Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 1 of 6

BRETT L. TOLMAN, U.S. Attorney (#8821) STEPHEN J. SORENSON, Assistant U.S. Attorney (#3049) Attorneys for the United States of America 185 South State Street, #400 Salt Lake City, Utah 84111 Telephone: (801) 524-5682 Email: Stephen.Sorenson@usdoj.gov Associated Local Counsel
Mary Jo O’Neill AZ #005924 (Pro Hac Vice) Sally C. Shanley AZ#012251 (Pro Hac Vice) Valerie L. Meyer CA #228586 (Pro Hac Vice) EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Phoenix District Office 3300 North Central Avenue, Suite 690 Phoenix, Arizona 85012 Telephone: (602) 640-5032 Email: mary.oneill@eeoc.gov
sally.shanley@eeoc.gov valerie.meyer@eeoc.gov
Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff, vs.
REID SCHOOL, INC.,

Case No. 2:06CV831 TC COMPLAINT AND JURY DEMAND

Defendant.

NATURE OF 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, against Defendant Reid School, Inc., to correct unlawful -1-

Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 2 of 6
employment practices on the bases of sex and pregnancy, and to provide appropriate relief to Tawna Pippin, who was adversely affected by such practices. The Equal Employment Opportunity Commission, (“EEOC” or “Commission”), alleges that Defendant discharged and/or failed to hire Ms. Pippin because of her sex and pregnancy
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 Sections 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, (“Title VII”), 42 U.S.C. §§ 2000e-5(f)(1) and (3), and Section 102 of the Civil Rights Act of 1991, 42 U.S.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 District of Utah.
PARTIES 3. Plaintiff, the EEOC, 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(f)(1) of Title VII, 42 U.S.C. § 2000e5(f)(1). 4. At all relevant times, Defendant Reid School, Inc. has continuously been and is now doing business in the State of Utah, and has continuously had at least fifteen
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Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 3 of 6
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).
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Tawna Pippin filed a charge with the Commission alleging violations of Title VII by the Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least March 2002, Defendant has engaged in unlawful employment practices in Salt Lake City, Utah, in violation of Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a). Defendant terminated and/or failed to hir Tawna Pippin because of her sex and pregnancy. 8. The effect of the practices complained of above has been to deprive Tawna Pippin of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex and pregnancy. 9. The unlawful employment practices complained of in paragraphs 7-8 above were intentional. 10. The unlawful employment practices complained of in paragraphs 7-8 above were done with malice or with reckless indifference to the federally protected rights of Tawna Pippin.
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Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 4 of 6
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendant, Reid School, Inc., its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the bases of sex or pregnancy. B. Order the Defendant, Defendant Reid School, Inc. to institute and carry out policies, practices and programs which provide equal employment opportunities for female and pregnant applicants and employees, and which eradicate the effects of its past and present unlawful employment practices. C. Order the Defendant, Reid School, Inc., to make whole Tawna Pippin by providing appropriate 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, including but not limited to rightful place reinstatement or front pay. D. Order the Defendant, Reid School, Inc., to make whole Tawna Pippin by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 7-10 above, including but not limited to costs incurred for obtaining subsequent employment and relocation expenses, in amounts to be determined at trial. E. Order the Defendant Reid School, Inc., to make whole Tawna Pippin, by
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Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 5 of 6
providing compensation for past and future nonpecuniary losses resulting from the unlawful employment practices described in paragraphs 7-10 above, including but not limited to, pain and suffering, mental anguish, humiliation, embarrassment, emotional distress, anxiety, inconvenience, and loss of enjoyment of life, in amounts to be determined at trial.
F. Order the Defendant, Reid School, Inc., to pay Tawna Pippin punitive damages for its malicious conduct or reckless indifference described and referenced in paragraphs 7-10 above, in amounts to be determined at trial.
G. Grant such further relief as the Court deems necessary and proper in the public interest.
H. Award the Commission its costs in this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
RESPECTFULLY SUBMITTED this 27th day of September, 2006.
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Case 2:06-cv-00831-TC Document 2 Filed 10/02/06 Page 6 of 6

