Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 1 of 7

IN TIlE UNITED STATES DISTRICT COURT FOR TRE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

DOCKETED
SEP 2 0 2004

jfl{

Plaintiff,

CIVIL ACTION N%DGE
CASTILLO

)V.

)

COMPLAINT

z

THE LAW BULLETIN PUBLISHING CO., )

JURY TRIAL DEMA14DEU

Defendant. MAGj3TR, r,

-

NATUIREOFTIIEACTION

u.- - r"

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J T2

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a. fl-i

This is an action under Tide VII of the Civil Rights Act of 1964, as amended, 42

U.S.C. § 2000e g. ("Title VII"), and Title I ofthe Civil Rights Act of 1991 to correct unlawful employment practices on the basis of race and retaliation and to provide appropriate

relief to Charging Party Deanna Young ("Young") who was adversely affected by such

practices. Plaintiff Equal Employment Opportunity Commission ("EEOC" or "Commission")

alleges that the Law Bulletin Publishing Co. ("Law Bulletin") subjected Young to harassment

on the basis of her race (Black). EEOC also- alleges that the Law Bulletin retaliated against

Young by terminating her when she complained of harassment.

JURISDICTION AND VENUE

1. Jurisdiction ofthisCourt is invoked pursuant to 28 U.S.C. § 451, 1331, 1337, 1343, and 1345. This action is authorized and instituted pursuant to Section 706(f)(l) and (3)

ofTitle WI, 42 U.S.C. § 2000e-5(f)(l) and (3), and § 102 ofthe Civil Rights Act of 1991, 42

U.S.C. § 1981A.

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Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 2 of 7

The employment practices hereafter alleged to be unlawÑl were and are now being committed within the jurisdiction ofthe United States District Court for the Northern District of Illinois, Eastern Division.

PARTIES

Plaintiff, the Equal Employment Opportunity Commission, is an 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(fl(1) and (3) of Title VII, 42 U.S.C. Section 2000e-5(f)(1) and (3).

At all times relevant, Defendant Law Bulletin has continuously been doing business in the Northern District of Illinois and has continuously had at least fifteen employees.
At all times relevant, Defendant Law Bulletin has continuously been an
employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. Sections 2000e(b), (g) and (h).

STATEMENT OF CLAIMS

More than thirty days prior to the institution of this lawsuit, Charging Party Deanna Young filed a charge with the Commission alleging violations of Title VII by the Law Bulletin. All conditions precedent to the institution of this lawsuit have been fulfilled.
Pursuant to 42 U.S.C. §2000e-5(f)(l), EEOC's representatives attempted to eliminated the unlawful employment practices alleged below and to effect voluntary compliance with Tide VII prior to institution of the lawsuit but EEOC was unable to secure a conciliation agreement acceptable to the Commission.

8

Since at least April 2004, the Law Bulletin has engaged in unlawihl employment

-2-

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Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 3 of 7
practices in Chicago, Illinois, in violation of Sections 701(k) and 703(a) ofTitle VII, 42 U.s.c.
Sections 2000e(k) and 2(a). Such unlawful employment practices include racially harassing Young, failing to correct the racially hostile work environment, and retaliating against Young
after she complained ofharassment by terminating her employment. The effect of the practices complained of above has been to deprive Young of
equal employment opportunities and otherwise adversely affect her status as an employee because of her race and/or because she opposed discrimination.
The unlawful employment practices complained of in paragraphs 8 and 9 above
were intentional.
il. The unlawfUl employment practices complained of in paragraphs 8 and 9 above
were done with malice or with reckless indifference to the federally protected rights of Young because other mce and/or because she opposed discrimination.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court: Grant a permanent injunction enjoining the Law Bulletin, its officers,
successors, assigns, and all persons in active concert or participation with it, from engaging in
any employment practice which discriminates because ofrace and from engaging in any
retaliation for opposing discrimination or for participating in any manner in any investigation, proceeding, or litigation under Title VII.
Order the Law Bulletin to institute and carry out policies, practices and
programs which eradicate the effects of its past and present unlawful practices.
Order the Law Bulletin to make whole Young by providing appropriate back
-3-
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Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 4 of 7
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, including reinstatement.
Order the Law Bulletin to make whole Young by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 8 and 9 above, in amounts to be determined at trial.
Order the Law Bulletin to make whole Young by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraphs 8 and 9 above, including emotional pain, inconvenience, and humiliation, in amounts to be determined at trial.
Order the Law Bulletin to pay to Young punitive damages for its malicious and reckless conduct described in paragraphs 8 and 9 above, in amounts to be determined at trial.
Grant such further relief as the Court deems necessary and proper in the public interest; and
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 1:04-cv-06063 Document 1 Filed 09/17/04 Page 5 of 7
Respectfully submitted, Eric S. Dreiband General Counsel James Lee Deputy General Counsel Owendolyn Young Reams Associate General Counsel EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
siI, 1801 "L" Stret, N.W.
Washingtojj! . U
John Henu't on
Regi al Attorney

