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

U.S, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

CaseNo. 08~008.

UNITED AIR LINES, INC. d/b/a UNITED AIRLINES,

JURY TRIAL DEMANDED

Defendant.

NATURE OF THE ACTION

FEB 0 3 2003

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

"ADA"), 42 U.S.C. § 12101 et seo~,, 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

Joanne Plurad ("Plurad"), who was adversely affected by such practices. The Commission alleges that Defendant United Airlines, Ihe. d/b/a United Airlines ("Defendant") discriminated

and retaliated against Plurad in that it failed to provide a reasonable accommodation to Plurad.

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

and 1345. This action is authorized and instituted pursuant to Section 107(a) of the ADA, 42

U.S.C. § 12117(a), which incorporates by reference Section 706(0(1) and (3) of Title VII of the

Civil Rights Act of 1964 ("Title VII"), 42 U.S.C. § 2000e-5(f)(l) and (3), and pursuant to

Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981A.

2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court in the Northern District of Illinois, Eastern Division.
PARTIES 3. PlaintiffU.S. Equal Employment Opporttmity Commission (the "Commission"), is an agency of the United States of America charged with the administration, interpretation and enforcement of Title I 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)and (3) of Title VII, 42 U.S.C. § 2000e-5(0(1) and (3). 4. At all relevant times Defendant United Airlines Inc. d/b/a United Airlines ("Defendant") has been and is now an Illinois corporation doing business in the State of Illinois and has continuously had and does now have at least fifteen (15) employees. 5.. At all relevant times, Defendant has continuously been an employer engaged in an industry affecting commerce under Section 10(5) of the ADA, 42 U.S.C. § 12111(5), and Section 101 (7) of the ADA, 42 U.S.C. § 12111 (7), which incorporates by reference Sections 701 (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(g) and (h). 6. At all relevant times, Defendant has been a covered entity under Section 101 (2) of the ADA, 42 U.S.C. § 12111(2).
STATEMENT OF CLAIM~ ¯ More than thirty (30) days prior to the institution of this lawsuit, Joanne Plurad filed a charge with the Commission alleging violations of Title I of the ADA by Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled.

8. Since at least March 1996 Defendant has engaged in unlawful employment practices at its Chicago O’Hare facility in violation of Sections 102(a), 102(b)(1) and 102(b)(6) of the ADA, 42 U.S.C. §§ 12112(a), 12112(b)(1) and 12112(b)(5). These practices include Defendant’s failure to provide Plurad with a reasonable accommodation, and Defendant’s retaliation against Plurad for having complained about the discriminatory treatment by placing her on unpaid involuntary sick leave.
9. The effect of the practices complained of has been to deprive Plurad of equal employment opportunities and otherwise adversely affect her employment status on the basis of her disability.
10. The unlawful employment practices complained of above were intentional. 1 l. Defendant, at all relevant times, has acted with malice or reckless indifference to the federally protected rights of Plurad.
pRAYeR FOR RELIEF WHEREFORE, the Commission respectfully prays that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, management personnel, .employees, agents, successors, assigns and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of disability; and from retaliation against any person because that person has, in good faith, opposed discriminatory policies or practices, has filed a charge with the EEOC, or because of the person’s participation in, or cooperation with, the initiation, investigation, and/or litigation of this

B. Order Defendant to institute and carry out policies, practices and programs which provide equal employment opportunities to qualified individuals with disabilities, and which eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant to make whole Joarme Plurad, by providing back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices.
D. Order Defendant to make whole Joarme Plurad, by providing compensation for pecuniary losses resulting from the unlawful employment practices described in paragraph 8, above, in amounts to be proved at trial.
E. Order Defendant to make whole Joarme Plurad, by providing compensation for nonpecuniary losses resulting from the unlawful practices complained of in paragraph 8 above, including pain, suffering, emotional distress, inconvenience and mental anguish, in amounts to be proved at trial.
F. Order Defendant to pay Joanne Plurad, punitive damages for its malicious and reckless conduct, as described in paragraph 8, in amounts to be proved at trial.
G. Grant such further relief as the Court deems necessary and proper. H. Grant the Commission its costs in this action.
JURY TRIAL DEMANDED The Commission requests a jury trial on all questions of fact raised by the Complaint.