Brett L. Tolman United States Attorney
s/Stephen J. Sorenson Stephen J. Sorenson Civil Chief
UNITED STATES ATTORNEY 185 S. State #400 Salt Lake City, Utah 84111
Associated Local Counsel for Plaintiff

Ronald S. Cooper General Counsel
James L. Lee Deputy General Counsel
Gwendolyn Young Reams Associate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 1801 L Street, N.W. Washington, D.C. 20507
s/ Mary Jo O’Neill Mary Jo O’Neill Regional Attorney
s/Sally C. Shanley Sally C. Shanley Supervisory Trial Attorney
s/Valerie L. Meyer Valerie L. Meyer Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Phoenix District Office 3300 N. Central Ave., Suite 690 Phoenix, Arizona 85012
Attorneys for Plaintiff

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 Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 1 of 14

U.S

FILED O:STiW:T

C(JUR

r

lD~3 ~AR ?1 A II: 52
2
DISTRICT OF GrAil
3

4

5

6

7

8
IN THE UNITED STATES DISTRICT COURT
9
DISTRICT OF UTAH, CENTRAL DIVISION

\0
11 EQUAL EMPLOYMENT 12 OPPORTUNITY COMMISSION,

a: ep(q c:.." S3\ "TL
Cl.'96 99831 Te

CONSENT DECREE

13

Plaintiff,

14

vs.

15 REID SCHOOL, INC.,
16
Defendant.
17

18

\9
The United States Equal Employment Opportunity Commission (the
20
"Commission") filed this action against Reid School, Inc., under Title VII of the Civil
21
Rights Act of 1964,42 U.S.C. §2000e et seq. (Title VII) and the Civil Rights Act of
22
1991,42 U.S.C. §1981a to correct alleged unlawful employment practices on the bases 0
23
sex and pregnancy and to provide appropriate relief to Tawna Pippin, who allegedly was
24
adversely affected by such practices. The Commission alleged that Reid School, Inc.
25
discriminated against Ms. Pippin by failing to hire and/or discharging her because of her
26
pregnancy. Reid School denies these allegations.
27
28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 2 of 14

The Parties do not object to the jurisdiction of the Court over this action and waive

2 their rights to a hearing and the entry offmdings offact and conclusions oflaw. The

3 parties agree that this Consent Decree is fair, reasonable, and equitable and does not

4 violate the law or public policy.

5

In the interest of resolving this matter, and as a result ofhaving engaged in

6 comprehensive settlement negotiations, the Parties agree that this action should be fmally

7 resolved by entry of this Decree. This Consent Decree shall not constitute an

8 adjudication and/or a fmding on the merits of the Lawsuit.

9

It is ORDERED, ADJUDGED AND DECREED:

10

1. This Decree resolves all claims arising out of the issues between the

II Commission and Defendant Reid School, Inc. ("Reid School" or "Defendant") in this

12 lawsuit, including without limitation, back pay, compensatory and punitive damages,

13 injunctive relief, costs and attorney's fees.

14

2. This Decree conforms with the Federal Rules of Civil Procedure and Title

15 VII and is not in derogation of the rights and privileges of any person. The entry of this

16 Consent Decree will further the objectives of Title VII and will be in the best interests of

17 the Commission, Tawna Pippin, Reid School, and the public.

18

3. This Decree, and any provision herein regarding Reid School, applies to

19 Reid School and to its officers, agents, employees, successors, and assigns.

20

INJUNCTION

21

4. Defendant and its officers, agents, employees, successors, and assigns both

22 at the time that this Decree becomes effective and for the duration of this Decree, are

23 enjoined from: (a) discriminating against any employee on the bases of sex and/or

24 pregnancy, including refusing to rehire and/or terminating an employee; (b) altering the

25 terms and conditions of any employee's employment because of pregnancy; and (c)

26 retaliating against any employee because he or she: (i) opposes or opposed discriminatory

27 practices made unlawful by Title VII; (ii) files or filed a charge of discrimination or

28 assists, assisted, participates, or participated in the filing of a charge of discrimination; or

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 3 of 14

I (iii) assists, assisted, participates or participated in an investigation or proceeding brought

2 under the Federal or State laws prohibiting discrimination or retaliation.