1\OW\k.Q
Laurie S. Elkin Trial Attorney

U3Q

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION Chicago District Office 500 West Madison Street

Suite 2800 Chicago, Illinois 60661

(312) 353-7726

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Civil Cover S

Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 6 of 7 Page 1 o12

ED STATES DISTRICT COURT NO THERN DISTRICT OF ILLINOIS
Civil Cover SheetaJ4c

DOCKETED
SEflo2004
Bose

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in

September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the 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 only in the Northern District of Illinois.

JUDGE CAS IILLÁ.j

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
County ofResidence:

Defendant(s)TIIE LAW BULLETIN PUBLISHING CO.
County of R1&T&AIE JUDGE MASON

Plaintiffs Any:

Laurie S. Ellcin

Defendant's Atty:

Equal Employment Opportunity

Commission

500 W. Madison, Suite 2800,

Chicago, Illinois

(312) 353-7726

Steven L. Loren Gardner, Carton & Douglas 191 N. Wacker Drive, Suite 3700 Chicago, Illinois

Basis of Jurisdiction:

1. U.S. GoVt Plaintiff

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

1V. Origin

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

Tille VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.

§2000e et seq., and Title I of the Civil Rights Act of 1991,42 U.S.C.

§1981a, to correct unlawful employment practices on the basis of

racial harassment and retaliation

YiLRguested in Complaint

Class Action: No

Dollar Demand:

Jury Demand: Yes

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

SignatureS pjj,j..J5 A> t,tk4rn fl oq Date. Q_pkQAWIb.Q&
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Case 1:04-cv-06063 Document 1 Filed 09/17/04 Page 7 of 7

In the Matter of

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILUNOIS
EASTERN DIVISION

U.S. Equal Employment Opportunity Commission
V.
The Law Bulletin Publishing Co.

DOCKETED

SEP 2 92004

j-
'-J

cf)O: u-oCi

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

U.S. Equal Employment Opportunity Commission

r "DGE '.1A8 TILi0

(A)

(j ej SIGNATURE

AsAA

NAME
Laurie S. Ellcin

> t't4QAA4_.

FIRM Equal Employment Opportunity Commission

500 W. Madison St., Suite 2800

Chicago, IL 60661

TELEPHONE NUMBER
312-353-7726
E-MAIL ADDRESS

FAX NUMBER

IDENTIFICATION NUMBER (SEE rTEM 4 ON REVERSE)
ARDC NO. 06210523

MEMBER OF TRIAL BAR?

YES

TRIAL ATTORNEY?

YES

///t//
J// SIGNA '1

No
r NO

N i John . ndri- ckson
Equal Employment Opportunity Commission

W. Madison St., Suite 2800

CITY/STATEjZIP Chicago, IL 60661

TELEPHONE NUMBER -
312-353-8551

FAX NUMBER

E-MAIL ADDRESS

â MAGISTRATE JUJ)GE MASON a

SIGN

WV

Js4SsÁt.i14.AaA

7/ Gr

1ur

FIRM Equal Employment Opportunity Commission

STREETADDRESS 500 W. Madison St., Suite 2800

CnY/STATE'ZIP Chicago, IL 6066v.