Respectfully submitted, NICHOLAS INZEO Acting Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel U.S. Equal Employment
Opporttmity Commission
J
! Attot’l :y
Supervisory Trial Attomey
fjunetW~alla~ calhoun r T~ Attorney U.S. Equal Employment
Opportunity Commission Cl’ficago District Office 500 West Madison Street Suite 2800 Chicago, Illinois 60661 (3 t2) 353-7259

Civil Cover Sheet

http ://w~d.uscourts.gov/PUBLIC/Forms/aulo_j s44,cfra

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS
Civil Cover Sheet
This automated JS-44 conforms generally to th~ manual JS-44 approwd by the Judicial Confercnc~ of the United September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating th¢ civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is authorized for use ~ in the Northern Dislrict of Illinois.

Plaintiff(s): U.S. EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

Defendant(s):UNITEDuNITED AIRLINES AIR LINES, INC, ~¢~’~K~0

County of Residence:

County of Residence: COOK

f ~ 0 S 2003

Plaintiffs Atty: June Wallace Calhoun Equal Employment

Defendant’s Atty:

Opportunity Commission

.500 W. Madison St, Suite 2800

Chicago, IL 60661

(312) 353-7259

Kim Dawsonia
United Airlines - WHQHR 1200 East Algonquin Road ElkGrove Village, IL 60007 (847)700-5881

|

II. Basis of Jurisdiction: 1. U.S. Gov’t Plaintiff

HI. Citizenship of Principal Parties (Diversity Cases Only)
Plaintiff:- N/A Defendant:- NIA

oaco0s
JUDGE JOHN W DARRAH

rv. o gta ¯

1. Original Proceeding

MAGISTRATE JUDGI~

V. Nature of Suit:

442 Employment

VI.Cause of Action:

Title I of Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.C. § 12101 et seq., and Title I of the Civil Rights Act of 1991, 42

U.S.C. § 1981a, to correct the unlawful employment practices on the

basis of disability.

VII. Requested in Complaint

Class Action:

Dollar Demand:

Jury Demand: Yes

VIII. This case IS NOT a refiling of a previously dismissed case.

! of 2

2/4/03 10:58 AM

~RITED STATES DISTRICT COf~IT THERN DISTRICT OF ILLINOIS
In the Matter of
U.S. Equal Employment Opportunity Commission, Plaintiff,

°°

0

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEY(S) FOR:

Plaintiff, U.S. EQUAL E1V[PLOYMENT OPPORTUNITY COMMISSION IUDGE JOHN W. DAR

i)OCKETED .......

Wallace Calhoun Equal Employment Opportunity Commission S~E~,OO~SS 500 W. Madison St., Suite 2800. CtrWSTAW-~Za’ Chicago, IL 60661

ra~2ao~ ~m~312-353-7259

i~mr~c~oN ~meR (s~ 1Tin, os ~vEue)USDC No. 06202058

~O~T~,L~,

~ X so

~AmNoelle C. Brerman Ft~ Equal Employment Opportunity Commission Sr~Er~Dr~SS ^ODmSS500 W. Madison St.~ Suite 2800

Chicago, IL 60661 TELEPHONE nUmu312-353-7582
IDENTIFICATION NUMBER ISE1~ ITEM 40/4 I~VE, R~E) ARDC No. 06228901

~ OF TRIA~ BAIt? TIUALATTORNEY~

~

NO

X

~

X

NO

DESIGNATED AS LOCAL COUNSEL?

$IGNATURI~

(V)

NAME

FIRM

W. Madison St.~ Suite 2800 CI~,~rA-mZt~ Chicago, IL 60661

STREET ADDRESS CITY~STATF~ZI~

~,~L~Or~ ~ ~312 - 353- 8551

TELEPHONE NUMBER

~rnr~c~r~or~ ~E~ (s~ rre~, ON ~VmmARDC No. 01187589 /DENTIFICAT/ON NUMBER (SEE ITEM 4 ON RliVERSE)

"mMBF.R OE TRIAL BAR?

