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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

~TEDSTATESEQUALENWLOYMENT

OPPORTUNITY COMMISSION,

Plaintiff,
v.
MOKA SHOE CORPORATION,
Defendant.

CIVIL ACTION NO.
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INJUNCTIVE RELIEF SOUGHT

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NATURE OF THE ACTION This is an actionunderTitleVIIoftheCivilRightsAct of1964 andTitle I ofthe CivilRights Act of 1991 to correct unlawful employmentpractices on the basis of sex and retaliation, and to provide appropriatereliefto MaribelRodriguez,SylviaCaban,and anyother similarlysituatedindividuals,who were adversely affected by such practices. As stated with greater particularity in paragraph 7, the United States Equal Employment Opportunity Commission (hereinafter the "EEOC" or the "Commission") alleges that Ms. Rodriguez, Ms. Caban and other similarly situated females were sexually harassed by Defendant's Production Manager at its Aguadilla, Puerto Rico location, when they were forced to endure unwelcome sexual commentsandphysicaltouchingbecauseoftheir sex, female. The harassment was sufficiently severe andpervasiveto createahostile,intimidatingwork environment.The Commissionfurtheralleges that Defendant subsequently retaliated againstMs. Caban by demoting her, transferring her and subjecting her to adverse terms and conditions of employment for engaging in protected activity. Defendant Employer's retaliatory conduct created a serious and material change in the terms and conditions of
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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 2 of 6

Ms. Caban's employmentrenderingher workingconditions so intolerablethat shewas forcedto resign.

JURISDICTION AND VENUE

1. Jurisdictionofthis Courtisinvokedpursuantto 28US.C. §§451, 1331,1337, 1343and

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

Rights Actof1964, as amended,42US.c. § 2000e-5(f)(I) and (3) ("TitleVII"),and Section 102ofthe

Civil Rights Act of 1991,42 US.C. § 1981A. 2. Theemploymentpracticesallegedto be unlawfulwerecommittedwithinthejurisdiction
ofthe United States District Court for the District of Puerto Rico.

PARTIES

3.

Plaintiff,theUnited StatesEqual Employment Opportunity Commission (the "Commission"

or "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(£)(1) and (3)

of Title VII, 42 US.C. § 2000e-5(£)(1)and (3).

4.

At all relevant times, Defendant, a Puerto Rico corporation, has continuously been doing

business in Puerto Rico and has continuously had at least 15 employees.

5.

At allrelevant times, Defendant has continuously been an employer engaged in an industry

affecting commerce within the meaning of Sections 70I (b), (g) and (h) of Title VII, 42 US.c. §§2000e(b), (g) and (h).

STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Ms. Rodriguez and Ms. Caban

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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 3 of 6

each filedchargeswith theCommissionallegingviolationsofTitleVll bytheDefendant. Allconditions

precedent to the institution of this lawsuit have been fulfilled. 7. Since at least May of 2004, Defendant Employer engaged in unlawful employment

practices in violation of Section 703(a) and Section 704(a) of Title VII, 42 U.S.C. §2000e-2(a) and

§2000e-3(a). a.

Ms. Rodriguez,Ms. Caban,and othersimilarlysituatedfemaleswere regularly

subjectedto sexual harassment by their supervisor, in the form of unwelcome

verbal comments and physical touching which were sufficiently severe and

pervasiveto constitutean intimidating, hostile and offensive work. The harassment included,but wasnot limitedto, frequent,egregioussexualcommentsincluding,

but not limited to, vulgar comments regarding sexual acts, offensive remarks

regarding their bodyparts, including their breasts and buttocks, and invitations to

engage in sexual activity in exchange for job advancement. On at least one

occasion, Defendant's Production Manager grabbed Ms. Rodriguez' buttocks. b. Ms. Rodriguez and Ms. Caban complainedrepeatedly to Defendant's upper

managementandHumanResourcesManagerregardingtheharassment,but they

failed to take prompt remedial action. c. Further,DefendantretaliatedagainstMs.Cabanforcomplainingofthe unlawful

sexualharassmentby demotingher, subjectingher to aninvoluntaryjob transfer

and adverse terms and conditions of her employment. d. DefendantEmployer'sretaliatoryconductcreateda seriousandmaterial change

