UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN, SOUTHERN DIVISION

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMSISION
Plaintiff,
-vsSERVICING SOLUTIONS, L.L.C.
Defendant.

Civ. Action No. 02-72791~~
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Honorable George E. Woods U.S. District Court Judge
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~N~ic-ho-la~s-I-nz-e-o------------------" Liliana A. Ciccodicola (P39148)

Acting General Counsel

Attorney for Defendant

Adele Rapport (P44833)

24300 Southfield Road, Ste. 101

Regional Attorney

Southfield, MI 48075

Robert Dawkins (P33519)

(248) 559-8110

Supervisory Trial Attorney

Omar Weaver (P58861)

U.S. EEOC, Detroit District Office

Patrick V. McNamara Bldg.

477 Michigan Avenue, Rm. 865

Detroit, MI 48226

(313) 226-3407

-----------------------------------------------,

STIPULATION OF DISMISSAL

The parties stipulate pursuant to Fed. R. Civ. P. 41 (a)(1 )(ii), that all claims

asserted in this case by Plaintiff U.S. Equal Employment Opportunity

Commission are dismissed with prejudice and that Plaintiff and Defendant shall

bear their own costs and fees.

--

SO STIPULATED
Clw.-12" ,~K By:
VI Nicholas Inzeo
Acting General Ctbunsel Adele Rapport (P44833) Regional Attorney Robert Dawkins (P33519) Supervisory Trial Attorney Omar Weaver (P58861) U.S. EEOC, Detroit District Office Patrick V. McNamara Bldg. 477 Michigan Avenue, Rm. 865 Detroit, MI 48226 (313) 226-3407

Liliana A. Ciccodic a (P39148) Attorney for Defendant 24300 Southfield Road, Ste. 101 Southfield, MI 48075 (248) 559-8110

ORDER

Based on the foregoing Stipulation of the parties,

IT IS HEREBY ORDERED AND ADJUDGED THAT all claims asserted in this

case by Plaintiff U.S. Equal Employment Opportunity Commission are dismissed

with prejudice and that Plaintiff and Defendant shall bear their own costs and

fees.

Dated :_ _::L..:.f_c..:.I_o-=.3_

U.S. District Judge
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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

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EQUAL EMPLOYMENT OPPORTUNITY)

02-72797

COMMISSION,

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Plaintiff,

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CASE NOEORGEE. WOODS

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SERVICING SOLUTIONS, L.L.C.

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HONORABLE

ARLSON

'MAGlS1'RAtE JUDGE C

Defendant.

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COMPLAINT AND JURY

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TRIAL DEMAND
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NATURE OF THE ACTION

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This is an action under Title VII of the Civil Rights Act of 1964 and Tifl.~if;Gtthe CiviF .

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Rights Act of 1991 to correct unlawful employment practices on the basis of Sex;i~:Iii'd to W,ovitle 1

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appropriate relief to Carolyn Pritchard who was adversely affected by such pract~s; Th~JEEOC

alleges that Defendant's Vice President, Joseph AdOljan, subjected Pritchard, who he directly

supervised, to a sexualy hostile work environment, quid pro quo sexual harassment, and demoted

Pritchard when she rejected his request for sex. The Defendant, failed to take reasonable care to

prevent the harassment.

JURISDICTION AND VENUE

I. 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(t)(l) and (3)

and 707(e) of Title VII ofthe Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e-5(t)(I) and

(3) and 42 U.S.C. 2000e-6(e) ("Title VII"), and Section 102 ofthe Civil Rights Act of 1991, 42 U.S.C. § 1981a.

2. The employment practices alleged to be unlawful were and are now being

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committed within the jurisdiction of the United States District Court for the Eastern District of

Michigan, Southern Division.

3. Plaintiff, the Equal Employment Opportunity Commission ("EEOC" or

"Commission"), is the 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) and (3) and 707(e) of Title VII, 42 U.S.C. §§ 2000e-5(f)(I) and (3), and 2000e-

6(e).

4. At all relevant times, Defendant, Servicing Solution, L.L.C. ("Employer"), has

continuously been a corporation doing business in the State of Michigan and the City of

Southfield, and has continuously had at least 15 employees.

5. At all relevant times, Defendant Employer 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. §§ 2000e(b), (g), and (h).

STATEMENT OF CLAIMS

6.

More than thirty days prior to the institution of this lawsuit, Carolyn Pritchard

filed a charge with the Commission alleging violations of Title VII by Defendant Employer. All

conditions precedent to the institution of this lawsuit have been fulfilled.