Y’~ X

NO

[]

MEMBER OF TRIAL I~AR?

YF~q

[]

rl~ A’rrORN’EY? DESIGNATED AS LOCAL COUNSEL?

Yr~ X
YES []

NO

[]

NO []

TRIAL ATTORNEYV DESIGNATED AS LOCAL COUNSEL9

YES

[]

YES

[]

NO [] NO []~ NO I~~

 
 ;~inutc Ord",~Form (06197)

United States District Court, Northern District of lIIinois

Name of Assigned Judge or Magistrate Judge

John W, Darrah

Sitting Judge if Other than Assigned Judge

CASE NUMBER

03 C 812

DATE

4/14/2004

CASE TITLE
MOTION:

EEOC VS, United Air Lines, Inc,
(In the followmg box (a) mdlcate the party filmg the motIon, e.g., plamlJff, defendant, 3rd party plamtlff, and (b) state briefly the nature of the motion being presented.]

DOCKET ENTRY:

(1)

0

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

(2)

0

Brief in support of motion due ___'

(3)

0

Answer brief to motion duc_ _ _ , Rcply to answcr brief duc_ _ _,

(4)

0

RulinglHearing on ___ set for ___ at ___'

(5)

0

Status hearing[heldlcontinued to] [set for/re-set for] on ___ set for ___ at _ _ _'

(6)

0

Pretrial conference[heldlcontinued to] [set forlre-set for] on ___ set for _ _ _ at _ _ _'

(7)

0

Trial[set forlre-set for] on _ _ _ at ___'

(8)

0

[Bench/Jury trial] [Hearing] heldlcontinued to ___ at ___'

(9)

0

• (10)

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 Local Rule 41.1 0 FRCP41(a)(I) 0 FRCP41(a)(2),
[Other docket entry] Joint motion for entry of consent decree is granted, Enter Consent Decree,

(11) o

[For further detail see order (on reverse side of/attached to) the original minute ordeL]

-
--;-

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.

nllmbcrofllOliccs
APR 152004
dale docketed
dockcting depuly inilials

courtroom

"-
~-'!

.(' "(,

! :

MF

deputy's

initials

Date/time received in central Clerk's Office

dale mailed nOlicc mailing depuly inilials

" ",~,;)tQ,c:uin:ent Numb.er.
\ \

" ..

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

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

UNITED AIR LINES, INC., d/b/a UNITED )

AIRLINES,

)

)

Defendant

)

--------~~~-----------

Case No. 03 C 0812 Judge Darrah
DOCKETED

CONSENT DECREE

APR 1 5 2004

THE LITIGATION

Plaintiff Equal Employment Opportunity Commission ("EEOC") filed this action

alleging that Defendant United Airlines, Inc. ("United Airlines" or "Defendant") violated Title I

of the Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.C. § 12101 et seq. The

EEOC seeks relieffor Joanne Plurad ("Ms. Plurad" or the "Charging Party"), who filed a charge

of discrimination.

In the interest of resolving this matter, and as a result of comprehensive settlement

negotiations, the parties have agreed that this action should be finally resolved by entry of this

Consent Decree. This Consent Decree fully and finally resolves any and all issues and claims

arising out of the Charge of Discrimination filed by Ms. Plurad (EEOC Charge No. 21OAIlO64)

and the Complaint filed by the EEOC in this action.

On December 9, 2002, United Airlines and several affiliated companies (UAL

CORPORATION, et al.) (the "Debtors") filed petitions for relief pursuant to Chapter 11 of

Title II of the United States Code (the "Bankruptcy Code"). These cases are being jointly