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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 4 of 6
in the terms and conditions ofMs. Caban's employmentrenderingher working conditions so intolerable that she was forced to resign. 8. The effectofthe conductcomplained of in paragraph 7 abovehas been to deprive Ms. Rodriguez, Ms. Caban, and other similarly situated females of equal employment opportunities and otherwise adversely affect their status as employees on the basis of sex and/or retaliation for their opposition to unlawful employment practices. 9. The unlawful employment practices complained ofin paragraph 7 above were intentional. 10. Theunlawfulemploymentpracticescomplained ofin paragraph7 aboveweredonewith malice or with reckless indifference to the federally protected rights of Ms. Rodriguez, Ms. Caban and any other similarly situated individuals.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant apermanent injunction enjoining Defendant, its officers,successors, assigns, and all persons in active concert or participation with Defendant, ITomengagingin unlawful retaliation, sex discrimination and any other employmentpractice which discriminates on the basis of sex and/or opposition to an unlawful employment practice. B. Order Defendant, to institute and carry out policies, practices, and programs which provide equal employment opportunitiesfor females,andwhich eradicate the effectsof its past unlawful employment practices. C. Order Defendant to make whole Ms. Rodriguez, Ms. Caban and any other similarly situated individuals by providing appropriateback pay with prejudgment interest, in amounts to be
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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 5 of 6

detennined at trial, and other affinnative relief necessary to eradicate the effects of its unlawful employment

practices. D.

Order Defendant to make whole Ms. Rodriguez, Ms. Caban and any other similarly

situated individualsby providingcompensationforpast and futurepecuniary losses resulting ITomthe

unlawful employment practices described in paragraph 7 above, including out of pocket losses in amounts to be determined at trial.
E. Order Defendant to make whole Ms. Rodriguez, Ms. Caban and any other similarly situatedindividualsbyprovidingcompensationforpast andfuturenonpecuniarylossesresultingfromthe

unlawful practices complained ofin paragraph 7 above, including emotional pain, suffering, inconvenience, humiliation, and loss of enjoyment of life, in amounts to be detennined at trial.
F. Order Defendant to pay Ms. Rodriguez, Ms. Caban and any other similarly situated individualspunitivedamagesforitsmalicious and reckless conduct described in paragraph7 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 in this action.
JURY TRIAL DEMAND

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

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Case 3:06-cv-01976-ADC Document 1-1 Filed 09/29/2006 Page 6 of 6
Respectfully Submitted, RONALD COOPER General Counsel JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel DELNER FRANKLIN-THOMAS Regional Attorney NORA E. CURTIN Supervisory Trial Attorney
~ ZA I GOME~ USDC-P.R. No.: 219311 EEOC Miami District Office One Biscayne Tower, Suite 2700 Two South Biscayne Boulevard Miami, FL 33131-1805 Tel.: (305) 808-1783 Fax: (305) 808-1835 maritza. gomez@eeoc.gov
7

 
 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,

CIVIL ACTION NO. 3:06-cv-1976 (AOC)

v.

MOKA SHOE CORPORATION,

Defendant.
----------------------------~/

CONSENT DECREE I. THE LITIGATION I. This Consent Decree ("Decree") is made and entered into by and between Plaintiff, the Equal Employment Opportunity Commission, and Defendant Moka Shoe Corporation. EEOC and Defendant are collectively referred to as the "Parties" throughout this Decree. 2. EEOC filed this action alleging that Defendant violated Title VII of the Civil Rights Act of 1964 when it subjected Sylvia Caban and Maribel Rodriguez to sexual harassment and retaliated against Sylvia Caban for complaining about the unlawful harassment. Moka Shoe denies the allegations. 3. In the interest of resolving this matter and as a result of having engaged in comprehensive settlement negotiations, the parties have agreed that this action should be finally resolved by entry of this Decree. This Decree resolves EEOC Charge No. 1622005-00382 filed by Maribel Rodriguez against Defendant and EEOC Charge No. 1622005-00383 filed by Sylvia Caban. The Decree does not resolve any other Charges of