3

MONETARY RELIEF

4

5. Defendant shall pay the amount of $34,500. The payment shall be made

5 directly to Tawna Pippin by check or money order at the address provided by the EEOC.

6 This payment represents settlement of compensatory damages. Defendant shall make no

7 deductions from this amount. The compensation is to be paid within fifteen (15) calend

8 days ofthe entry of this Consent Decree. By January 31, 2009, Defendant shall issue

9 United States Internal Revenue Service Fonn 1099 to Ms. Pippin for the payment.

\0

6. Within 5 business days of the date the check or money order is placed in

11 themail pursuant to this Consent Decree, a copy of the check will be furnished to the

12 Regional Attorney, Equal Employment Opportunity Commission, Phoenix District

\3 Office, 3300 North Central Avenue, Suite 690, Phoenix, Arizona 85012.

14

7. Defendant will not condition the receipt of monetary relief on Ms. Pippin's

15 agreement to: (a) maintain as confidential the tenns of this Decree; or (b) waive her

16 statutory right to file prospectively a charge with any federal or state anti-discrimination 17 agency; or (c) refrain from reapplying for ajob with Defendant..

18

OTHER RELIEF

19

8. Defendant will institute and carry out policies and procedures that help

20 assure a work enviromnent free from sex discrimination (including pregnancy 21 discrimination) for its employees and that allow employees to raise concerns or

22 complaints without retaliation about matters made unlawful by Title VII (whether

23 alleged, perceived or actual).

24

9. . Defendant will post the Notice contained in the attached Attachment A.

25 The Notice will be posted in an appropriate place frequented by employees, for the

26 duration of this decree. The Notice shall be the same type, size, and style as Attachment

27 A.

28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 4 of 14

10_ Dr_ Ethna Reid shall attend a course, seminar or training session on

2 awareness of sex discrimination, with particular emphasis on forms of pregnancy

3 discrimination.

4

a. Defendant will arrange for and be fmancially responsible for the

5

course, seminar, or training session.

6

b. The course, seminar, or training session selected shall be subject to

7

approval by the Commission, which shall not be unreasonably withheld.

8

c. The training shall be at least two (2) hours in length, including

9

twenty (20) minutes for questions and answers.

10

d. The training shall be completed within sixty (60) days of entry of

II

this consent decree.

12

e. The training shall focus on sex discrimination, including

13

discrimination on the basis of pregnancy. The training shall cover typical

14

manifestations of pregnancy discrimination in the workplace at both the

15

application and employment phases; common challenges faced by pregnant

16

women in the workplace; legal obligations of employers of pregnant employees;

17

and informational resources available to employers with pregnant employees.

18

11. To assist Defendant in maintaining compliance in.the area of anti-

19 discrimination and equal employment opportunity, within 30 (thirty) days of the entry of

20 the Decree, Defendant will select, subject to approval of the EEOC, an appropriate and

21 qualified employee or appropriate and qualified third-party administrator to be

22 responsible for the duties described in Paragraph 12. The EEOC shall notifY Defendant

23 within fourteen (14) days whether or not it approves of Defendant's choice. If Defendant

24 selects one of its employees rather than a third-party administrator, the EEOC may

25 condition its approval of the selectee upon the selectee's completion of additional trainin

26 on pregnancy discrimination and the provisions of Title VII. In the event that the EEOC

27 and Defendant are unable to agree on the selection of an employee or third-party

28 administrator, they may each submit the names and curriculum vitae of not more than

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 5 of 14

two proposed employees or third-party administrators, and the Court will make the

2 selection. The EEOC consents to Reid School's selection of McKay, Burton & Thurman

3 should Reid School select it as the third-party administrator.