CHI 10635501.2
I

administered under Case No. 02-48191 through 02-48218 before the Honorable Judge Eugene R. Wedoffin the Bankruptcy Court in the Northern District ofIJIinois (the "Bankruptcy Case").
FINDINGS Having carefuJly examined the terms and provisions of this Decree, and based on the pleadings, records and stipulations of the parties, the Court finds the following: A. This Court has jurisdiction of the subject matter of this action and of the parties. B. The terms of this Decree are adequate, fair and reasonable. The rights of the parties and the public interest are adequately protected by this Decree. C. This Decree conforms with the Federal Rules of Civil Procedure and the ADA and is not in derogation of the rights or privileges of any person. The entry of this Decree will further the objectives ofthe ADA and will be in the best interests of the parties, the Charging Party, and the public. NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:
DURATION OF DECREE AND RETENTION OF JURISDICTION 1. Unless otherwise noted, all provisions of this Decree shall be in effect (and the Court shall retain jurisdiction of this matter to enforce this Decree) for a period of two (2) years from the date the Court enters the Decree (hereinafter the "effective date"), provided, however, that if, at the end of the two (2) year period, any disputes under Paragraph 12 below remain unresolved, the term of the Decree shall be automatically extended (and the Court will retain jurisdiction of this matter) solely for the purpose of resolving all such disputes and the term shall terminate after all disputes have been resolved.
INJUNCTION AGAINST DISABILITY DISCRIMINATION 2. For a period of two (2) years following the effective date of this Decree, United Airlines and its officers, agents, management (including supervisory employees), successors,
2
CHI 10635501.2

--
assigns, and all persons acting in concert with them shall not: (i) discriminate against United Airlines employees/applicants for employment with the Chicago O'Hare Airport Operations Division on the basis of their disability related to mUltiple sclerosis or diabetes; or (ii) fail to make a reasonable accommodation for any qualified employee or qualified employee/applicant with the Chicago O'Hare Airport Operations Division, with a disability related to diabetes or multiple sclerosis, in violation of the ADA. Chicago O'Hare Airport Operations Division includes employees in Ramp Service, Cabin Service and Customer Service Representatives at the Chicago O'Hare facility.
United Airlines' obligations under this injunction are no greater than those required under the ADA or any other comparable state or local law, or ordinance prohibiting disability discrimination.
The EEOC's ability to seek a contempt order under this Paragraph shall be no greater than its statutory rights conferred by the ADA and/or Title VII, nor shall it relieve the EEOC of its statutory obligations under the enforcement provisions of the ADA or Title VII.
EFFECT OF DECREE 3. This Consent Decree shall not constitute an admission by any party as to the claims or defenses of another party.
SETTLEMENT OF CLAIMS 4. Ms. Plurad will be allowed a noncontingent, general, unsecured prepetition claim in the gross amount of $200,000.00 on account of any damages arising out ofthis action (less applicable withholding for the employee's share of federal, state and local taxes and other applicable deductions as required by law). United Airlines will direct its official Notice and Claims Agent to docket a noncontingent, liquidated, undisputed, general unsecured prepetition claim in the amount of $200,000.00 in favor of Ms. Plurad and to expunge Ms. Plurad's Proof of
3
CHI 10635501.2

-
Claim and the EEOC's Proof of Claim filed on Ms. Plurad's behalf (identified in the Bankruptcy Case as Claims No. 37501 and No. 37311), as well as any other Proof of Claims filed by Ms. Plurad or on Ms. Plurad's behalf. Ms. Plurad and the EEOC acknowledge that any distribution on account of such claim will be made only pursuant to a confirmed plan of reorganization in the Bankruptcy Case. Such claim shall not enjoy any type of statutory or administrative priority over any other general, unsecured, prepetition claim in the Bankruptcy Case.
5. The Debtors shall duly file a motion (the "9019 Motion") with the Bankruptcy Court pursuant to Federal Rule of Bankruptcy Procedure 9019 for approval of this Consent Decree. In the absence of any objection filed and served within twenty (20) days after the filing of the 9019 Motion, the Debtors will submit a Certificate of No Objection so that the Bankruptcy Court may enter the order (the "9019 Order") approving the 9019 Motion. After the Bankruptcy Court enters the 9019 Order, the Debtors may execute and consummate the Consent Decree, and said Consent Decree will be binding on them and their estate without any further action by the Bankruptcy Court. If an objection is raised within the 20-day notice period and ultimately is resolved in the Debtors' favor, the Consent Decree will become effective upon entry of a court order denying the objection. If an objection is raised within the 20-day notice period and ultimately is resolved in favor of the objector, the Consent Decree shall be deemed to have been void ab initio.
EMPLOYMENT STATUS OF MS. PLURAD 6. United Airlines agrees to keep Ms. Plurad on Extended Illness Status until May 28, 2006 at which time she will be eligible to retire under Section 11.17.2 of the Collective Bargaining Agreement. Ms. Plurad agrees that she will retire at that time.
4
CHI 10635501.2

