1 A. LUIS LUCERO, JR. Regional Attorney
2 BARBARA J. STANDAL Supervisory Trial Attorney
3 JOHN STANLEY Senior Trial Attorney
4 EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 5 909 First Avenue, Suite 400
Seattle, WA 98104 (206) 220-6892 6

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8

UNITED STATES DISTRICT COURT

9

FOR THE DISTRICT OF OREGON

10

11 EQUAL EMPLOYMENT OPPORTUNITY
12 COMMISSION,

l3

Plaintiff,

14

and

15 INTERNATIONAL LINE BUILDERS, INC.

16 Defendant.
17

) ) CASE NO. 00-3105-CO ) ) CONSENT DECREE AND ORDER ) DISMISSING ACTION ) ) ) ) ) ) )

18

I. INTRODUCTION

19

1. This action originated with a charge of discrimination filed with the plaintiff,

20 Equal Employment Opportunity Commission ("EEOC" or "Commission"), on March 28, 2000,

21 by Susan Baldwin. The charge alleged sexual harassment and sex discrimination and that the

22 defendant, International Line Builders, Inc. ("ILB") failed to rehire Baldwin in retaliation for her

23 complaints of discrimination, in violation of Title VII ofthe Civil Rights, 42 U.S.C. §2000e et

24 seq. ("Title VII"). A copy of the charge is attached to this consent decree as Exhibit 1.

25

2. The EEOC sent the defendant a Letter of Determination on August 8, 2000,

CONSENT DECREE - PAGE 1

u.s. EaUAL EMPLOYMENT OPPORTUNITY COMMISSION
Seattle District Office
909 First Avenue, Suite 400 Seattle, Washington 98104·1061
Telephone: (206) 220·6883 Foc::;imilo: (206) 220 6911 TOO: (206) 220·6882

with a finding there was reasonable cause to believe that Baldwin's allegations were true and that

2 it had violated Title VII. A copy of the Letter of Determination is attached as Exhibit 2.

3

3.

The Commission filed this lawsuit on September 28, 2000, in the United States

4 District Court for the District of Oregon.

5

4.

The parties want to conclude the claims arising out of Baldwin's charge, the

6 EEOC's determination, and this action without expending further resources in contested

7 litigation.

8

II. NONADMISSION OF LIABILITY AND

NONDETERMINATION BY THE COURT

9

5.

This consent decree is not an adjudication Or finding on the merits of this case

10 and shall not be construed as an admission by the defendant of a violation of Title VII.

11 III. SETTLEMENT SCOPE

12

6.

This consent decree is the final and complete resolution of all allegations of

13 unlawful employment practices contained in Susan Baldwin's discrimination charge, in the

14 EEOC's Letter of Determination, and in the complaint filed in this action, including all claims by

15
the parties for attorney fees and costs. The injunctive relief provisions of this consent decree

16

apply to all ILB facilities in the state of Oregon.
17 IV. MONETARY RELIEF

18

7.

In settlement of this suit, the defendant agrees to pay Susan Baldwin $52,000

19 in equitable and compensatory damages as designated in this paragraph, less applicable

20 withholding required by law, in settlement and satisfaction of all claims for monetary relief in

21
this action. This amount shall be designated as $32,000 in lost wages and $20,000 in

22 compensatory damages. Defendant agrees to mail two checks, in the amounts indicated, to

23 Baldwin within 10 days of the entry of this consent decree by the court. In return, Baldwin will

24 release defendant from all claims arising out of this lawsuit. A copy of the release is attached as

25

CONSENT DECREE - PAGE 2

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
909 First Avenue, Suite 400
Seattle, Washington 98104·1061 Telephone: (206) 220·6883 F"'r.~imiIA: /2061 220-6911 TOO: (206) 220·6882

Exhibit 3.
2

3

V. INJUNCTIVE RELIEF

4

A. General Provisions

5

8. The defendant reaffirms its commitment to comply with the provisions of Title

6 VII and all other federal laws against discrimination in its employment decisions. To further this

7 commitment, it will monitor the affirmative obligations of this consent decree.

8

9. The defendant will not retaliate against any current or former employee for

9 opposing any practice made unlawful by Title VII. Nor will the defendant retaliate against any

10 current or former employee for making a charge or for testifying, assisting, or participating in

11 any investigation, proceeding, or hearing associated with this action.