4

12. The employee or third-party administrator selected pursuant to Paragraph

5 11 shall be responsible for: (a) creating and implementing, and/or reviewing and

6 revising, Defendant's anti-discrimination policies; (b) creating and implementing, and/or

7 reviewing and revising, Defendant's procedures with respect to responding to and

8 keeping records regarding complaints received; (c) receiving and investigating

9 complaints of discrimination; (d) evaluating and, if appropriate, referring employees to

10 Defendant for discipline or termination for violation of Defendant's anti-discrimination

11 policies; and (e) preparing reports to the Commission, as required by this Decree.

12

13. Defendant will provide training on sex discrimination, including

13 discrimination on the basis of pregnancy, and retaliation, according to the following

14 terms:

15

a. Defendant will arrange for and be fmancially responsible for a

16

consultantllecturer(s) who will provide consultation and a training session for all

17

of its employees. The training session(s) shall be provided jointly by the

18

consultantllecturer(s).

19

b. The seminar training session shall be at least two (2) hours in length,

20

including thirty (30) minutes for questions and answers. All of Defendant's

21

supervisory, management and non-supervisory employees shall attend the seminar

22

sessIOn.

23

c. Defendant shall keep a written record of all employees who attend

24

the training. Defendant may at its election have duplicative sessions to

25

accommodate staffing needs or videotape the training session. Defendant shall be

26

responsible for any additional costs to provide such duplicative or videotaped

27

sessIOns.

28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 6 of 14

d. The seminar-training session shall be held within five months of the

2

entry ofthe consent decree.

3

e. All personnel, designated in Paragraphs 13(a) and (b) above, shall

4

both register for and attend the seminar-training session or view a videotape ofthe

5

session. The registry of attendance shall be retained by Defendant for the duration

6

of the Decree.

7

f. The training will include the subject of what constitutes pregnancy

8

discrimination, as well as retaliation for engaging in protected activity under Title

9

VII. In addition, the training will cover the myths and stereotypes often associated

10

with the ability of pregnant women to work. The training will also cover

11

discrimination in the hiring, firing, compensation, assignment or other terms,

12

conditions or privileges of employment; the prevention of discrimination; how to

13

provide a work environment free from discrimination, harassment and retaliation;

14

and to whom and by what means employees may complain if they feel they have

15

been subjected to discrimination, harassment or retaliation in the workplace. The

16

session shall also review and explain Defendant's anti-discrimination policies.

17

14. During the live training session(s), the consultant/lecturers will speak to the

18 employees about the discipline that can be taken against supervisors, managers and

19 employees who commit acts of discrimination, harassment or retaliation or allow

20 discrimination, harassment or retaliation to occur in the workplace; the importance of

21 maintaining an environment free of discrimination; and Defendant's anti-discrimination

22 policies. The Commission, at its discretion, may designate representatives to attend the

23 seminar training sessions. The representatives shall have the right to participate in the

24 sessions.

25

15. Within sixty (60) days of the entry of this Decree, Defendant will create

26 and implement, if such policies do not already exist, written policies concerning

27 discrimination and retaliation that conform with the law. Defendant's written policies

28 must include, at a minimum:

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 7 of 14

a. A strong and clear commitment to a workplace free of sex

2

discrimination, including discrimination on the basis of pregnancy;

3

b. A clear and strong encouragement ofpersons who believe they have

4

been discriminated against to come forward;

5

c. A description of the consequences, up to and including termination,

6

that will be imposed upon violators of the policy;

7

d. A statement of Defendant's intent to handle complaints of sex

8

discrimination, including pregnancy discrimination, as confidentially as

9

appropriate under the circumstances;

10

e. An assurance of non-retaliation for persons who believe they have

11

been discriminated against and for witnesses of discrimination;