POSTING OF NOTICE 7. Within ten (10) business days after the effective date of this Decree, United Airlines shall post copies of the Notice attached as Exhibit B to this Decree on the bulletin boards at its Chicago O'Hare facility, which are usually used by United Airlines for conununicating with United Airlines O'Hare Airport Operations employees. The Notice shall remain posted for two (2) years from the effective date of this Decree. United Airlines shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other material. United Airlines shall certify to the EEOC in writing within ten (10) business days after entry of the Decree that the Notice has been properly posted. United Airlines shall pennit a representative ofthe EEOC to enter United Airlines' premises for purpose of verifying compliance with this Paragraph at any time during normal business hours without prior notice.
RECORD KEEPING 8. For a period of two (2) years from the effective date of this Decree, United Airlines shall maintain all records concerning its implementation of this Consent Decree. United Airlines shall also maintain records of complaints of disability discrimination and failure to accommodate from employees or applicants for employment with Chicago O'Hare Airport Operations, made to Personnel Administrative Supervisors, Human Resources with responsibility for O'Hare Airport Operations, the Legal Department, United's toll-free Business Conduct Line, and to Corporate Diversity. The records shall include United Airlines' investigation of such complaints and any response or action taken as a result of the complaints.
REPORTING 9. United Airlines shall furnish to the EEOC the following written reports every six (6) months for a period of two (2) years following the effective date of the Decree. The first
5
CHI 10635501.2

report shall be due six (6) months after effective date of the Decree. Each such report shall contain:
a. A summary of the information recorded by United Airlines pursuant to Paragraph 8;
b. A certification by United Airlines that the Notice required to be posted pursuant to Paragraph 7 remained posted during the entire six (6) month period preceding the report;
c. A certification that United Airlines' Chicago O'Hare Airport employees have received the training required pursuant to Paragraph 11, a list of the employee job classifications that have received such training, and the dates on which they received such training.
DISTRIBUTION OF POLICY AGAINST DISABILITY DISCRIMINATION
ro. United Airlines will redistribute its policy against disability discrimination, in the
marmer it normally distributes its personnel policies, within thirty (30) days of entry of this Decree. The policy shall, at a minimum:
a. Specifically prohibit discrimination on the basis of disability against United Airlines employees and applicants for employment.
b. Provide that employees are entitled to a reasonable accommodation of their qualifying disability in accordance with the terms of the ADA.
c. Provide that complaints of disability discrimination will be investigated thoroughly and promptly.
6
CHI 10635501.2

-.'
d. Provide that United Airlines employees who violate the policy with respect to qualifying employees and applicants for employment are subject to discipline up to and including discharge.
TRAINING 11. All United Airlines supervisors and managers at the Chicago O'Hare facility working in Airport Operations, including Human Resources personnel, shall participate in a training session by a United in-house or outside attorney, or a trainer paid for by United Airlines regarding the requirements of the ADA. United Airlines shall submit to EEOC the materials used in, relied upon or distributed in the training session, forty-five (45) days prior to such training. EEOC will respond to United Airlines, in writing, within ten (10) days of receipt of the training materials. The training shall begin within sixty (60) days of effective date of this Decree and shall be completed within twelve (12) months of the effective date of this Decree. United Airlines' policy, as referenced in Paragraph 10, shall be distributed at the training session(s).
DISPUTE RESOLUTION 12. In the event that either party to this Decree believes, in good faith, that the other party has failed to comply with any provision(s) of the Decree, the complaining party shall notify the other party of the alleged non-compliance and shall afford the alleged non-complying party (10) business days to remedy the non-compliance or to satisfy the complaining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged non-compliance or satisfied the complaining party that it has complied within ten (10) business days, the complaining party may apply to the Court for appropriate relief.
MISCELLANEOUS PROVISIONS 13. Each party to this Decree shall bear its own expenses and costs. The EEOC and United Airlines shall bear their own attorney's fees.
7
CHI 10635501.2