12

10. In recognition of its obligations under Title VII, the defendant will institute the

13 policies and practices set forth below.

14

B. Establishment of Policy and Procedures to Prevent Discrimination

15

11. ILB will implement an effective written equal employment opportunity policy

16 which sets forth the requirements of federal laws against employment discrimination and

17 specifically those provisions which make sexual harassment and retaliation unlawful.

18

12. The policy will include a statement of defendant's commitment to ensuring that

19 the practices and the conduct of its employees will comply with the requirements of federal laws

20 against ~mploym~nt discrimination. It will includ~ a provision stating that those who violate the

21 policy will be subject to appropriate discipline, up to and including termination.

22

13. The policy will include an internal complaint procedure for employees to

23 report suspected incidents of discrimination so that the defendant can investigate and take

24 appropriate action if it determines that any employee has violated its EEO policy.

25

14. The internal complaint procedure will include the following provisions:

CONSENT DECREE - PAGE 3

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Seattle District Office
909 First Avenue, Suite 400 Seattle, Washington 98104-1061
Telephone: (206) 220-6883 Facsimile: (.206) 220-6911 TOO: (206) 220-6882

a.

A list of the appropriate persons to whom an individual should report

2

allegations of discrimination in the workplace, including those that are

3

unlawful under Title VII.

4

b.

An explanation of how to make a complaint and what an investigation

5

will involve, including informing the affected individuals of the outcome of the

6

investigation.

7

15. The defendant will submit a copy of its policy for the EEOC's review and

8 approval within forty-five days of the date of entry of this decree. Within 30 days of the date of

9 approval by thc EEOC, the defendant will redistribute the policy to all present and future

10 employees, both management and non-management.

11

C. Posting Notice

12

16. The defendant will post the notice attached as Exhibit 4 to this consent decree.

13 The notice shall be posted on a centrally located bulletin board at all ILB facilities in the state of

14 Oregon where notices to employees are normally posted or where employees will see the notice

15 for the duration of the consent decree. The defendant will also post in the same location a copy

16 of the EEO policy referenced in paragraph 11.

17

E. Training

18

17. During the term of this consent decree, the defendant will provide at least six

19 hours of employment discrimination training annually for its managers at ILB facilities in the

20 state of Oregon. The training agenda must include instruction on employment issues, including

21 topics related to sexual and gender harassment and retaliation. The first training will take place

22 within sixty days of entry of this consent decree. The second training will take place within sixty

23 days after the one-year period following entry of this consent decree. The form, content, and

24 number ofthe training events will be subject to prior review by the EEOC, and the cost of

25 training shall be borne by defendant.

CONSENT DECREE - PAGE 4

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Seattle District Office
909 First Avenue, Suite 400 Seattle, Washington 98104·1061
Telephone: (206) 220·6883 Fl'Ir.<:;imil",· (?On) ??O-n911 TOD: (206) 220·6882

18. The defendant will provide to the EEOC a list of attendees of the trainings

2 provided pursuant to paragraph 19, an evaluation form filled out and signed by each attendee,

3 and a copy of the training materials and handouts with the reports required in paragraph 19.

4

F. Reporting

5

19. Twelve months after entry of this decree, and twelve months after the one-year

6 period following entry of this decree, the defendant will providc a rcport to thc Commission with

7 a summary of the complaints of employment discrimination, if any, filed pursuant to the

8 provisions of its EEO policy as set forth in paragraphs 11-14 during the preceding twelve-month

9 period. The report will describe the resolution of each complaint.

10

20. The report will also include copies of the attendee lists, evaluations, and

11 materials generated by the training required by paragraphs 17-18.

12

21. The defendant will also include in the report a statement listing the other

13 provisions of this decree that it was required to perform during the preceding period and

14 certifying that it has complied with the terms of the decree. If the defendant has not complied

15 with any term of the decree, the statement will specify the areas of noncompliance, the reason for

16 the noncompliance, and the steps taken to bring the defendant into compliance.

17

VI. ENF'ORCEMENT

18

22. The United States District Court for the District of Oregon shall retain

19 jurisdiction over this matter for the duration of the decree. If the EEOC believes the defendant

20 has not complied with any of the above provisions, it must provide the defendant written

21 notification of the alleged breach. The 20-day period following the written notification is for the

22 parties to attempt to reach agreement on compliance with the decree. The parties may extend the

23 20-day period by mutual agreement. Only after the parties have exhausted these informal efforts

24 may the Commission bring an action to enforce this consent decree.