12

f. That discrimination on the basis of sex, including pregnancy, by

\3

anyone, including management officials, supervisors, vendors, suppliers, third

14

parties and customers, is prohibited and will not be tolerated;

15

g. The identification of specific alternative individuals, including

16

managers with their telephone numbers, to whom employees who have been

17

subjected to sex discrimination, including pregnancy discrimination, can report the

18

discrimination and who have the authority to investigate allegations of

19

discrimination in a neutral and confidential marmer;

20

h. A written statement that an employee may report the harassment to a

21

designated person outside of his or her chain of management should the

22

complainant believe managers in the chain of command have a conflict of interest,

23

are implicated in the allegations, or may not adequately investigate the complaint;

24

and

25

I. Assurances that Defendant will investigate allegations of sex

26

discrimination, including pregnancy discrimination, promptly, fairly, reasonably

27

and effectively by appropriate investigators and that appropriate corrective action

28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 8 of 14

will be taken by Defendant to make victims whole and to eradicate the

2

discrimination.

3

16. These policies shall be posted in a location frequented by employees at

4 Defendant's facilities in Utah. These policies shall be transmitted to Defendant's

5 employees by its CEO and distributed to each current employee within sixty (60) days of

6 the entry of the Decree. These policies shall be distributed to all new employees when

7 hired. These policies also shall be posted in a prominent place frequented by Defendant's

8 employees. Defendant shall make these written policies available in alternative formats

9 necessary for persons with cognitive and print disabilities that may prevent them from

\0 reading the policies. Alternative formats will include but not be limited to an audiotape

11 format.

12

17. Defendant shall promptly and appropriately investigate all complaints of

13 sex discrimination, including discrimination on the basis of pregnancy. The investigation

14 should include a finding of whether discrimination occurred, a credibility assessment;

15 interviews of all potential victims and witnesses identified; and concurrent notes of the

16 investigation. Defendant shall take immediate appropriate corrective action to make

17 discrimination victims whole, to discipline violators and to eradicate the discrimination.

18

18. Defendant shall not retain documents related to the investigation in any of

19 the complainant's personnel files. All disciplinary actions taken against employees for

20 violation of Defendant's policy will be retained in the violator's personnel file. In those

21 cases in which no conclusion could be reached on the allegations, the investigation

22 documents shall remain in the alleged violator's file.

23

REFERENCES

24

19. Within fourteen (14) days of the entry of the Decree, Defendant shall

provide Ms. Pippin with the written employment reference attached hereto as Attachment
25

26 B and shall provide a copy of Attachment B whenever an employment reference is

requested by the prospective employer of Ms. Pippin.
27
II
28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 9 of 14

REPORTING BY DEFENDANT AND ACCESS BY EEOC

2

20. Defendant, or its representative, shall report in writing to the Regional

3 Attorney ofthe Commission's Phoenix District Office at 3300 N. Central Ave., Suite 690,

4 Phoenix, Arizona 85012, beginning six months from the date of the entry of this Decree,

5 and thereafter every six months for the duration of the Decree the following information:

6

a. Any changes, modifications, revocations, or revisions to its policies

7

and procedures which concern or affect the subject of sex discrimination,

8

including pregnancy discrimination, and retaliation.

9

b. The name, address, position, and telephone number of any individua

\0

who has brought allegations of discrimination and/or retaliation against

11

Defendant's personnel, formal or informal, including, but not limited to,

12

management officials, vendors, agents, employees and/or customers, during the

\3

six months preceding the report. The nature of the complaint, investigatory efforts

14

made by Defendant and the corrective action taken, if any, shall be specified.

IS

c. The registry of persons attending the seminar(s) required in

16

Paragraph 13(e) of this Decree and a list of current personnel employed by

17

Defendant on the days of the seminar-training sessions.

18

d. Confirmation that: (i) the Notice required in Paragraph 9 of this

19

Decree was posted and the location(s) where it was posted; and (ii) the policies

20

required in Paragraph IS were distributed to each current and new employee and

21

posted.