TELEPHONE NIMBER
312-353-7259

4 NI1.IBEO
.

E-MAIL ADDRESS

¿ --

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVE)

ARDC NO. 06210804

(

MEMBER OF TRIAL BAR?

I

TRIAL ATTORNEY?

-

-

cai
CT
YeS

J -..
ÑÓ) U
NO

DESIGNATED AS LOCAL LJNSEL7

YES

D NO U

SIGNATURE NAME

STREETADDBESS CITY/STATERIF TELEPHONE NIMBER E-MAlI. ADDRESS

FAX NIMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)
ARDCNO. 01187589

MEMBER OF TRIAL BAR?

YES

rA

NO

TRIAL ATTORNEY?

YES

NO

DESIGNATED AS LOCAL QNSEL?

D NO

IDENTIFICAI1ON NUMBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR? TRIAL ATTORNEY? DESIGNATED AS LOCAL COINSEL?

YES

NO

YES

NO

YES

NO

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 Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 1 of 8

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

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

Case No. 04 C 6063

V.

Judge Castillo

THE LAW BULLETIN PUBLISHING CO., Defendant.

Magistrate Judge Mason

CONSENT DECREE
THE LITIGATION
Plaintiff Equal Employment Opportunity Commission (the "EEOC") filed this action alleging that Defendant, The Law Bulletin Publishing Co. ("The Law Bulletin") violated
Sections 701(k) and 703(a) of Title VII of the Civil Rights Act of 1964, as amended ("Title
VII"), 42 U.S.C. § 2000e(k) and 2(a), by retaliating against Deanna Young after she complained of racial harassment by terminating her employment. The Law Bulletin denies these allegations and denies committing any wrongdoing whatsoever.
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 Consent Decree (hereafter "Decree"). This Decree filly and finally resolves any and all issues and claims arising out of the Complaint filed by the EEOC in
this action. FINDINGS
Having carefully examined the terms and provisions of this Decree, and based on
i

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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 2 of 8

the pleadings, record, and stipulations of the parties, the Court finds the following: This Court has jurisdiction of the subject mauer of this action and of the

parties.

The terms of this Decree are adequate, fair, reasonable, equitable, and

just. The rights of the parties and the public interest are adequately protected by this Decree. This Decree conforms with the Federal Rules of Civil Procedure and Title
VII and is not in derogation of the rights or privileges of any person. The entry of this Decree will further the objectives of Title VII 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:

NON-RETALIATION The Law Bulletin, its officers, agents, employees, successors, assigns and all persons acting in concert with it shall not engage in any forni of retaliation against any person
because such person has opposed any practice made unlawflil under Title VII, filed a Charge of
Discrimination under Title VII, testified or participated in any manner in any investigation, proceeding, or hearing under Title VII, or asserted any rights under this Decree.

NON-ADMISSION Nothing in this Consent Decree shall be construed as an admission by either
party of liability or non-liability with respect to any of the claims or defenses in the suit.

MONETARY RELIEF The Law Bulletin shall pay the gross sum of $20,000 to Charging Party Deanna Young in compensatory damages. Within ten (10) business days after receipt by The Law Bulletin of a Release Agreement in the form attached hereto as Exhibit A and entry of this Decree, The Law
2

