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i IN THE UNITED STATES DISTRICT CbURT! ~.
FOR THE NORTHERN DISTRICT OF T~XAS AUG 3 0 2001

DALLAS DIVISION

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EQUAL EMPLOYMENT OPPORTUNITY )

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COMMISSION,

)

)

CIVIL ACTION NO.

Plaintiff,

)

)

v.

)

)

COMPLAINT

1
MINORITY OPPORTUNITY NEWS, INC. )

)

)

Defendant.

)

JURY TRIAL DEMAND

)

NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and to provide relief to Charging Party Jamila Thomas. The Commission alleges that Defendant Minority Opportunity News, Inc. (hereafter "Defendant"), violated Title VII when it demoted and discharged Jamila Thomas based upon her sex, female, and because of her pregnancy.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 US.C. §451, 1331,1337, 1343, 1345. This action is authorized and instituted pursuant to Section 706(1)(f) and (3) of the Civil Rights Act of 1964, as amended, ("Title VII"), 42 US.C §2000e-5(f) (1) and (3), and Section 102 of the Civil Rights Act of 1991,42 US.C. § 1981A.

2. The employment practices alleged to be unlawful were and are now being committed within the jurisdiction of the United States District Court for the Northern District of Texas.

PARTIES

3. Plaintiff, Equal Employment Opportunity Commission, (the "Commission"), is

an agency of the United States of America charged with the administration, interpretation and

enforcement of Title VII of the Civil Rights Act of 1964, as amended and is expressly authorized

to bring this action by Sections 706(f)(I) and (3) of Title VII, 42 U.S.C. §2000e-5(f)(I) and (3).

4. At all relevant times, Defendant has continuously been and is now doing business

in the State of Texas and the City of Dallas, and has continuously had at least fifteen

employees.

5. At all relevant times, Defendant has continuously been an employer engaged in an

industry affecting commerce under Sections 701(b), (g) and (h) of Title VII, 42 U.S.c. §2000e-

(b), (g) and (h).

STATEMENTS OF CLAIMS

6.

More than thirty days prior to the institution of this lawsuit, lamila Thomas filed

a charge with the Commission alleging violations of Title VII of the Civil Rights Act of 1964, as

amended, by the Defendant. All conditions precedent to the institution of this lawsuit have been

fulfilled.

7. Since at least lune 26,2000, the Defendant has engaged in unlawful

employment practices in violation of Section 703(a) (1) of Title VII, 42 U.S.c. §2000e-2(a)(I)

by demoting and discharging lamila Thomas because she was pregnant.

8.

The result of the foregoing practices has been to deprive lamila Thomas of equal

employment opportunities because of her sex and pregnancy. 9. The unlawful employment practices complained of in paragraph 7 above were
intentional. 10. The unlawful employment practices complained of in paragraph 7 above
were done with malice or with reckless indifference to the federally protected rights of lamila Thomas.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendant, its officers, successors, assigns, and all person in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of pregnancy. B. Order the Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for lamila Thomas and eradicate the effects of its past and present unlawful unemployment practices. C. Order the Defendant to make whole lamila Thomas by providing appropriate back pay with prejudgment interest in amounts to be determined at trial, front pay and pecuniary damages, including out-of-pocket expenses, and other affirmative relief necessary to eradicate the effects of the Defendant's unlawful employment practices, including but not limited to rightful place reinstatement under terms and conditions which will permit Ms. Thomas to work free from discrimination. D. Order the Defendant to make lamila Thomas whole by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including but not limited to, emotional pain, suffering,

inconvenience, mental anguish, and loss of enjoyment of life, in amounts to be detennined at trial.
E. Order the Defendant to pay lamila Thomas punitive damages for its malicious conduct or reckless indifference described in paragraphs 7 and 10 above, in an amount to be detennined at trial.
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. 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.

Respectfully submitted,
NICHOLAS M. INZEO Acting Deputy General Counsel
~~~1 !(J Ct>Qcj~~
TOBYW. COSTAS Acting Regional Attorney Texas State Bar No. 04855720
DEVIKA S. D BEY Senior Trial Attorney Hawaii State Bar No. 005599
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 Houston, 3rd Floor Dallas, Texas 75202 (214) 655-3338 (telephone) (214) 655-3331 (facsimile)

 
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DALLAS DIVISION

,

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CLEl~ ,U.S. STRICT COURT

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EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

CIVIL ACTION NO.

)

3-OlCVl712-R

Plaintiff,

)

)

v.

)

}

MINORITY OPPORTUNITY NEWS,

)

)

)

Defendant.

)

)

STIPULATION OF DISMISSAL
Now comes the Plaintiff, Equal Employment Opportunity Commission (EEOC), and the
Defendant, Minority Opportunity News (Defendant) pursuant to Federal Rule of Civil Procedure
41 and stipulate to the dismissal of the above-entitled lawsuit. Defendant further stipulates to
having been received notice of the filing of the lawsuit in compliance with the Federal Rules.
Each party agrees to bear its own costs and attorneys fees.
Respectfully submitted,
FOR PLAINTIFF:
lffilhtd-
SUZANNE M. ANDERSON Acting Regional Attorney Texas State Bar No.
TOBY W. COSTAS Supervisory Trial Attorney Texas State Bar No. 04855720

( f "
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DEVIKA S. DUBEY Senior Trial Attorney Hawaii State Bar No. 005599
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 Houston, 3rd Floor Dallas, Texas 75202 (214) 655-3358 (telephone) (214) 655-3331 (facsimile)
FOR DEFENDANT:
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1825 Market Center Blvd. Suite 430 Dallas, Texas 75207 ~/¥-67F-S9t7cJ
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SY3I1~. /99/~5(J (J

 
 District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?215895090679995-L_3...

CLOSED, JURY, KAPLAN
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:01-cv-01712

Equal Employment Opp v. Minority Opp News Assigned to: Judge Jerry Buchmeyer Demand: $0 Cause: 42:2000 Job Discrimination (Sex)
Plaintiff Equal Employment Opportunity Commission

Date Filed: 08/30/2001 Date Terminated: 01/08/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Toby W Costas Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2760 Fax: 214/253-2749 FAX Email: toby.costas@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Devika S Dubey Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2764 Fax: 214/253-2749 FAX Email: devika.dubey@eeoc.gov

V. Defendant Minority Opportunity News, Inc

Date Filed 08/30/2001

#

Docket Text

1 COMPLAINT filed; Government, no fee paid (5) (vdf) (Entered: 08/31/2001)

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District Version 3.0.3 - Docket Report

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08/30/2001 08/30/2001 08/30/2001 01/08/2002
01/08/2002 01/08/2002

1 DEMAND for jury trial by plaintiff Equal Employment Opp (vdf) (Entered: 08/31/2001)
PRELIMINARY ASSIGNMENT TO Magistrate Judge Jeff Kaplan (vdf) (Entered: 08/31/2001)
2 SUMMONS(ES) issued for defendant Minority Opp News (Issued-1) (vdf) (Entered: 08/31/2001)
3 RETURN OF SERVICE executed as to defendant Minority Opp News on 12/28/01 via personal service. Answer due on 1/17/02 for Minority Opp News. (1) (jaw) (Entered: 01/09/2002)
4 STIPULATION of dismissal. (2) (jaw) (Entered: 01/09/2002)
Case closed (jaw) (Entered: 01/14/2002)

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