. Defendants agree that they will not engage in any employment practice which violates
Title vn by unlawfully discriminating against any individual because of such individual's sex.
3. Defendants agree that they will not retaliate against any individual who opposes any
practic~ made an unlawful employment practice by Title vn, or against any individual who has
provided testimony or evidence related to this lawsuit or to the Charge ofDiscrimination upon which this lawsuit was based.
4. Within forty-five (45) days after the Court's entry of this Consent Decree, all Defendants' supervisors and managers in their training departments shall receive training on employment discrimination laws. The training shall include instruction on the investigation of employee complaints of any type ofunlawful harassment, including sexual harassment. Prior to such training session, the Houston District Office of the EEOC shall receive a copy of the training presentation outline. Within ten (10) days after the completion of the training, the EEOC shall be provided with a sworn statement attesting to the date on which the training was completed, . verification of attendance, and verification that all topics in the training presentation outline were covered; also, the EEOC will be provided with copies of forms -- signed by all managers at the conclusion ofthe training -- acknowledging the managers' responsibility to protect employees from harassment.
S. More than nine (9) months after the Court's entry ofthis Consent Decree, but prior to the expiration ofthe Decree, all Defendants' supervisors and managers in their training departments shall receive another training session on employment discrimination laws. The training shall include instruction on the investigation of employee complaints of any type of unlawful harassment,
2

including sexual harassment. Prior to such training session, the Houston District Office ofthe EEOC shall receive a copy ofthe training presentation outline. Within ten (1 0) days after the completion of the training, the EEOC shall be provided with a sworn statement attesting to the date on which the training was completed, verification of attendance, and verification that all topics in the training presentation outline were covered; also, the EEOC will be provided with copies offorms -- signed by all managers at the conclusion of the training -- acknowledging the managers' responsibility to protect employees from harassment.
6. Defendants agree that within the first week that they begin work as trainees, all Membership Sales Consultant trainees will be advised ofDefendants' anti-discrimination policy, and will be advised of the procedures for making internal complaints of sexual harassment.
7. If Defendants open or operate any Contact Centers in Texas while this Decree is in effect, a non-discrimination notice will be posted at any such location for as long as this Consent Decree is in effect. A copy of this notice is attached hereto as Exhibit "A." The notice will be posted in a location, to be agreed upon by the parties, which is conspicuous and accessible to all employees. Defendants shall designate a manager, whose name will be provided to the EEOC, who will be responsible for ensuring that the notice remains posted during the term of this Decree.
8. Defendants agree to pay Starla Griffin a lump sum ofTHlRTY-FIVE THOUSAND DOLLARS ($35,000.00) within ten (10) calendar days from the date ofentry ofthis Decree and the effective date of a Waiver and Release signed by Starla Griffin. The check shall be mailed via certified mail, return receipt requested, to Starla Griffin at her home address, which will be supplied to Defendants by Plaintiff. A copy ofthe check shall be sent concurrently to the Commission at the following address: Equal Employment Opportunity Commission, attn: Timothy M. Bowne, 1919
3

Smith Street, 7th Floor, Houston, Texas 77002. To receive this payment, Ms. Griffin must execute a separate Waiver and Release fonn, the tenns of which will have been negotiated and agreed upon prior to the filing of this Decree.
9. Within ten (10) days after the Court's entry ofthis Consent Decree, Defendants shall provide EEOC with the names and last known addresses and telephone numbers -- to the extent these are in Defendants' possession, custody, or control -- of women who were Membership Sales Consultant trainees at the Trilegiant Contact Center in Houston at any time from March 1, 2003 through June 30, 2003. For any ofthese women who the EEOC is unable to locate after a reasonable search or for any ofthese women who the EEOC is unable to confirm that it has located the correct individual, the EEOC may request further contact information, including Social Security numbers, for any such women for whom it is unable to locate or confinn the identity, and the Defendants shall provide the EEOC with such information, if it within Defendants' possession, custody, or control.
10. Defendants agree to pay an additional sum of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00) to resolve the claims of female former Membership Sales Consultant trainees other than Ms. Griffin. Within sixty (60) days from the date of entry of this Decree, EEOC will supply Defendants with a list of former Membership Sales Consultant trainees who will share portions ofthis amount, along with the respective amounts to be paid the listed women. Within ten (10) calendar days after receiving this list from EEOC and the effective date ofa Waiver and Release signed by each such individual, Defendants shall issue checks to the listed individuals, in accordance with the amounts stated on the list. A copy ofeach ofthese checks shall be sent concurrently to the Commission at the following address: Equal Employment Opportunity Commission, attn: Timothy M. Bowne, 1919 Smith Street, 7th Floor, Houston, Texas 77002. Individuals receiving any
4