Discrimination including any pending or future charges.
n. FINDINGS
4. Having carefully examined the terms and provisions of this Decree, and based on the pleadings, record, and stipulations of the parties, the Court finds the following:
a. This Court has jurisdiction over the subject matter of this action and the parties.
b. No party shall contest the jurisdiction of this Federal Court to enforce this Decree and its terms or the right of the EEOC to bring an enforcement suit upon alleged breach of any term(s) of this Decree.
c. The terms of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, successors, and assigns of Defendant.
NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: III. MONETARY RELIEF
5. Defendant shall pay an aggregate of ONE HUNDRED THOUSAND DOLLARS ($100,000.00) to resolve this litigation to be paid to Sylvia Caban and Maribel Rodriguez in the manner set forth below:
a. Fifty thousand dollars ($50,000) shall be paid to Sylvia Caban 1. Twenty thousand dollars ($20,000) shall be representative
of lost wages to Sylvia Caban, less amounts required to be withheld for Commonwealth of Puerto Rico income taxes. Defendant will issue a Commonwealth of Puerto tax form to Sylvia Caban for such amount, and Defendant shall be responsible for paying the

employer's share of any income taxes and social security withholdings. 2. Thirty thousand dollars ($30,000) shall be representative of
compensatory damages. Defendant shall issue a Commonwealth of Puerto Rico tax fonn to Sylvia Caban for this amount.
b. Fifty thousand dollars ($50,000) shall be paid to Maribel Rodriguez.
1. Twenty thousand dollars ($20,000) shall be representative of lost wages to Maribel Rodriguez, less amounts required to be withheld for Commonwealth of Puerto Rico income taxes. Defendant will issue a Commonwealth of Puerto tax fonn to Maribel Rodriguez for such amount, and Defendant shall be responsible for paying the employer's share of any income taxes and social security withholdings.
2. Thirty thousand dollars ($30,000) shall be representative of compensatory damages. Defendant shall issue a Commonwealth of Puerto tax fonn to Maribel Rodriguez for this amount.
6. Defendant shall make these payments m three installments of equal amounts:
a. The first payment shall be made by September 15, 2008. b. The second payment shall be made by October 15,2008. c. The third payment shall be made by November 15, 2008. Defendant shall mail all payments described in paragraph 5(a) directly to Sylvia Caban Certified Mail (Return Receipt Requested) at the following address: 3342 S. Semoran Blvd. Apt. 8, Orlando, FL 32822 and in paragraph 5(b) to Maribel Rodriguez at the

following address: 262 Pascua Street, Urb. Corchado, Isabela, PR 00662. Copies of all payments and tax forms shall be forwarded to the attention of Nora E. Curtin, Regional Attorney, U.S. Equal Employment Opportunity Commission, Miami District Office, 2 South Biscayne Blvd., Suite 2700, Miami, Florida 33131 within five calendar days of issuance.
7. If Defendant fails to tender payments described in paragraph 5 in the manner set forth in paragraph 6, then Defendant shall pay interest on the defaulted payment at the rate calculated pursuant to 26 U.S.C. §6621(b) until it is paid, and bear any additional costs incurred by Defendant's delay or non-compliance.
IV. GENERAL INJUNCTIVE PROVISIONS 8. Defendant denies that it engaged in any discriminatory conduct but agrees that Moka Shoe, its officers, managers, employees, agents and partners, successors and assigns, shall refrain from engaging in sexual harassment in violation of Title VII of the Civil Rights Act of 1964. 9. Defendant, its officers, managers, agents and partners, successors and assigns, and all persons acting in concert with shall refrain from retaliating against any employee because he or she has opposed any of Defendant's practices which the employee believed to be a violation of Title VII, filed a charge of discrimination with the EEOC alleging violation(s) of such statute, testified or participated in any manner in any investigation, proceeding, or hearing under Title VII, or asserted any rights under this Decree.
V. DISTRIBUTION OF ANTI-DISCRIMINATION POLICY 10. Defendant shall redistribute its written policy prohibiting discrimination