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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 3 of 8
Bulletin or its agent shall issue and send by certified mail a check to Charging Party in the amount set forth in paragraph 6 above. A copy of the check issued shall be sent to the EEOC.
EEOC POSTING
Within ten (10) business days after entry ofthis Decree, The Law Bulletin shall post or continue to post the official EEOC Poster describing federal laws prohibiting job
discrimination on bulletin boards usually used by The Law Bulletin for communicating with all its employees. The Law Bulletin shall ensure that the posting is not altered, defaced or covered by any other material. The Law Bulletin shall certify to the EEOC in writing within
ten (10) business days after entry of this Decree that the Notice has been or remains properly posted. The Law Bulletin shall permit a representative of the EEOC to enter its premises for purposes of verifying compliance with this Paragraph at any time during business hours.
RECORD KEEPING
For a period of one (1) year following entry of this Decree, The Law Bulletin shall maintain and make available for inspection and copying by the EEOC records of each complaint of retaliation for engaging in any of the protected activities described in paragraph
4 above. Such records shall indicate the date the complaint was made, who made it, what was alleged, and what actions The Law Bulletin took to resolve the matter, and when.
The Law Bulletin shall make all documents or records referred to in Paragraph 9 above, available for inspection and copying within ten (10) business days after the EEOC so requests. In addition, The Law Bulletin shall make available for interview all persons within
its employ whom the EEOC reasonably requests for purposes of verifying compliance with this Decree and shall permit a representative of the EEOC to enter its premises for such
purposes on five (5) business days advance notice by the EEOC. Nothing contained in this Decree shall be construed to limit any obligation The
Law Bulletin may otherwise have to maintain records under Title VII or any other law or
3
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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 4 of 8

regulation.

REPORTING

12. The Law Bulletin shall furnish to the EEOC the following written reports semi-
annually for a period of one (1) year following entry of this Decree. The first report shall be due six (6) months after entry of the Decree. The final report shall be due eleven (11) months

after entry of the Decree. Each such report shall contain:

a

A summary ofthe information recorded by The Law Bulletin pursuant to

Paragraph 9, including the names of each person who complained of retaliation, the date of

the complaint, and the actions, and dates thereof, taken by The Law Bulletin, including any

discipline given;

b

A certification by The Law Bulletin that the Notice required to be posted

in paragraph 8 above remained posted during the entire six (6) month period preceding the

report.

DISTRIBUTION OF POLICY AGAINST RETALIATION
13. Within twenty-one (21) days after the entry of this Consent Decree, The Law
Bulletin shall distribute to each employee of The Law Bulletin its Policy against retaliation for
making complaints of harassment or discrimination. 14. A copy of the Policy shall be given to each new employee on or about the day
the person is hired. Copies of the Policy shall also be posted on the bulletin boards
customarily used for posting notices from management to employees.

TRAINING
15. Within 60 days of the entry of this Decree, The Law Bulletin shall retain and
pay for a trainer approved by the EEOC, to provide training to all owners and officers who are
4

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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 5 of 8
actively engaged in the management of the business, supervisors and managers with respect to retaliation and with respect to the Policy referred to in paragraph 13 above. Attendance shall be mandatory. A registry of attendance shall be maintained.
The Law Bulletin shall obtain the EEOC's approval ofits proposed trainer prior
to the training session. The Law Bulletin shall submit the name, address, telephone number
and resume of the proposed trainer to the EEOC within 30 days of the entry of this Decree. The EEOC shall have ten calendar days from the date of receipt of the information described
above to accept or reject the proposed trainer. In the event the EEOC does not approve The Law Bulletin's designated trainer, The Law Bulletin shall have ten calendar days to identify
an alternate trainer. The EEOC shall have ten calendar days from the date of receipt of the
information described above to accept or reject the alternate trainer. In the event the EEOC does not approve The Law Bulletin' s alternate trainer, the EEOC shall designate the trainer to be retained and paid for by The Law Bulletin.
The Law Bulletin shall certify to the EEOC in writing within ten (10) business days after the training has occurred that the training has taken place and that the required
personnel have attended. Such certification shall include: (i) the date, location and duration of the training; and (ii) a copy of the registry of attendance, which shall include the name and position of each person in attendance.
The Law Bulletin agrees to provide EEOC with any and all copies ofpamphlets, brochures, outlines or other written materials provided to the participants of the training
sessions.
DISPUTE RESOLUTION In the event that either party to this Decree believes 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 within ninety (90) days of the alleged non-
compliance and shall afford the alleged non-complying party ten (10) business days to remedy the
5
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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 6 of 8
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 or otherwise made arrangements that are mutually satisfactory to the parties, the complaining party may apply
to the Court for appropriate relief
DURATION OF THE DECREE AND RETENTION OF JURISDICTION All provisions of this Decree shall be in effect (and the Court will retain
jurisdiction of this matter to enforce this Decree) for a period of one (1) year immediately following entry of the Decree, provided, however, that if, at the end of one year, any disputes under Paragraph 19, above, remain unresolved, the term of the Decree shall be automatically extended (and the Court will retain jurisdiction of this matter to enforce the Decree) until such
time as all such disputes have been resolved.
MISCELLANEOUS PROVISIONS Each party to this Decree shall bear its own expenses and costs. The EEOC and The Law Bulletin shall bear their own attorneys' fees.
The terms of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns, and successors of The Law Bulletin in their capacities as representatives, agents, directors and officers of The Law Bulletin, and not in their
individual capacities.
When this Decree requires the submission by The Law Bulletin of reports, certifications, notices, or other materials to the EEOC, they shall be mailed to: Laurie Elkin, Trial Attorney, Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, Illinois, 60661. When this Decree requires submission by the EEOC of materials to The Law Bulletin, they shall be mailed to: Alan King at Gardner Carton & Douglas LLP, 191 N. Wacker Drive, Suite 3700, Chicago, Illinois 60606.
6
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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 7 of 8