payments pursuant to this Consent Decree are precluded from bringing any claims that Defendants, through the date of entry of this Consent Decree, violated Title VII or other anti-discrimination statute by subjecting them to a hostile work environment. To receive this payment, the identified individual must execute a separate Waiver and Release fonn, the terms of which will have been negotiated and agreed upon prior to the filing of this Decree. Signed Releases will be forwarded within five (5) business days after signing to Defendants' counsel.
11. Defendants agree that on the list referenced in paragraph 10, above, EEOC may designate women who contend that they were constructively discharged from their jobs because of sexual harassment. For any woman so designated, provided that the individual's job performance at the Houston Contact Center was satisfactory while employed by Trilegiant, Defendants agree to offer that individual, at her sole discretion, either 1) employment at another ofDefendants' call centers; or (2) to provide a positive job reference for that individual should she re-apply at the Houston call center formerly owned by Defendants. In the event that any woman so designated chooses employment at another of Defendants' Contact Centers, each individual must meet all standards required ofother similarly-situated employees, including without limitation those related to training and other requirements of employment.
12. Defendants acknowledge that Michael S. Cain no longer works for them or any affiliated company, and agree that he will not be re-hired by Defendants within the term of this Decree.
13. This Decree shall remain in effect for eighteen months from the date of signing. During that period, the Court shall retain jurisdiction to assure compliance with this Decree and to permit entry of such further orders or modifications as may be necessary or appropriate.
5 .

14. The parties shall bear their own costs and attorney's fees. 15. The parties agree that nothing in this Consent Decree or Exhibit A, including without limitation any payments made by the Defendants, shall be deemed or construed at any time for any purpose as an admission by the Defendants or their affiliates ofany liability or unlawful conduct ofany kind, all of which the Defendants deny. 16. The parties agree that any press release concerning the settlement ofthis matter and/or this Consent Decree will be jointly issued and will be agreed upon by both parties prior to the issuance of any such press release.

III Signed on this --=..g......:(J-C-:.._ .- _ _ day of

~

,2004.

United States District Judge

6

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Houston District Office
1919 Smith St, 7'" Floor Houston, TX 77002·8049
PH: (713) 209·3372 FAX: (713) 209·3381 LEGAL: (713) 209·3401
NOTICE PURSUANT TO TITLE VII OF THE CIVIL RIGHTS ACT OF 1964,
and THE CIVIL RIGHTS ACT OF 1991
1. Federal law requires that there be no discrimination against any employee or applicant for employment because of the employee's sex, national origin, race, or religion with respect to compensation, hiring, promotions, or other terms, conditions or privileges of employment. This federal law prohibits sexual harassment.
2. Trilegiant support and will comply with such Federal law in all respects and will not retaliate against employees who have exercised their rights under the law by filing charges with the Equal Employment Opportunity Commission (EEOC), providing information to the EEOC, and/or receiving a settlement of such charges.
3. Any applicant or employee who wishes to complain ofillegal discrimination is advised to report such complaint to Human Resources. Also, employees who believe they have been subjected to illegal employment discrimination can contact the Equal Employment Opportunity Commission ("EEOC") at 1919 Smith Street, Houston, TX 77002, (713) 209-3372.
SIGNED this _ _ day of _ _ _ _ _ _ _, 2004.

[Management Official] This NOTICE shall be posted until _ _ _.....,--_ _ _ _ _:, 2006.

170694v2

Exhibit "A"

 
 DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

https://ecf.txsd.uscourts.gov/cgi-bin/DktRpt.pl?559945420216733-L_3...

U.S. District Court SOUTHERN DISTRICT OF TEXAS (Houston) CIVIL DOCKET FOR CASE #: 4:04-cv-03703

CLOSED

Equal Employment v. TRL Group Inc. et al Assigned to: Judge Lee H Rosenthal Cause: 28:451 Employment Discrimination
Plaintiff Equal Employment Opportunity Commission
V. Defendant TRL Group Inc. Defendant Trilegiant Corp.

Date Filed: 09/23/2004 Date Terminated: 11/08/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Timothy M Bowne EEOC 1919 Smith 6th Fl Houston, TX 77002 713-209-3395 Fax: 713-209-3402 Email: timothy.bowne@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 09/23/2004 09/23/2004 09/23/2004
10/07/2004

#

Docket Text

1 COMPLAINT against TRL Group Inc., Trilegiant Corp. (Filing fee $ 150) filed by Opportunity Commission Equal Employment.(hlerma, ) (Entered: 09/23/2004)
Summons Issued as to TRL Group Inc., Trilegiant Corp. , filed.(hlerma, ) (Entered: 09/23/2004)
2 ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons Initial Conference set for 1/28/2005 08:45 AM in Courtroom 11B before Judge Lee H Rosenthal. Parties notified.(hlerma, ) (Entered: 09/24/2004)
3 CERTIFICATE OF INTERESTED PARTIES by Equal Employment Opportunity Commission, filed.(Bowne, Timothy) (Entered: 10/07/2004)

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DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

https://ecf.txsd.uscourts.gov/cgi-bin/DktRpt.pl?559945420216733-L_3...

11/03/2004 11/08/2004

4 AGREED MOTION to enter Consent Decree by Equal Employment Opportunity Commission, TRL Group Inc., Trilegiant Corp., filed. Motion Docket Date 11/23/2004. (sjones, ) (Entered: 11/05/2004)
5 CONSENT Decree/JUDGMENT.( Signed by Judge Lee H Rosenthal ) Parties notified.(rkonieczny, ) (Entered: 11/09/2004)

PACER Service Center

Transaction Receipt

06/12/2007 13:23:22

PACER Login: hs0328

Client Code: eeoc

Description: Docket Report Search Criteria: 4:04-cv-03703

Billable Pages: 1

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