and sexual harassment ("Policy") to all current employees and management staff within sixty calendar days after the entry of this Consent Decree. This Policy shall clearly defme conduct prohibited by Title VII. The Policy shall specifically prohibit all forms of sexual harassment and retaliation.
11. A copy of the Policy referenced in paragraph 10 shall be forwarded to EEOC within thirty calendar days of the entry of this Decree. This and any other submissions, reports, certifications, notices, or other materials that are required to be submitted to EEOC shall be mailed to Nora E. Curtin, Regional Attorney, U.S. Equal Employment Opportunity Commission, Miami District Office, 2 South Biscayne Blvd., Suite 2700, Miami, Florida 33131.
12. The Policy shall be included in any relevant policy or employee manuals kept by Defendant's business. The Policy shall also be kept and maintained in a conspicuous and accessible place for all employees at all of Defendant' facilities and printed in a font that is easily legible (at least 12 point font). The Policy shall be kept and maintained in an area that is accessible to all workers.
13. A copy of the Policy shall be distributed to each new regular full-time, part-time, or temporary employee on the day the employee is hired and, for temporary workers who are assigned to work for Defendant through a staffing or temporary agency, on the day that the worker first performs work for Defendant. The manager responsible for distributing the Policy shall review the Policy in depth with each new employee. Defendant shall maintain records demonstrating that each new employee discussed the Policy with the responsible manager and illustrating the length of time spent discussing the Policy.

VI. TRAINING 14. Defendant shall provide training to all of its management personnel on Title VII and the Policy. The training shall be conducted by videotape which has been prepared by an entity acceptable to the EEOC. This training shall be conducted separately from other job-related training and/or business-wide meetings and the training sessions shall be dedicated solely to Title VII and the Policy. Defendant shall provide EEOC with written notice of the training session, including the location of the training, no later than fifteen business days before the session. Defendant will provide EEOC any and all copies of:pamphlets, brochures, outlines, or other written materials provided to the participants of the training sessions at least fifteen calendar days before any materials are used in the training sessions. 15. Defendant agrees that EEOC shall, at EEOC's discretion, be in attendance at each training session. 16. Within ten calendar days of completing the training session, Defendant shall notify EEOC of the dates the training was conducted, the name and title of the person(s) who conducted the training, and the name and job title of each person who received the training.
VII. POSTING OF NOTICE 17. Within ten (10) business days after entry of this Decree, Defendant shall post an eleven (11) inches by fourteen (14) inches laminated copy of a Spanish-language translation of the Notice attached as Exhibit A to this Decree at each of its facilities in a conspicuous location easily accessible to and commonly frequented by persons who

perfonn work for Defendant. The Notice shall remain posted for one year from the date of entry of this Decree. Defendant shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other material. Defendant shall certify to EEOC in writing within fifteen days after entry of the Decree that the Notice has been properly posted. Defendant shall pennit a representative of EEOC to enter Defendant's premises for purposes of verifying compliance with this paragraph at any time during nonnal business hours without prior notice.
VIn. MONITORING AND REPORTING 18. Defendant shall furnish to EEOC the following written reports twice annually for a period of one year following the entry of this Decree. The first report shall be due six months after entry of the Decree. Each report shall contain:
a. A description of each complaint of sexual harassment, including the names, addresses and current telephone numbers of the complaining parties and witnesses and the resolution of such complaint of each person complaining about discrimination.
b. A description of any and all action Defendant took in response to each complaint, conclusions reached, and actions taken as a result of each complaint, and all related investigative records and/or documents related to the complaintls and investigation/so
C. A certification by Defendant that the Notice required to be posted remained posted during the entire six month period preceding the report.
19. Defendant shall provide the last known home address, home telephone number, and mobile telephone number for all persons within its employ during the tenn

of the Decree whom EEOC requests and identifies for purposes of verifYing compliance

with this Decree within ten business days of EEOC's request. In the event that EEOC is

unable to contact an employee for purposes of verifYing compliance with this Decree, it

shall notifY Defendant and Defendant shall, within ten business days, provide EEOC with

the employee's scheduled hours of work over the next fourteen day period so that EEOC

can conduct interviews during employees' breaks, at the end of the day, or at some other

time convenient to the employee and EEOC. Defendant agrees that it will not discourage

employees from participating in the interviews.

20. Nothing in this Decree shall be construed to limit any obligation

Defendant may otherwise have to maintain records under any law or regulation.

IX. DURATION OF THE DECREE AND RETENTION OF JURISDICTION

21.