22

21. The Commission, upon reasonable notice, shall have the right to enter and

23 inspect Defendant's premises to ensure compliance with this Decree.

24

CERTIFICATION OF COMPLIANCE

25

22. Defendant, or its representative, will report in writing to the Commission

26 on a semi-annual bases within six (6) months from the entry of this Decree. The

27 certification shall state that Defendant has taken the action required with each and every

28 provision of this Consent Decree.

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"Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 10 of 14

23. The duration of this Decree shall be thirty-six (36) months from the date of 2 its entry.

3

24. The parties shall bear their own attorneys' fees and costs incurred in this

·4 action up to the date of entry of this Decree.

5

25. This Court shall retain jurisdiction of this action for a period of thirty-six

6 (36) months after entry of the Decree. This Decree shall expire by its own terms at the

7 end of thirty-six (36) months after entry of the Decree, without further action by the

8 parties or the Court.

9

26. The Commission may petition this Court for compliance with this Decree at

JO any time during which this Court maintains jurisdiction over this action. If the

I I Commission determines that the Defendant has not complied with the Consent Decree,

12 the Commission will provide written notification of the alleged breach to the Defendant

13 and will not petition the Court for enforcement sooner than thirty (30) days after

14 providing written notification. If the Commission petitions the Court and the Court finds

15 the Defendant to be in violation of the terms of the Decree, the Court may extend this

16 Consent Decree or order other appropriate relief as may be necessary to remedy

17 Defendant's non-compliance. At the end of thirty-six (36) months, this lawsuit will be

18 dismissed with prejudice, provided that the Defendant has complied with the terms of this

19 Consent Decree.

20

27. The parties agree to the entry of this decree subject to final approval by the

21 Court.

22

.2 (, 23 DATED this

day ~ltAPf2008.

24

25

26

27

28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 11 of 14

APPROVED AND CONSENTED TO:

2
3~~~~
4 Mary~~01lS
5 Re 'onal Attorn~

6 P~~~~~~"-I

Sally c. ey

7 Supervisory Trial Attorney

8 ~A1~<{1o.J D{

9 Valerie L. ttyer

<tJ 1<5'

10 Trial Attorney

EQUAL EMPLOYMENT

11 OPPORTUNITY COMMISSION

12. Phoenix District Office

Suite 690

13 3300 North Central Avenue

14 Phoenix, Arizona 85012

(602) 640-4988

15 Attorneys for Plaintiff

16

17

18
Bruce Boehm 19 McKay Burton & Thunnan

20 170 South Main Street, Suite 800
Salt Lake City, UT 84lOi 21 Attorneys for Defendant

22

I.

. 23 t~~
24 ;:_.:t~' ddSchool~
2S P.·.....a-

26

27

28

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Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 12 of 14

ATTACHMENT A

NOTICE TO ALL EMPLOYEES OF REID SCHOOL, INC

This notice is posted pursuant to a consent decree entered into in case EEOC v. Reid School, Inc, CIV-06-0083l-TC under Title VII ofthe· Civil Rights Act of 1964.

It is unlawful under federal law (Title VII ofthe Civil Rights Act of 1964) and state law to discriminate against an employee on the basis of pregnancy. It is also unlawful to retaliate against any person because the person protested discriminatory practices or contacted the EEOC.

Reid School, Inc. will not discriminate against any employee on the basis of pregnancy and will not retaliate against any employee.

If you believe you have been discriminated against by Reid School, Inc., you have the right to seek assistance from:

(1) EEOC, 3300 North Central Avenue, Suite 690, Phoenix, Arizona 85012, (602) 640-5000; or

(2) Utah Antidiscrimination and Labor Division (UALD), 160 East 300 South, 3rd Floor, Salt Lake City, UT 84111, (801) 530-6801 or 1-800-222-1238 or (801) 530-7685 (TDD)

and/or have the right to file a charge with the EEOC or UALD if you believe you are being discriminated against.