25

CONSENT DECREE - PAGE 5

u.s. EOUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
909 First Avenue, Suite 400
Seattle, Washington 98104·1061 Telephone: (206) 220·6883 Facsimile: 12061 220·6911 TOO: (206) 220·6882

1

VII. TERMINATION OF DECREE

2

23. This decree shall be in effect for two years and 60 days commencing with the

3 date the decree is entered by the court. If the EEOC petitions the court and the court finds the

4 defendant to have violated the terms of this consent decree, it may extend the period of this

5 consent decree and award the Commission its costs in bringing an enforcement action.

6

DArED this _ _ _ _ day _ _ _ _ _ _ _, 200l.

7

8 Respectfully submitted,
9 A. LUIS LUCERO, JR. Regional Attorney
10 BARDARA 1. STANDAL
11 Supervisory Trial Attorney

GWENDOLYN YOUNG REAMS Associate General Counsel

12 JOHN F. STANLEY Senior Trial Attorney
13

14 BY:
15 EQUAL EMPLOYMENT OPP
16 COMMISSION Seattle District Office
17 909 1st Avenue, Suite 400 Seattle, Washington 98104
18 Telephone (206) 220-6892

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Office of the General Counsel 1801 "L" Street, N.W. Washington, D.C. 20507

19

Attorneys for Plaintiff

20 21

BY:

~t Cf)£~-

22 Jeffrey A. Johnson COSGRAVE VERGEER & KESTER
23 121 SW Morrison, Ste. 1300 Portland, Oregon 97204-3193
24 A ttorneys for Defendant
25

CONSENT DECREE - PAGE 6

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
909 First Avenue, Suite 400
Seattle. Washington 98104·1061 Telephone: 1206) 220-6883 Facsimile: (206) 220-6911 TDD: (206) 220-6882

ORDER

2

The Court, having considered the foregoing stipulated agreement of the parties,

3 HEREBY ORDERS THAT the foregoing consent decree be, and the same hereby is, approved as

4 the final decree of this Court in full settlement of this action. This lawsuit is hereby dismissed

5 with prejudice and without costs or attorneys' fees to any party. The Court retains jurisdiction of

6 this matter for purposes of enforcing the consent decree approved herein.

7

8

.) r> ( ~_j,~ DATED this ('r' day of __./l.-!..J-'1t--=C:I/~' lit" _ _, 2001 .

9

,/J

I

10 / I.

11

P. COONEY

ITED STATES MAGIST EJUDGE

12

13

14

15

16

17

18 19

20

21

22

23

24

25

CONSENT DECREE - PAGE 7

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Seattle District Office
909 First Avenue. Suite 400 Seattle, Washington 98104·1061
Telephone: (206) 220·6883 Facsimile: (206) 220·6911 TDD: (206) 220·6882

CHARGE'

.. ---------------~~ --:__-___r---------__,

;SCRIMINATION

}C Y

CHARGE NUMBER

This f0rm is aff~ct~d by the Privacy Act of 1974; See Privacy Act Statement before c0mpleting this form.

and EEOC

NAME (Indicate Mr .• Ms .• Mrs.)

TELEPHONE (Include Area Code)

STREET ADDRESS

CITY, STATE AND ZIP CODE

P.O. Box 6 64 Nikiski AK

NAMED IS THE EMPLOYER, LABOR ORGANIZATION, EMPLOYMENT AGENCY APPRENTICESHIP COMMITTEE,

STATE OR LOCAL GOVERNMENT AGENCY WHO DISCRIMINATED AGAINST ME (Ir more than one list below.)

NAME

OF EMPLOYEES, MEMBERS

International Line Builders

STREET ADDRESS

CITY, STATE

00 Antelo e Rpad White Cit
NAME

TELEPHONE NUMBER (Include Area Code)

STREET ADDRESS

CITY, STATE AND ZIP CODE

COUNTY

~C~AU~S~ E =O= F ~D=IS=C~ RI~ M~ IN~A~ TI~ ON~~B~AS~ED--O- N -(~ C/~ lec-k-a~pp~ro-p-ri- at- e -bo-x- (e-s)-) --------.-------D-A- TE--D- IS- CR-I- M- IN-A- TI-O- N -T-O- OK--PL-A-CE