All provisions of this Decree shall be in effect for a period of one (I) year

immediately following entry ofthe Decree.

"fSO ORDERED, ADJUDGED AND DECREED, this .21 - day of August, 2008.

AGREED TO: FOR THE PLAINTIFF, UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

By: /s/ Nora E. Curtin
NORA E. CURTIN Regional Attorney
United States Equal Employment Opportunity Commission 2 S. Biscayne Blvd., Ste. 2700 Miami, FL 33131
Telephone: (305) 808-1789 Facsimile: (305) 808-1834 nora.curtin@eeoc.gov

Date: 20 August 2008

AGREED TO: FOR DEFENDANT MOKA SHOE CORPORATION

By: /s/ Graciela J. Belaval. Esq.
GRACIELA J. BELAVAL, ESQ. Attorney for Defendants BarNo. 201007
MARTINEZ, ODELL & CALABRIA P.O. Box 190998 San Juan, Puerto Rico 00919-0998 Tel.: (787) 753-8914 Fax: (787) 759-9075, 753-8402 E-mail: gbelaval@mocpr.com

Date: 20 August 2008

ENTERED:
Date: !f/2-I/O'6

~~~ HON. AIDA ~ELGO=COLON
UNITED STATES DISTRICT COURT JUDGE

EXHIBIT A
NOTICE TO ALL EMPLOYEES OF MOKA SHOE CORPORATION PURSUANT TO CONSENT DECREE
This Notice is being posted pursuant to a Consent Decree entered by the United States District Court in EEOC v. Moka Shoe Corporation, Civil Action No. 3:06-cv-1976 (ADC).
Moka Shoe Corporation is committed to providing all employees with a workplace that is free from discrimination.
EEOC is the United States government agency that enforces federal laws prohibiting employment discrimination on the basis of sex, race, national origin, religion, color, disability and age. If you believe you have been discriminated against, you may contact the San Juan Office of EEOC at 787771 1464. EEOC charges no fees and has employees who speak Spanish and English.
This Notice must remain posted for one year (1) from the date below and must not be altered, defaced or covered by any other material. Any questions about this Notice or compliance with its terms may be directed to:

Date:

MOKA SHOE CORPORATION

DO NOT REMOVE BEFORE AUGUST 2009.

 
 Case: 3:06-cv-1976 As of: 05/28/2017 06:26 PM AST 1 of 4
United States District Court District of Puerto Rico (San Juan) CIVIL DOCKET FOR CASE #: 3:06−cv−01976−ADC

JUDGE

United States Equal Employment Opportunity Commission v. MOKA Shoe corporation Assigned to: Chief Judge Aida M. Delgado−Colon Cause: 28:451 Employment Discrimination
Plaintiff

Date Filed: 09/29/2006 Date Terminated: 08/23/2008 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

United States Equal Employment Opportunity Commission

represented by Carla J. Von Greiff U. S. Equal Employment Opportunity Commission − Tampa, FL 501 E Polk St. Suite 1000 Tampa, FL 33602 813−202−7903 Fax: 813−228−2045 Email: carla.vongreiff@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Maritza I. Gomez−Fernandez Quintairos, Prieto, Wood & Boyer, P.A. 9300 S. Dadeland Blvd., 4th Floor Miami, FL 33156 305−670−1101 Fax: 305−670−1161 Email: maritzaigomez@yahoo.com TERMINATED: 12/22/2006 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Nora E. Curtin U.S. Equal Employment Opportunity Comm. Miami District Office One Biscayne Tower 2 South Biscayne Boulevard Suite 2700 Miami, FL 33131 305−808−1789 Fax: 305−808−1835 Email: nora.curtin@eeoc.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

V. Defendant MOKA Shoe corporation

represented by Graciela J. Belaval−Bruno Martinez Odell & Calabria PO Box 190998 San Juan, PR 00919−0998 787−274−2904 Fax: 787−759−9075 Email: gbelaval@mocpr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 3:06-cv-1976 As of: 05/28/2017 06:26 PM AST 2 of 4