No Retaliation Clause. No action may be taken against you by any supervisory or management official of Reid School for (1) opposing discriminatory practices made unlawful by federal law, (2) filing a charge or assisting or participating in the filing of a charge of discrimination, or (3) assisting or participating in an investigation or proceeding brought under state or federal anti-discrimination laws. Should any such retaliatory actions be taken against you, you should immediately contact me and/or the EEOC or the UALD at the address or telephone numbers listed above.

Dated:

EthnaReid Reid School, Inc.

Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 13 of 14
ATTACHMENT B

Case 2:06-cv-00831-TC Document 18 Filed 03/27/08 Page 14 of 14
[Reid School Letterhead] To Whom It May Concern:
This letter will serve to confirm Tawna Pippin's employment with Reid School from July 1999 to May 2002. During this time, Ms. Pippin held the position of preschool teacher. At all times during this period, Ms. Pippin performed her job duties in a competent manner. In addition, Ms. Pippin is eligible for rehire at Reid School.
Sincerely,
Dr. Ethna Reid Reid School

 
 Case: 2:06-cv-00831-TC As of: 04/24/2012 11:21 AM MDT 1 of 3
Electronic Case Filing System District of Utah (Central)
CIVIL DOCKET FOR CASE #: 2:06−cv−00831−TC

CLOSED

Equal Employment Opportunity Commission v. Reid School Assigned to: Judge Tena Campbell Cause: 42:2000 Job Discrimination (Employment)
Plaintiff

Date Filed: 09/29/2006 Date Terminated: 03/27/2008 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Equal Employment Opportunity Commission

represented by Mary Jo O'Neill EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (AZ) PHOENIX DISTRICT OFFICE 3300 N CENTRAL AVE STE 690 PHOENIX, AZ 85012−1848 (602)640−5000 Email: mary.oneill@eeoc.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Stephen J. Sorenson US ATTORNEY'S OFFICE (UT) SALT LAKE CITY, UT 00000 (801)325−3218 LEAD ATTORNEY ATTORNEY TO BE NOTICED

Sally C. Shanley EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (AZ) PHOENIX DISTRICT OFFICE 3300 N CENTRAL AVE STE 690 PHOENIX, AZ 85012−1848 (602)640−5032 Email: sally.shanley@eeoc.gov PRO HAC VICE ATTORNEY TO BE NOTICED

Valerie L. Meyer EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (AZ) PHOENIX DISTRICT OFFICE 3300 N CENTRAL AVE STE 690 PHOENIX, AZ 85012−1848 (602)640−5000 PRO HAC VICE ATTORNEY TO BE NOTICED

V. Defendant Reid School

represented by Bruce J. Boehm MCKAY BURTON &THURMAN 170 S MAIN STE 800 SALT LAKE CITY, UT 84101 (801)521−4135 Email: bboehm@mbt−law.com LEAD ATTORNEY

Case: 2:06-cv-00831-TC As of: 04/24/2012 11:21 AM MDT 2 of 3 ATTORNEY TO BE NOTICED

Date Filed 09/29/2006 10/02/2006 10/02/2006 10/02/2006 10/02/2006 10/02/2006
10/02/2006
10/02/2006
12/19/2006 12/26/2006 03/08/2007 04/10/2007
04/10/2007 04/11/2007