;
14. The tenns of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns, and successors of all parties.
1S. When this Consent Decree requires the submission by United Airlines of reports, certifications, notices, or other materials to the EEOC, they shall be mailed to: United Airlines ADA I Settlement, Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661. When this Decree requires submission by the EEOC of materials to United Airlines, they shall be mailed to: Vania Montero Wit, United Airlines, WHQLD, 1200 East Algonquin Road, Elk Grove Village, Illinois 60007.
16. In the event of a catastrophic event, United Airlines may petition the Court for relief from or suspension of the Consent Decree.
8
CH I 10635501.2

~ ..
ENTERED AND APPROVED FOR: Equal Employment Opportunity Commission
ERIC S, DREIBAND General Counsel
JAMES LEE Deputy General Counsel

United Airlines, Inc.

_____--,'ane Smason Supervisory Trial Attorney
G464111 It ·1Jt~--/if2/-ozPamela S. Mo'()f:GibbS Trial Attorney
Equal Employment Opportunity Commission
Chicago District Office 500 West Madison Street Suite 2800 Chicago, Illinois 60661 (312) 886-9120

ENTER: ----.f~~.c:::".--i)~~&:'."'-""-­
orable John W, Darrah

9
CHI 1063550L2

EXHIBITB
NOTICE TO ALL UNITED AIRLINES EMPLOYEES
This Notice is being posted pursuant to a Consent Decree entered by the federal court in EEOC v. United Airlines, Inc., Case No. 03 C 0812, resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against United Airlines. In its suit, the EEOC alleged that United Airlines discriminated against an employee on the basis of her disability.
To resolve the case, United Airlines and the EEOC have entered into a Consent Decree which provides, among other things, that: 1) United Airlines will provide a claim for monetary damages to the United Airlines employee; 2) United Airlines will not discriminate against any employee on the basis of disability which is the result of either diabetes or multiple sclerosis; or fail to make a reasonable accommodation for any qualified employee or qualified applicant in O'Hare Airport Operations with a disability, which is the result of either diabetes or multiple sclerosis, in violation of the ADA; and 3) United Airlines will comply with various reporting and record keeping requirements for two (2) years.
The EEOC enforces the federal laws against discrimination in employment on the basis of race, color, religion, national origin, sex, age or disability. If you believe you have been discriminated against, you may follow the complaint procedure in United Airlines' non-discrimination and anti-harassment policy and you may contact the EEOC at (312) 353-2713. The EEOC charges no fees and has a TID number.
TIllS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
This Notice must remain posted for two years from the date below and must not be altered, defaced of covered by any other material. Any questions about this Notice or compliance with its terms may be directed to: United Airlines Settlement, EEOC, 500 West Madison
Street, Suite 2800, Chicago, IL 606, \ ~
Date
CHI 10635501.2

 
 CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?823661980992692-L_35...
LEVIN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:03-cv-00812

EEOC v. United Air Lines Inc Assigned to: Hon. John W. Darrah Demand: $0 Cause: 42:12101 Americans with Disabilities Act

Date Filed: 02/04/2003 Date Terminated: 05/26/2004 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by 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 LEAD ATTORNEY ATTORNEY TO BE NOTICED

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 ATTORNEY TO BE NOTICED

Noelle Christine Brennan Brennan & Monte, Ltd. 20 South Clark Street Suite 1530 Chicago, IL 60603 (312) 422-0001 Email: nbrennan@brennan-monte.com TERMINATED: 12/04/2003

V. Defendant

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United Air Lines Inc doing business as United Airlines

represented by Gary S. Kaplan Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 346-8000 Fax: 312-269-8869 Email: gkaplan@seyfarth.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Beth Golub Joffe Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 460-5000 Email: bjoffe@seyfarth.com ATTORNEY TO BE NOTICED
Stephanie Joan Pulcanio Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312)346-8000 Email: spulcanio@seyfarth.com ATTORNEY TO BE NOTICED