Elizabeth M. Lizardi−Mendez Cond. Plaza del Prado 7 Carr. 833 Apt. 1104−A Guaynabo, PR 00969 787−306−6670 Fax: 787−759−9075 Email: elizardi@hotmail.com ATTORNEY TO BE NOTICED

Date Filed 09/29/2006 09/29/2006 11/27/2006 12/07/2006 12/22/2006 04/03/2007 04/24/2007
12/17/2007 01/14/2008
01/15/2008

# Docket Text
1 COMPLAINT against MOKA Shoe corporation (Filing fee $ 350.), filed by United States Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4)(Gomez−Fernandez, Maritza) (Entered: 10/03/2006)
Summons Issued as to MOKA Shoe corporationService due by 1/27/2007. (jap, ) (Entered: 10/04/2006)
2 NOTICE Notice of Withdrawal of Counsel by United States Equal Employment Opportunity Commission (Gomez−Fernandez, Maritza) (Entered: 11/27/2006)
3 ANSWER to Complaint filed by Graciela J. Belaval−Bruno on behalf of Defendant MOKA Shoe corporation.(Belaval−Bruno, Graciela) (Entered: 12/07/2006)
4 ORDER re 2 Notice (Other) filed by United States Equal Employment Opportunity Commission. NOTED. The Clerk of Court is to amend docket entries accordingly. Signed by Judge Aida M. Delgado−Colon on 12/20/2006. (wm, ) (Entered: 12/22/2006)
5 REPORT JOINT SCHEDULING REPORT by all parties. (Belaval−Bruno, Graciela) (Entered: 04/03/2007)
6 SCHEDULING ORDER/CASE MANAGEMENT ORDER. The attorneys for the parties are experienced litigators in federal court. Thus, the Court has examined and
favorably considered their joint proposed scheduling and approves the same. Joint Parties and Amend Pleadings by 9/3/2007. Expert Witness Reports by 11/19/2007. Rebuttal Expert Witness & Exchange reports by 12/14/2007. Discovery due by 1/30/2008. A Settlement Conference is set for 2/6/2008 at 10:00 AM in ADC's Chambers before Judge Aida M. Delgado−Colon. Dispositive Motions due by 3/5/2008; responses thereto 4/5/2008. Filing Joint Pretrial Memorandum by 4/20/2008. A Pretrial Conference is set for 8/19/2008 at 10:00 AM in ADC's Chambers before Judge Aida M. Delgado−Colon.Jury Trial is set for September 18 through September 19, 2008 at 09:00 AM in ADC's Courtroom before Judge Aida M. Delgado−Colon. Signed by
Judge Aida M. Delgado−Colon on 4/24/2007. (wm, ) (Entered: 04/24/2007)
7 MOTION for Extended Pretrial Deadlines filed byCarla J. Von Greiff on behalf of United States Equal Employment Opportunity Commission (Von Greiff, Carla) (Entered: 12/17/2007)
8 MOTION to Dismiss/Lack of Prosecution as to United States Equal Employment Opportunity Commission filed byGraciela J. Belaval−Bruno on behalf of MOKA Shoe corporation Suggestions in opposition/response due by 1/30/2008 (Attachments: # 1 Exhibit Exh. A, Letter dated December 7, 2006 with Exhibits A and B)(Belaval−Bruno, Graciela) (Entered: 01/14/2008)
9 ORDER TO SHOW CAUSE. The EEOC is to show cause, in writing and within the next 5 working days, as to why this case should not be dismissed. Failure to comply,
will lead to the dismissal of the case. Show Cause Response due by 1/22/2008. Signed by Judge Aida M. Delgado−Colon on 1/14/2008. (wm) (Entered:
01/15/2008)

Case: 3:06-cv-1976 As of: 05/28/2017 06:26 PM AST 3 of 4

01/22/2008 02/20/2008
07/01/2008 07/09/2008 07/29/2008 07/30/2008 08/05/2008 08/06/2008 08/20/2008 08/22/2008 08/22/2008

10 RESPONSE TO ORDER TO SHOW CAUSE and Response in Opposition to Defendant's Motion Requesting Dismissal filed by United States Equal Employment Opportunity Commission Re: 9 Order to Show Cause, 8 MOTION to Dismiss/Lack of Prosecution as to United States Equal Employment Opportunity Commission filed by MOKA Shoe corporation filed by United States Equal Employment Opportunity Commission. (Von Greiff, Carla) (Entered: 01/22/2008)