For the Equal Employment Opportunity Commission 1801 L Street, N.W. Washington, D.C. 20507 Eric Dreiband General Counsel

James Lee Deputy General Counsel

Gwendolyn Young Reams Associate General Counsel

Equal Employment Opportunity

Commission

500 West Madison Street

Suite 2800

60" 1

John H ndrickson Regi nal Attorney

Laurie S. Elkin Trial Attorney
DATE: ffl1110S
7
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Case 1:04-cv-06063 Document 44 Filed 08/15/05 Page 8 of 8 For The Law Bulletin Publishing Co. Alan S. King
Gardner Cart .ffWouglas LLP
191 North Wacker Drive Suite 3700 Chicago, Illinois 60606
/ DATE: 7Á9 ç
Judge Ruben Castillo
C}102/ 22397779.2
8
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 Case: 1:04-cv-6063 As of: 05/05/2010 05:58 PM CDT 1 of 5
MASON, PROTO
United States District Court Northern District of Illinois − CM/ECF LIVE, Ver 4.0.3 (Chicago)
CIVIL DOCKET FOR CASE #: 1:04−cv−06063

EEOC v. Law Bulletin Pub Co Assigned to: Honorable Ruben Castillo Demand: $0 Cause: 42:2000e Job Discrimination (Employment)
Plaintiff

Date Filed: 09/17/2004 Date Terminated: 07/14/2005 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Equal Employment Opportunity Commission

represented by Laurie S. Elkin Equal Employment Opportunity Commission 500 W. Madison Street 2800 Chicago, IL 60661 (312) 353−7259 Email: laurie.elkin@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory M. Gochanour United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 886−9124 Email: gregory.gochanour@eeoc.gov 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

V. Defendant Law Bulletin Publishing Company

represented by Steven L. Loren Gardner, Carton &Douglas 191 North Wacker Drive Suite 3700 Chicago, IL 60606 (312)569−1000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Sterling King Gardner Carton &Douglas LLP 191 North Wacker Drive Suite 3700 Chicago, IL 60606−1698 (312) 569−1000

Case: 1:04-cv-6063 As of: 05/05/2010 05:58 PM CDT 2 of 5
Email: alan.king@dbr.com ATTORNEY TO BE NOTICED
Carrie Elizabeth O'Brien DrinkerBiddleGardnerCarton Suite 3700 191 North Wacker Drive Chicago, IL 60606 (312)569−1000 Email: carrie.obrien@dbr.com

Date Filed 09/17/2004 09/27/2004 10/13/2004
11/04/2004 11/15/2004 11/15/2004 11/23/2004 11/29/2004
12/14/2004 12/14/2004
01/14/2005 01/25/2005