RACE

U COLOR

[Xl SEX

o RELIGION

o NATIONAL ORIGIN

fo.llRLIEST

LATEST

RETALIATION

AGE

DISABILITY [ ] OTHER (Spectry)

11/04/1999

[ ] CONTINUING ACTION

THE PARTICULARS ARt:: (If' additional space is neeaea, attae!! exGra sllt:c,(s));
From approximately May 1, 1999 through June 18, 1999 I was subjected to

sexual harassment and sex discrimination. Due to the hostile work

environment. I was forced to remove myself from the job. After the
union intervened, the Company gave my my final check, agreed that the
reason for leaving would be "layoff" and that I was eligible for rehire.
On November 4, 1999 I received a dispatch and responded to a call for
work at the Company. When I reported for work, the foreman rejected me

for the job.

I reported the sexual harassment and sex discrimination to Company
officials on June 18, 1999. I am not aware of whether any action was
taken to discipline the harassers. The reason the foreman gave me for refusing to hire me on November 4, 1999 was because of the "trouble" I had caused last summer. I believe that he was referring to my complaint
about the hostile work environment. Therefore, I believe that I was denied hire in retaliation for the complaint I made in June, 1999 about unlawful sexual harassment and sex discrimination.

I believe that I was sexually harassed and discriminated against due to

Illy sex, female in violation of Title VII of the Civil Rights,~\~ffilHiU.f1l

1964, as amended and retaliated against in violation of S~¢,~~ .. !f~~~~~)

of the statute.

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c=J I want this charge filed with both the EEOC and the State 0 NOTARY (When necessary for St;~ii':'~~~!'lc.ql.fle~~th~ints)

local Agency, if any. I will advise the agencies if I change myl--_ _ _ _ _ _ _ _ _ _ _ _ _ _ _·_·_·~:'_".t:'_"'Cl:J,;t:c;__'_'f:>.\.:.:.,··-,'·__'-"·----__1

address or telephone number and cooperate fully with them in the I swear or affirm that I have read the above ~harg~ and that

processing of my charge in accordance with their procedures.

it is true to the best of my knowledge, information and belief.

I declare under penalty of perjury that the foregoing is true and correct.

V6}te --~L _ ;2. 9 - 0 0
EEOC FORM 5 (Rev. 06/99) I

Charging Party (Signat

SIGN~URE OF COMPLAINANT

,

/Y~UtB;S.jC(jR--I4B-GED--rA, ND~ SWORN TO~ BEFORE ME THIS DATE

(Month, day and year)

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Se*lJs Qjslf~ch1ffice

Federal OfJ\ce Building 909 First Ave., Suite 400

Scattle, WA 98104-1061

PI!: (206) 220-6883

TOO: (206) 220-6882

FAX: (206) 220-6911

Charge 380A00862

Susan Baldwin POBOX 6964 Nikiski, AK 99635

Charging Party

International Line Builders, Inc. 900 Antelope Road White City, OR 97503

Respondent

DETERMINATION

Under the authority vested in me by the Commission, I issue the following determination as to the merits of th.e subject charge filed under Title VII of the Civil Rights Act of 1964, as amended (Title VII).
All requirements for coverage have been met. Charging Party alleged that Respondent discriminated against her in violation of Title VII in that she was subjected to sexual harassment and gender discrimination due to her sex, female. She further alleged that the unlawful sexual and gender harassment created a hostile work environment, which led to her constructive discharge. In addition, although the Company had reached an agreement with the union that she was eligible for rehire, she was rejected for hire when she responded to a dispatch a few months later. She alleged that the Company failed to hire her in retaliation for her prior complaint of unlawful sexual harassment and gender discrimination.
During the investigation, all relevant, available witnesses were interviewed, and all relevant documents were reviewed. I have considered all the evidence disclosed during the investigation and have determined that there is reasonable cause to believe that Charging Party was subjected to unlawful sexual harassment and gender harassment which created a hostile work environment and which led to her constructive discharge, in violation of Title VII. In addition, there is reasonable cause to believe that the Company failed to hire her at a later date in retaliation for her prior complaint of sexual harassment and gender discrimination, in violation of Section 704(a) of the statute.

EXHIBIT 2..