11 Minute Entry for proceedings held before Judge Aida M. Delgado−Colon. Settlement Conference held on 2/6/2008. Motion to Dismiss/Lack of Prosecution at Docket No. 8 is DENIED. Motion to Extend Pretrial Deadlines at Docket No. 7 is NOTED and
GRANTED. Pretrial schedule agreed upon remains as follows: Discovery due by 6/30/2008. Settlement Conference is set for 7/10/2008 at 9:30 AM in ADC's Chambers before Judge Aida M. Delgado−Colon. Dispositive Motions due by 8/6/2008. Responses thereto due by 9/5/2008. Filing Joint Pretrial Memorandum by 9/30/2008. Pretrial Conference is set for 10/30/2008 at 2:00 PM in ADC's Chambers before Judge Aida M. Delgado−Colon.Jury Trial is set for November 10 through November 14, 2008 at 9:00 AM in Courtroom 1 before Judge Aida M. Delgado−Colon. Signed by Judge Aida M. Delgado−Colon on 2/15/2008.
(wm) (Entered: 02/20/2008)
12 MOTION to Continue REQUESTING ADJOURNMENT OF SETTLEMENT CONFERENCE filed by Elizabeth M. Lizardi−Mendez on behalf of MOKA Shoe corporation (Attachments: # 1 Exhibit 1 − E−mail communication from Atty. Nora Curtin)(Lizardi−Mendez, Elizabeth) (Entered: 07/01/2008)
13 ORDER re 12 Motion to Continue Settlement Conference. GRANTED.
Settlement Conference is reset for 8/5/2008 at 5:00 PM in ADC's Chambers before Judge Aida M. Delgado−Colon. Signed by Judge Aida M. Delgado−Colon on 7/9/2008. (wm)
(Entered: 07/09/2008)
14 MOTION for Extension of Time until August 26, 2008 to file dispositive motions filed by Graciela J. Belaval−Bruno on behalf of MOKA Shoe corporation Suggestions in opposition/response due by 8/14/2008 (Belaval−Bruno, Graciela) (Entered: 07/29/2008)
15 ORDER granting 14 Motion for Extension of Time to File. Term to file dispositive motions is extended to 8/30/08. The EEOC is granted up to 8/10/08 to report the name of new counsel. Meanwhile it remains responsible for continuing to display good
efforts towards settlement. Attorney Appearance Deadline due by 8/10/2008. Motions due by 8/30/2008. Signed by
Judge Aida M. Delgado−Colon on 7/30/08. (sr) (Entered: 07/30/2008)
16 Minute Entry for proceedings held before Judge Aida M. Delgado−Colon: Settlement
Conference held on 8/5/2008. Parties met. Settlement was reached. Pretrial Conference set for 10/30/08 and Jury Trial set for November 10−14, 2008 are hereby vacated. (Court Reporter None.) Present: Attorney Nora Curtin
(plaintiff). Attorney Graciela Belaval(defendant) (sr) (Entered: 08/06/2008)
17 ORDER. Parties are granted until 8/20/08 to file necessary motions as to enable entry
of Judgment. Notice of Compliance Deadline due by 8/20/2008. Signed by
Judge Aida M. Delgado−Colon on 8/5/08.(sr) (Entered: 08/06/2008)
18 NOTICE of Filing of Consent Decree for Approval by United States Equal Employment Opportunity Commission (Attachments: # 1 Exhibit Consent Decree for Execution)(Von Greiff, Carla) (Entered: 08/20/2008)
19 CONSENT DECREE ORDER re 18 Notice (Other) filed by United States Equal Employment Opportunity Commission. Signed by Judge Aida M. Delgado−Colon on 8/21/2008.(wm) (Entered: 08/22/2008)
20 ORDER FOR ENTRY OF JUDGMENT. Signed by Judge Aida M. Delgado−Colon on 8/21/2008.)(wm) (Entered: 08/22/2008)

Case: 3:06-cv-1976 As of: 05/28/2017 06:26 PM AST 4 of 4 08/23/2008 21 JUDGMENT. Signed by Clerk on 8/23/08.(sr) (Entered: 08/23/2008)