# Docket Text
1 COMPLAINT; jury demand − Civil cover sheet − Appearance(s) of John C. Hendrickson, Gregory M. Gochanour, Laurie S. Elkin as attorney(s) for plaintiff (no summons(es) issued.) (Documents: (1−1 through 1−3)) (gma) (Entered: 09/20/2004)
2 WAIVER of service of summons as to defendant sent on 9/17/04 (lc) (Entered: 09/28/2004)
SCHEDULE set on 10/13/04 by Hon. Ruben Castillo : After a review of the initial pleadings in this case, this Court has decided to hold an expedited settlement conference. Plaintiff's counsel is directed to immediately serve the complaint and exhaust all settlement possibilities for this lawsuit. The Court will hold a settlement conference in chambers on 11/18/04 at 2:00 p.m. Clients with settlement authority are directed to appear or be available by telephone. Parties to file a joint status report on or before 11/15/04. (SEE REVERSE SIDE OF THIS ORDER FOR FURTHER INFORMATION.) Counsel for plaintiff to notify all other parties of the Court's order. Mailed notice (rao) (Entered: 10/13/2004)
SCHEDULE set on 11/4/04 by Hon. Ruben Castillo : Settlement conference reset to 2:00 p.m. on 11/29/04. Parties to file the joint status report on or before 11/23/04. Mailed notice (rao) (Entered: 11/04/2004)
3 ATTORNEY APPEARANCE for defendant Law Bulletin Pub Co by Steven L. Loren, Alan Sterling King, Carrie Elizabeth Kienstra. (jmm) (Entered: 11/18/2004)
4 ANSWER by defendant and affirmative defenses to plaintiff's complaint [1−1]; Notice. (jmm) (Entered: 11/18/2004)
5 JOINT STATUS REPORT by parties; Notice. (lc) (Entered: 11/24/2004)
6 MINUTE ORDER of 11/29/04 by Hon. Ruben Castillo : Status hearing set for 12/14/04 at 9:45a.m. Settlement conference held in chambers. The parties are requested to fully exhaust all remaining settlement possibilities in light of the Court's recommendation. Defendant is requested to make any settlement offer in writing on or before 12/10/04. The 12/14/04 status will be held in open court. Mailed notice (lc) (Entered: 11/30/2004)
7 REFERRAL ORDER: Case referred to Honorable Michael T. Mason for an expedited settlement conference. Mailed notice. (srb) (Entered: 12/22/2004)
8 MINUTE ORDER of 12/14/04 by Hon. Ruben Castillo : Status hearing held and continued to 02/02/05 at 9:45a.m. Parties to make disclosures pursuant to F.R.Civ.P. 26(A)(1) no later than 12/31/04. Discovery cut−off date set on 03/30/05. This case is referred to Magistrate Judge Michael Mason for an expedited settlement conference. Mailed notice (lc) (Entered: 12/23/2004)
9 JOINT MOTION by defendant to terminate referral to Magistrate for settlement conference ; Notice (las) (Entered: 01/14/2005)
11 MINUTE entry before Judge Ruben Castillo: Joint Motion by defendant to terminate referral to Magistrate for Settlement Conference 9 is withdrawn. (srb,) (Entered: 02/02/2005)

Case: 1:04-cv-6063 As of: 05/05/2010 05:58 PM CDT 3 of 5

02/01/2005
02/22/2005
02/23/2005
03/22/2005 03/22/2005
04/01/2005 04/01/2005
04/04/2005 04/04/2005 05/12/2005 05/26/2005 06/01/2005 06/01/2005
06/01/2005 06/01/2005 06/02/2005 06/08/2005