# Docket Text
1 Case has been opened and assigned to Judge Tena Campbell. Plaintiff Equal Employment Opportunity Commission is directed to E−File the Complaint(found under Complaints and Other Initiating Documents) by the end of the business day. Filing Fee waived (USA) (rlr, ) (Entered: 09/29/2006)
2 COMPLAINT against Reid School No Filing Fee, filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet) Assigned to Judge Tena Campbell (Sorenson, Stephen) (Entered: 10/02/2006)
3 MOTION for Admission Pro Hac Vice of Sally C. Shanley (no registration fee required) filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Sorenson, Stephen) (Entered: 10/02/2006)
4 MOTION for Admission Pro Hac Vice of Mary J. O'Neill (no registration fee required) filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Sorenson, Stephen) (Entered: 10/02/2006)
5 MOTION for Admission Pro Hac Vice of Valerie L. Meyer (no registration fee required) filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Sorenson, Stephen) (Entered: 10/02/2006)
6 ORDER granting 4 Motion for Admission Pro Hac Vice of Mary Jo O'Neill for Equal Employment Opportunity Commission. Attorneys admitted Pro Hac Vice may download a copy of the District of Utahs local rules from the courts web site at http://www.utd.uscourts.gov. Signed by Judge Tena Campbell on 10/2/06 (alt) (Entered: 10/03/2006)
7 ORDER granting 3 Motion for Admission Pro Hac Vice of Sally C. Shanley for Equal Employment Opportunity Commission. Attorneys admitted Pro Hac Vice may download a copy of the District of Utahs local rules from the courts web site at http://www.utd.uscourts.gov. Signed by Judge Tena Campbell on 10/2/06 (alt) (Entered: 10/03/2006)
8 ORDER granting 5 Motion for Admission Pro Hac Vice of Valerie L. Meyer for Equal Employment Opportunity Commission. Attorneys admitted Pro Hac Vice may download a copy of the District of Utahs local rules from the courts web site at http://www.utd.uscourts.gov. Signed by Judge Tena Campbell on 10/2/06 (alt) (Entered: 10/03/2006)
9 Defendant Reid School's Answer to Plaintiff's Complaint ANSWER to Complaint filed by Reid School.(Boehm, Bruce) (Entered: 12/19/2006)
10 **RESTRICTED DOCUMENT** SUMMONS Returned Executed by Equal Employment Opportunity Commission as to Reid School served on 12/4/2006, answer due 12/26/2006. (Shanley, Sally) (Entered: 12/26/2006)
11 REPORT OF ATTORNEY PLANNING MEETING. (Shanley, Sally) (Entered: 03/08/2007)
12 SCHEDULING ORDER: Amended Pleadings due by 4/25/2007; Joinder of Parties due by 4/25/2007; Discovery due by 4/25/2008; Motions due by 6/13/2008; Final Pretrial Conference set for 10/27/2008 03:00 PM before Judge Tena Campbell; 3−day Jury Trial set for 11/17/2008 08:30 AM before Judge Tena Campbell. Signed by Judge Paul M. Warner on 4/9/07 (alt) (Entered: 04/10/2007)
13 CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission Initial Disclosure Statement (Shanley, Sally) (Entered: 04/10/2007)
14 CERTIFICATE OF SERVICE by Reid School Defendant Reid School's Initial Disclosures (Boehm, Bruce) (Entered: 04/11/2007)

Case: 2:06-cv-00831-TC As of: 04/24/2012 11:21 AM MDT 3 of 3

07/19/2007 07/20/2007 03/26/2008 03/27/2008

15 Stipulated MOTION for Protective Order filed by Plaintiff Equal Employment Opportunity Commission, Defendant Reid School. (Attachments: # 1 Text of Proposed Order)(Shanley, Sally) (Entered: 07/19/2007)
16 PROTECTIVE ORDER re: confidential information. Signed by Judge Tena Campbell on 7/20/07 (Attachments: # 1 Checklist for Filing Documents Under Seal) (alt) (Entered: 07/25/2007)
17 Joint MOTION for Entry of Judgment /Consent Decree filed by Plaintiff Equal Employment Opportunity Commission, Defendant Reid School. (Attachments: # 1 Text of Proposed Order Consent Decree)(Meyer, Valerie) (Entered: 03/26/2008)
18 CONSENT JUDGMENT/DECREE and injunction against Reid School, granting 17 Joint MOTION for Entry of Judgment /Consent Decree. Defendant to pay $34,500.00 as settlement of compensatory damages. Signed by Judge Tena Campbell on 3/26/08 (alt) (Entered: 03/27/2008)