7. Since June 1997, Defendant Employer has engaged in unlawful employment

practices at its Southfield, Michigan facility, in violation of Section 703(a), 42 U.S.C. § 2000e-

2(a). The Defendant's unlawful employment practices include the following:

a. Sexually explicit and vulgar comments directed at Pritchard by Joseph Adorjan,

Vice President, include the following:

1. Whether she lets her husband suck milk from her breast;

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2. Asking if Pritchard would "get naked" in response to her request to leave work early; 3. Stating to Pritchard that he wished he had seen her in her with the back of her hospital gown open; 4. Following a biopsy, stating to Pritchard he could see her breasts weren't sick anymore; 5. Stating to Pritchard that if an asteroid were headed for Earth, he would throw her down on the desk and "go at it"; b. Demoting Pritchard when she rejected AdOIjan's direct request that she have sex with him. 8. The effect of the pattern and practice of conduct complained of in paragraph 7 above has been to deprive Pritchard of equal employment opportunities and otherwise adversely to affect her status as an employee because of her sex. 9. The unlawful employment practices complained of in paragraph 7 above were and are intentional. 10. As the result ofthe unlawful employment practices, Pritchard has suffered emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life. 11. The unlawful employment practices complained of in paragraph 7 above were and are done with malice or with reckless indifference to the federally protected rights of Pritchard.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers,
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successors, assigns, and all persons in active concert or participation with it, from engaging in sexual harassment and any other employment practice which discriminates on the basis of sex.
B. Order Defendant Employer to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices, including institution of a training program.
C. Order Defendant Employer to make whole Pritchard, and similarly situated individuals by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above in amounts to be proven at trial.
D. Order Defendant Employer to make whole Pritchard, by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7 above in amounts to be proven at trial.
E. Order Defendant Employer to pay Pritchard, punitive damages for its malicious or reckless conduct described in paragraph 7 above, in amounts to be proven at trial.
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Commission its costs of this action.
JURy TRIAL DEMAND
The Commission requests a jury trial on all questions offact raised by its complaint.
Respectfully submitted, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION NICHOLAS INZEO 4

Acting General Counsel
ROBERT DAWKINS (P33519) / Supervisory Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION DETROIT DISTRICT OFFICE Patrick V. McNamara Bldg. 477 Michigan Avenue, Rm. 865 Detroit, Michigan 48226 Telephone: 313/226-670 I
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 CM/ECF - U.S. District Court:mied - Docket Report

https://ecf.mied.uscourts.gov/cgi-bin/DktRpt.pl?237975365686983-L_3...

U.S. District Court Eastern District of Michigan (Detroit) CIVIL DOCKET FOR CASE #: 2:02-cv-72797-GEW

CLOSED, TAC

EEOC v. Svc Solutions L L C Assigned to: Honorable George E Woods Demand: $0 Plaintiff Equal Employment Opportunity Commission
V. Defendant Servicing Solutions, L. L. C.

Date Filed: 07/09/2002 Date Terminated: 02/06/2003 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Adele Rapport Equal Employment Opportunity Commission 477 Michigan Avenue Room 865 Detroit, MI 48226 313-226-5670 Email: Adele.Rapport@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stanley H. Pitts Honigman, Miller, (Detroit) 660 Woodward Avenue Suite 2290 Detroit, MI 48226-3506 313-465-7516 Email: spitts@honigman.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Liliana A. Ciccodicola Firestone Law Firm 30555 Southfield Road Suite 530 Southfield, MI 48076 248-540-2701 Email: lcicco@firestonelaw.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

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CM/ECF - U.S. District Court:mied - Docket Report

https://ecf.mied.uscourts.gov/cgi-bin/DktRpt.pl?237975365686983-L_3...

Date Filed 07/09/2002 08/02/2002 08/02/2002 08/02/2002 08/08/2002 09/09/2002 09/12/2002 09/13/2002 01/17/2003 01/24/2003 02/06/2003

#

Docket Text

1 COMPLAINT, with jury demand (RH) (Entered: 07/10/2002)
2 APPEARANCE for Svc Solutions L L C of attorney Liliana A. Ciccodicola (kb) (Entered: 08/06/2002)
3 ANSWER by Svc Solutions L L C to complaint [1-1]; jury demand (kb) (Entered: 08/06/2002)
4 PROOF of service by Svc Solutions L L C of [3-1], [2-1] (kb) (Entered: 08/06/2002)
5 NOTICE by the court of Rule 16 and Rule 26(f) scheduling consultation (kb) (Entered: 08/09/2002)
6 PROOF of service by plaintiff of attorney appearance (ew) (Entered: 09/10/2002)
7 PROOF of service of Svc Solutions L L C Initial Disclosure (ew) (Entered: 09/12/2002)
8 DISCOVERY plan jointly filed pursuant to Fed. R. Civ. P. 26(f) (dh) (Entered: 09/16/2002)
9 ORDER by Judge George E. Woods, setting settlement conference for 1/30/03 , with proof of mailing. [EOD Date 1/21/03] (RH) (Entered: 01/21/2003)
10 NOTICE by counsel for defendant Svc Solutions L L C of change of address with proof of service (lh) (Entered: 01/27/2003)
11 ORDER by Judge George E. Woods with stipulation dismissing the case with prejudice [EOD Date: 2/7/03 (ew) (Entered: 02/07/2003)

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