10 MINUTE entry before Judge Michael T. Mason : Settlement Conference set for 2/22/2005 at 09:30 AM in courtroom 2214. Parties are to strictly abide by this Court's Standing Order for Settlement Conference, a copy of which is enclosed. Plaintiff's counsel to submit copies of both plaintiff's settlement demand letter and defendant' response letter to the courtroom deputy, room 2220, by 2/17/05. Notices mailed by judge's staff (kef, ) (Entered: 02/01/2005)
12 MINUTE entry before Judge Michael T. Mason : Settlement conference held on 2/22/2005. Parties were not able to reach an agreement to settle the case at this time. All matters relating to the referral of this case having been resolved, the referral is closed and the case is returned to the assigned judge. Judicial staff mailed notice (kef, ) (Entered: 02/22/2005)
13 MINUTE entry before Judge Ruben Castillo: Status hearing held on 2/23/2005 and continued to 6/14/2005 at 9:45 A.M. Discovery cut−off is extended to 4/29/2005. Dispositive Motions to be filed by 6/1/2005. Mailed notice by judge's staff. (srb,) (Entered: 02/24/2005)
14 JOINT MOTION by Plaintiff Equal Employment Opportunity Commission for entry of agreed protective order (gma, ) (Entered: 03/22/2005)
15 NOTICE of Motion by Laurie S. Elkin for presentment of JOINT MOTION by Plaintiff Equal Employment Opportunity Commission for entry of agreed protective order 14 before Honorable Ruben Castillo on 3/30/2005 at 09:45 AM. (gma, ) (Entered: 03/22/2005)
16 JOINT MOTION by Plaintiff Equal Employment Opportunity Commission for entry of agreed protective order (gma, ) (Entered: 04/01/2005)
17 NOTICE of Motion by Laurie S. Elkin for presentment of JOINT MOTION by Plaintiff Equal Employment Opportunity Commission for entry of agreed protective order 16 before Honorable Ruben Castillo on 4/6/2005 at 09:45 AM. (gma, ) (Entered: 04/01/2005)
18 MINUTE entry before Judge Ruben Castillo : Parties joint motion for entry of agreed protective order [14, 16] is granted. Enter Agreed Protective Order. Mailed notice (lxs, ) (Entered: 04/06/2005)
19 AGREED PROTECTIVE Order Signed by Judge Ruben Castillo on 4/4/2005: Mailed notice (lxs, ) (Entered: 04/06/2005)
20 MINUTE entry before Judge Ruben Castillo : Status hearing reset to 6/9/2005 at 10:00 AM. Status hearing set for 6/14/05 is vacated. Judicial staff mailed notice (rao, ) (Entered: 05/12/2005)
21 STIPULATION by parties to dismiss the racial harrassment claim. (lcw, ) (Entered: 06/01/2005)
22 MOTION by Defendant Law Bulletin Publishing Company for summary judgment (gma, ) (Entered: 06/02/2005)
23 NOTICE of Motion by Law Bulletin Publishing Company for presentment of MOTION by Defendant Law Bulletin Publishing Company for summary judgment 22 before Honorable Ruben Castillo on 6/9/2005 at 09:45 AM. (gma, ) (Entered: 06/02/2005)
24 MEMORANDUM by defendant in support of MOTION by Defendant Law Bulletin Publishing Company for summary judgment 22 (gma, ) (Entered: 06/02/2005)
25 RULE 56.1(a) STATEMENT by defendant of material facts (gma, ) (Entered: 06/02/2005)
26 MINUTE entry before Judge Ruben Castillo: Plaintiff's racial harassment claim is voluntarily dismissed with prejudice. Mailed notice (lcw, ) (Entered: 06/03/2005)
28 SUMMARY of Revelant Dates and Events by Equal Employment Opportunity Commission; Notice. (lcw, ) (Entered: 06/13/2005)

Case: 1:04-cv-6063 As of: 05/05/2010 05:58 PM CDT 4 of 5

06/09/2005
06/27/2005 06/28/2005 07/01/2005 07/01/2005 07/06/2005 07/08/2005
07/12/2005 07/12/2005 07/12/2005 07/14/2005
07/14/2005 07/14/2005 08/11/2005 08/11/2005 08/15/2005