Upon finding that there is reason to believe that violations have occurred, the Commission attempts to eliminate the alleged unlawful practices by informal methods of condliatioll. Therefore, the Commission now invites the parties to join with it in reaching a just resolution of this matter. The Commission will also consider compensatory and punitive damages under the Civil Rights Act of 1991.
If the Respondent declines to discuss settlement or when, for any other reason, a settlement acceptable to the office Director is not obtained, the Director will inform the parties and advise them of the court enforcement alternatives available to aggrieved persons and the Commission. A Commission representative will contact each party in the near future to begin conciliation.
On behalf of the Commission

AUG - 8 2000

NETTE M. LEINO STRICT DIRECTOR

NOTICE TO ALL EMPLOYEES This notice is being posted pursuant to a consent decree entered into by INTERNATIONAL LINE BUILDERS, INC. ("ILB") and the EQUAL EMPLOYMENT OPPORTUNITY COMMISSION. The consent decree is a document settling a lawsuit filed by the EEOC against ILB in the federal district court for the District of Washington at Medford, Case No. 00-3105CO. Title VII of thc Civil Rights Act of 1964, as amended, the Age Discrimination in Employment Act of 1967, the Equal Pay Act of 1963, and the Americans with Disabilities Act of 1990 are enforced by the EEOC and require the following:
That there be no discrimination against any employee or applicant for employment because of the employee's race, sex, color, religion, national origin, age (age 40 and over), or disability with respect to hiring, firing, compensation, or other terms, conditions or privileges of employment. It is an unlawful employment practice for an employer to retaliate against any employees or applicants for employment because they have opposed a practice or because they have made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under these statutes. ILB will institute a training program to train managers regarding the requirements of the above statutes, with particular emphasis on sexual harassment and retaliation issues. ILB has posted this notice because the company supports and will comply with thesc federal laws in all respects and will not take any retaliatory action against employees because they have exercised their rights under the law. DATED _ _ _ _ _ _ _ _ __
INTERNATIONAL LINE BUILDERS, INC.
EXHIBIT 3

 
 1 A LUIS LUCERO, JR. Regional Attorney
2 BARBARAJ. STANDAL Supervisory Trial Attorney
3 JOHN STANLEY Senior Trial Attorney
4 EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 5 909 First Avenue, Suite 400
Seattle, WA 98104 (206) 220-6892
6

FIl FrORIGINAL

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7

8

UNITED STATES DISTRICT COURT

FOR DISTRICT OF OREGON

9

AT MEDFORD

10

EQUAL EMPLOYMENT OPPORTUNITY

)

11 COMMISSION,

) )

CIVIL ACTION NO. 00- 3JC15-CO

12

Plaintiff,

)

)

COMPLAINT

13

v.

)

)

JURY TRIAL DEMAND

14 INTERNATIONAL LINE BUILDERS, INC.,

)

)

15

)

Defendant.

)

16

)

17 NATURE OF THE ACTION
18 This is an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I of
19 the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and to
20
provide appropriate relief to Susan Baldwin. The Equal Employment Opportunity Commission
21 alleges that International Line Builders, Inc. harassed Ms. Baldwin because of her sex, female, creat-
22 ing a hostile environment and thereby discriminatorily interfering with her employment. This led to
23 Ms. Baldwin's constructive discharge_ Further, plaintiff alleges that International Line Builders, Inc.
24 failed to rehire Ms. Baldwin in retaliation for her earlier complaints of sexual harassment. Plaintiff
25 seeks monetary and injunctive relief, including pecuniary and nonpecuniary compensatory damages,
26 and punitive damages.
27

COMPLAINT - PAGE I

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office Building 909 First Avenue, Suite 400
Seattle, Washington 98104-1061 Telephone (206) 220-6883 Fax (206) 220-6911 TDO (206) 220 6882

1

JURISDICTION AND VENUE

2

1.

Jurisdiction of this Court is invoked pursuant to 28 U.S.c. §§ 451,1331,1337, 1343

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

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

5 section 102 of the Civil Rights Act of 1991,42 U.S.C. § 1981a.

6

2.

The employment practices alleged to be unlawful were committed within the

7 jurisdiction of the United States District Court for the District of Oregon at Medford.

PARTIES

9

3.

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

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

11 enforcement of Title VII and is expressly authorized to bring this action by sections 706(f)(l) and (3)

12 of Title VII, 42 U.S.C. §§ 2000e-5(f)(l) and (3).

13

4.

At all relevant times, defendant International Line Builders, Inc. (the "employer"), has

14 continuously been a corporation doing business in the state of Oregon and the city of Medford, and

15 has continuously had at least 15 employees.