Date Filed 02/04/2003
02/14/2003 02/20/2003 02/21/2003 03/31/2003 04/03/2003

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of June Wallace Calhoun, Noelle Christine Brennan, John C. Hendrickson as attorney(s) for plaintiff (No summons(es) issued.) (Documents: 1-1 through 1-3) (hp) (Entered: 02/05/2003)
2 ATTORNEY APPEARANCE for defendant by Gary S. Kaplan, Beth Tracey Golub, Stephanie Joan Pulcanio (yap) (Entered: 02/18/2003)
SCHEDULE set on 2/20/03 by Hon. John W. Darrah : Status hearing set to 9:00 4/8/03 . Mailed notice (wah) (Entered: 02/20/2003)
3 WAIVER of service of summons as to defendant United Air Lines Inc sent on 2/4/03 (rmm) (Entered: 02/24/2003)
4 ANSWER by United Air Lines Inc and affirmative defenses to plaintiff's complaint [1-1] (ar) (Entered: 04/01/2003)
5 JOINT report of parties' Rule 26(F) planning meeting by plaintiff and defendant; Notice (ar) (Entered: 04/04/2003)

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04/08/2003 05/27/2003 06/04/2003
07/03/2003 09/10/2003 10/09/2003
12/03/2003 12/04/2003 04/01/2004 04/14/2004 05/26/2004

SCHEDULE set on 4/8/03 by Hon. John W. Darrah : Status hearing held. Discovery ordered closed on 10/15/03 . Pretrial conference set to 1:00 2/18/04. Jury trial set to 10:00 3/22/04 . Mailed notice (ldg) (Entered: 04/08/2003)
6 MOTION by defendant for protective order and for settlement conference ; Notice (ar) (Entered: 06/06/2003)
7 MINUTE ORDER of 6/4/03 by Hon. John W. Darrah : Defendant's motion for protective order and settlement conference is granted in part and denied in part [6-1] [6-2]. Motion for protective order staying all discovery is granted. Motion for settlement conference is denied. Status hearing is set for 9:00 a.m. on 07/03/03. Mailed notice (ar) (Entered: 06/06/2003)
SCHEDULE set on 7/3/03 by Hon. John W. Darrah : Status hearing held and continued to 9:00 9/10/03 . Mailed notice (ldg) (Entered: 07/03/2003)
SCHEDULE set on 9/10/03 by Hon. John W. Darrah : Status hearing held and continued to 9:00 10/9/03 . Mailed notice (ldg) (Entered: 09/10/2003)
SCHEDULE set on 10/9/03 by Hon. John W. Darrah : Status hearing held. Discovery extended to 2/6/04. Pretrial conference set for 2/18/04 is stricken and re-set to 6/2/04 at 3:00 p.m. Jury trial set for 3/22/04 is stricken and re-set to 8/9/04 at 10:00 a.m. Mailed notice (maf) (Entered: 10/09/2003)
8 WITHDRAWAL by plaintiff EEOC of appearance of Noelle C. Brennan; Notice (ar) (Entered: 12/04/2003)
9 MINUTE ORDER of 12/4/03 by Hon. John W. Darrah : Attorney Noelle Brennan is granted leave to withdraw her appearance on behalf of plaintiff [8-1]. Mailed notice (ar) (Entered: 12/04/2003)
10 JOINT MOTION by plaintiff for entry of consent decree ; Notice. (gma) (Entered: 04/15/2004)
11 MINUTE ORDER of 4/14/04 by Hon. John W. Darrah: Joint motion for entry of consent decree is granted [10-1]. (Entered Consent Decree) Mailed notice (gma) (Entered: 04/15/2004)
12 MINUTE ORDER of 5/26/04 by Hon. John W. Darrah: Parties having entered a consent decree on 4/14/04, the pretrial conference of 6/2/04 and jury trial of 8/9/04 are vacated. Terminating case. Mailed notice (gma) (Entered: 05/27/2004)

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