27 MINUTE entry before Judge Ruben Castillo : Defendant's motion for summary judgment 22 is denied for the reasons stated in open court. Status hearing held on 6/9/2005 and continued to 7/7/2005 at 9:45 a.m. Jury trial set for 7/18/2005 at 10:00 a.m. Parties to submit a modified pretrial order which includes a list of agreed and contested witnesses, a list of agreed and contested trial exhibits and any motions in limine by 7/1/2005. Parties to submit their jury instructions on 7/18/2005. Judicial staff mailed notice (rao, ) (Entered: 06/09/2005)
29 STIPULATION by parties that the cause may be dismissed. (lcw, ) (Entered: 06/29/2005)
30 SUBSTITUTION of Counsel by defendant; Notice.(lcw, ) (Entered: 06/30/2005)
31 MOTION by defendant in limine to bar plaintiff from asserting costructive discharge; Notice. (lcw, ) (Entered: 07/07/2005)
32 MODIFIED Final Pretrial Order by defendant; Notice.(lcw, ) (Entered: 07/07/2005)
34 MEMORANDUM by defendant in Support of it's objections to certain exhibits and in opposition to plaintiff's objections to certain exhibits; Notice. (Exhibits) (lcw, ) (Entered: 07/08/2005)
33 MINUTE entry before Judge Ruben Castillo : Status hearing held. Plaintiff's response to defendant's motion in limine to bar plaintiff from asserting constructive discharge 31 and response to defendant's objections to plaintiff's exhibits are due before 12:00 p.m. on 7/12/2005. Defendant's replies will be due before 12:00 p.m. on 7/14/2005. Final Pretrial Conference set for 7/14/2005 at 03:30 PM. Judicial staff mailed notice (rao, ) (Entered: 07/08/2005)
35 RESPONSE by plaintiff Equal Employment Opportunity Commission to defendant's motion in limine to bar plaintiff from asserting constructive discharge 31 ; Notice. (Exhibits) (lcw, ) (Entered: 07/14/2005)
36 RESPONSE by plaintiff Equal Employment Opportunity Commission to defendant's objections to certain exhibits and in support of plaintiff's objections to certain exhibits; Notice. (lcw, ) (Entered: 07/14/2005)
37 MEMORANDUM by defendant Law Bulletin Publishing Company in Opposition to plaintiff's objections to defendant's proposed Exhibit No. 5; Notice. (lcw, ) (Entered: 07/14/2005)
38 MINUTE entry before Judge Ruben Castillo : Final settlement conference held in chambers. Full binding settlement reached on the record. This case is dismissed without prejudice subject to the entry of an appropriate consent decree which will be fully enforced by the Court. Trial set for 7/18/2005 is hereby vacated. Any pending motions are denied as moot. Civil case terminated. Judicial staff mailed notice (rao, ) (Entered: 07/15/2005)
39 REPLY by defendant in support of its objections to certain exhibits; RESPONSE to plaintiff EEOC's objections to certain exhibits; Notice. (Exhibits) (lcw, ) (Entered: 07/18/2005)
40 REPLY by defendant to plaintiff EEOC's response to defendant's motion in limine to bar plaintiff from asserting constructive discharge; Notice. (Exhibits)(lcw, ) (Entered: 07/18/2005)
41 AGREED MOTION by Plaintiff Equal Employment Opportunity Commission for entry of consent decree (gma, ) (Entered: 08/11/2005)
42 NOTICE of Motion by Laurie S. Elkin for presentment of AGREED MOTION by Plaintiff Equal Employment Opportunity Commission for entry of consent decree 41 before Honorable Ruben Castillo on 8/16/2005 at 09:45 AM. (gma, ) (Entered: 08/11/2005)
43 MINUTE entry before Judge Ruben Castillo: Parties' agreed Motion for entry of consent decree 41 is granted. Enter Consent Decree. The parties do not have to appear for the motion call on 8/16/05. Mailed notice (lcw, ) (Entered: 08/17/2005)

Case: 1:04-cv-6063 As of: 05/05/2010 05:58 PM CDT 5 of 5

08/15/2005

44 CONSENT DECREE Signed by Judge Ruben Castillo on 8/15/2005.(lcw, ) (Entered: 08/17/2005)