16

5.

At all relevant times, defendant has continuously been an employer engaged in an

17 industry affecting commerce under sections 701(b), (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b),

18 (g), and (h).

19

STATEMENT OF CLAIMS

20

6.

More than thirty days prior to the institution of this lawsuit, Susan Baldwin filed a

21 charge with the Commission alleging violations of Title VII by defendant. All conditions precedent

22 to the institution of thi!:i lawsuit have been fulfilled.

23

7.

From at least May 1, 1999, defendant has engaged in unlawful employment practices

24 through its Medford, Oregon area facility in violation of sections 703(a) and 704(a) of Title VII, 42

25 U.S.C. §§ 2000e-2(a) and -(3)(a). Defendant harassed Ms. Baldwin because of her sex, female,

26 creating a hostile environment and thereby discriminatorily interfering with her employment. This

27 discriminatory conduct led to Ms. Baldwin's constructive discharge because her working conditions

COMPLAINT· PAGE 2

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office
Federal Office Building 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone (206) 220-{)883
Fax (206) 220-6911 TDD (206) 2?n-llRR?

1 were intolerable. Plaintiff also alleges that International Line Builders, Inc. failed to rehire Ms. 2 Baldwin on or about November 4, 1999, in retaliation for her earlier complaints of sexual

3 harassment.

4

8. The effect of the practices complained of in paragraph 7 above has been to deprive

5 Susan Baldwin of equal employment opportunities and otherwise adversely affect her status as an

6 employee of International Line Builders because of sex and retaliation.

7

9. The unlawful employment practices complained of in paragraph 7 above were

8 intentional.

9

10. The unlawful employment practices complained of in paragraph 7 above were done

10 with malice or with reckless indifference to the federally protected rights of Susan Baldwin.

11

PRAYER FOR RELIEF

12

Wherefore, the Commission respectfully requests that this Court:

13

A. Grant a permanent injunction enjoining defendant, its officers, successors, agents,

14 assigns, and all persons in active concert or participation with it, from engaging in any other

15 employment practice which discriminates on the bases of sex and retaliation.

16

B. Order defendant to institute and carry out policies, practices, and programs which

17 provide equal employment opportunities for all employees, and which eradicate the effects of its past

18 and present unlawful employment practices.

19

c. Order defendant to make whole Susan Baldwin by providing appropriate back pay

20 with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary

21 to eradicate the effects of its unlawful employment practices.

22

D. Order defendant to make whole Susan Baldwin by providing compensation for past

23 and future pecuniary losses resulting from the unlawful employment practices described in paragraph

24 7 above, including past and future out-of-pocket expenses, in amounts to be determined at trial.

25

E. Order defendant to make whole Susan Baldwin by providing compensation for past

26 and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7

27 above, including without limitation emotional pain, suffering, and loss of enjoyment of life, in

COMPLAINT - PAGE 3

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office Building 909 First Avenue, Suite 400
Seattle, Washington 98104·1061 Telephone (206) 220-6883 Fax (206) 220-6911 TOO (206) 220-1>882

amounts to be determined at trial.

2

F. Order defendant to pay Susan Baldwin punitive damages for its malicious and

3 reckless conduct described in paragraph 7 above, in amounts to be determined at trial.

4

G. Grant such further relief as the Court deems necessary and proper in the public

5 interest.

6

H. Award the Commission its costs of this action.

7

8

JURY TRIAL DEMAND

9

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

10

DATED this ,;21 ')Tit day of 6·...(j'Ii'lhbe V

,2000.

11

12 A. LUIS LUCERO, JR.
Regional Attorney 13
BARHARA J. STANDAL 14 Supervisory Trial Attorney

C. GREGORY STEWART General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel

15 JOHN F. STANLEY Senior Trial Attorney
16

17 EQUAL EMPLOYMENT OPP
18 COMMISSION Seattle District Office
19 909 First Avenue, Suite 400 Seattle, Washington 98104
20 Telephone (206) 220-6892

Office of the General Counsel 1801 "L" Street NW Washington, D.C. 20507

21

Attorneys for Plaintiff

22

23

24

25 26

27

COMPLAINT - PAGE 4

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Seattle District Office Federal Office Building 909 First Avenue, Suite 400
Seattle, Washington 98104-1061 Telephone (206) 220-6883 Fax (206) 220-6911 TOO (206) 220-6882

 
 District of Oregon - Docket Report

https://ecf.ord.uscourts.gov/cgi-bin/DktRpt.pl?116565666394344-L_35...

U.S. District Court District of Oregon (Medford) CIVIL DOCKET FOR CASE #: 1:00-cv-03105-CO

TERMINATED

Equal Employment Opportunity Commission v. International Line Builders, Inc. Assigned to: Magistrate Judge John P. Cooney Cause: 28:451 Employment Discrimination

Date Filed: 09/28/2000 Date Terminated: 03/01/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by A.Luis Lucero, Jr. Equal Employment Opportunity Commission 909 First Avenue, Suite 400 Seattle, WA 98104 (206) 220-6892 ATTORNEY TO BE NOTICED

Barbara J. Standal Equal Employment Opportunity Commission 909 First Avenue, Suite 400 Seattle, WA 98104 (206) 220-6892 ATTORNEY TO BE NOTICED

C. Gregory Stewart Office of the General Counsel 1801 "L" Street NW Washington, DC 20507 ATTORNEY TO BE NOTICED

Gwendolyn Young Reams Office of the General Counsel 1801 "L" Street NW Washington,, DC 20507 ATTORNEY TO BE NOTICED

John Freeman Stanley Equal Employment Opportunity Commission (EEOC) 909 First Avenue Suite 400 Seattle, WA 98104-1061 (206) 220-6896 Fax: (206) 220-6911

1 of 3

5/23/2007 12:16 PM

District of Oregon - Docket Report

https://ecf.ord.uscourts.gov/cgi-bin/DktRpt.pl?116565666394344-L_35...

V. Defendant International Line Builders, Inc.

Email: john.stanley@eeoc.gov ATTORNEY TO BE NOTICED
represented by Jeffrey A. Johnson Cosgrave Vergeer Kester, LLP 805 SW Broadway 8th Floor Portland, OR 97205 (503) 323-9000 Fax: (503) 323-9019 Email: jjohnson@cvk-law.com ATTORNEY TO BE NOTICED

Date Filed 09/28/2000 11/08/2000 11/08/2000
11/08/2000 11/09/2000 11/09/2000 11/09/2000 11/16/2000 12/11/2000

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Docket Text

1 Complaint against International Line Builders, Inc.,. Summons issued as to International Line Builders, Inc.. Filed by Equal Employment Opportunity Commission (Norris, Debbie) (Entered: 09/28/2000)
2 Discovery and Pretrial Scheduling Order: Discovery to be completed by 3/8/2001. Pretrial Order due by 4/9/2001. (Norris, Debbie) (Entered: 11/08/2000)
3 Order plaintiff shall serve a copy of the discovery and pretrial scheduling order, notice of presiding Judge and consent to a magistrate form on defendant. By Judge John P. Cooney. (related document(s)2) (Norris, Debbie) (Entered: 11/08/2000)
4 Return of Service Executed upon International Line Builders, Inc. on 10/20/00. Filed by Equal Employment Opportunity Commission. (Norris, Debbie) (Entered: 11/08/2000)
5 Motion for Extension of Time to Answer.(related document(s)1) Filed by International Line Builders, Inc.,. (Norris, Debbie) (Entered: 11/09/2000)
6 Affidavit of Jeffrey A. Johnson. (related document(s)5) Filed by International Line Builders, Inc.,. (Norris, Debbie) (Entered: 11/09/2000)
7 Order Granting Motion for Extension of Time to Answer (Related Doc #5). by Judge John P. Cooney. (Norris, Debbie) (Entered: 11/09/2000)
8 Response to Motion and Order for Extension of Time for Defendant to File Appearance. (related document(s)5, 7) Filed by Equal Employment Opportunity Commission. (Norris, Debbie) (Entered: 11/16/2000)
9 Answer to Complaint. (Related Doc # 1) Filed by International Line Builders, Inc.,. (Norris, Debbie) (Entered: 12/11/2000)

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District of Oregon - Docket Report

https://ecf.ord.uscourts.gov/cgi-bin/DktRpt.pl?116565666394344-L_35...

03/01/2001 03/15/2001

10 Order of Dismissal. Reported settled. Signed 3/1/01 (Norris, Debbie) (Entered: 03/01/2001)
11 Consent Judgment and Order Dismissing Action: Signed 3/15/01 by Judge John P. Cooney. (Norris, Debbie) (Entered: 03/16/2001)

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