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FIND IN THE UNITED STATES

DII STRICN T COURTCL U.S 1).cERAK,'Sl3

i

OFFICE ,, :

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

SEP 2 12006

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION ,

JAMES N HATTEN. Clerk By. wqc~ Deputy cl erk

Plaintiff,
V.
AAA PARKING , Defendant .

CIVIL ACTION NO .
1 0 6 C V 22 ? $
COMPLAINT
JURY TRIAL DEMANDE~ D ~ .

COMPLAINT 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 ("Title VII") to correct unlawful employment practices on the basis of religion, and to provide appropriate relief to Ms . Anissa M . Moussa, (Moussa) who was adversely affected by such practices . Moussa was employed by Defendant, AAA Parking, as a cashier at its Atlanta, Georgia location . Moussa, a Muslim, requested a reasonable accommodation from the employer for her sincerely held religious beliefs . However, the employer failed to provide Moussa with a reasonable accommodation and terminated her employment because of her religious beliefs in violation of Title VIA .

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 Section 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U .S.C. § 2000e-5(x(1) and (3) (Title VII), and Section 102 of the Civil Rights Act of 1991, 42 U .S .C . § 1981a . 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Northern District of Georgia, Atlanta Division .
PA RTI ES 3 . Plaintiff, the Equal Employment Opportunity Commission (the "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 th is action by Section 70fi(f)(1) and (3) of Title VII, 28 U .S.C. § 2000e5( f)(1) and (3) . 4. At all relevant times, Defendant AAA Parking (the "Defendant") has continuously been doing business in the State of Georgia and the City of Atlanta and has continuously had at least 15 employees . 5 . At all relevant times, Defendant has continuously been an employer
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engaged in an industry affecting commerce under Section 701(b), (g) and (h) of Title VII, 42 U.S .C . § 2000e(b), (g) and (h) .
STATEMENT OF CLAIMS 6 . More than 30 days prior to the institution of this lawsuit, Moussa filed her charge with the Commission alleging violations of Title VII by Defendant . All conditions precedent to the institution of this lawsuit have been fulfilled .
7 . Since at least October 4, 2005, Defendant has engaged in unlawful employment practices at its Atlanta, Georgia, facility in violation of Section 70b( f) (1) and (3) of Title VII . 28 U .S .C. § 2000e-5(fl(1) and (3), by refusing to provide Moussa with a reasonable accommodation of her religious beliefs, and by terminating her because of her religious beliefs in violation of Title VII .
8. The effects of the practices complained of in paragraph 7 above have been to deprive Moussa of equal employment opportunities and otherwise adversely affect her status as an employee because of her religious beliefs .
9. The unlawful employment practices complained of in paragraph 7 above were intentional .
10. The unlawful employment practices complained of in paragraph 7 above were carried out with malice and/or reckless indifference to the federally protected rights of Moussa.
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PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court : A . Grant a permanent injunction enjoining Defendant , its officer s, successors, assigns and all other persons in active concert or participation with it, from engaging in employment practices which discriminate on the basis of religion by subjecting individuals who request reasonable accommodations to adverse employment actions in violation of Title VII .
B. Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for employees who request reasonable accommodations of their religious beliefs under Title VII, and which eradicate the effects of its past and present unlawful employment practices .
C. Order Defendant to make whole Moussa, who was adversely affected by Defendant's discriminatory conduct, by providing appropriate back pay with prejudgement interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices .
D. Order Defendant to make whole Moussa by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described above, including job search expenses, in amounts to be determined at trial .
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E. Order Defendant to make whole Moussa by providing compensation for non-pecuniary losses resulting from the unlawful employment practices described above, including emotional pain and suffering, inconvenience, loss of enjoyment of life, anxiety, stress, depression, and humiliation, in amounts to be determined at trial .
F . Order Defendant to pay to Moussa punitive damages for Defendant's malicious and reckless conduct described above, in amounts to be determined at trial .
G . Grant such further relief as the Court deems necessary and proper . H . Award the Commission its costs in this action .
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JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its Complaint .
Respectfully submitted, Ronald S . Cooper General Counsel James L. Lee Deputy General Counse l Gwendolyn Young Reams Associate Gf,a 1 Counsel
R'obert K. Dawkins Regional Attorney Michigan Bar No . P38289 S . Robert Royal Senior Trial Attorney Georgia Bar No . 617505 U.S . Equal Employment Opportunity Commission Atlanta District Office 100 Alabama St ., SW, Suite 4R30 Atlanta, Georgia 30303 Telephone: (404) 562-6818 Facsimile : (404) 562-6905
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U.S. District Court Northern District of Georgia (Atlanta) CIVIL DOCKET FOR CASE #: 1:06-cv-02278-JTC

CLOSED

Equal Employment Opportunity Commission v. AAA Parking Assigned to: Judge Jack T. Camp Cause: 42:2000e Job Discrimination (religion)

Date Filed: 09/21/2006 Date Terminated: 06/07/2007 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by S. Robert Royal Equal Employment Opportunity Commission Atlanta District Office-Legal Unit 100 Alabama Street, S.W. 4R30 Atlanta Federal Center Atlanta, GA 30303-8704 404-562-6820 Email: stan.royal@eeoc.gov TERMINATED: 01/26/2007

Suzanne Julia Carelli Equal Employment Opportunity Commission-ATL Atlanta District Office-Legal Unit 100 Alabama Street, S.W. 4R30 Atlanta Federal Center Atlanta, GA 30303-8704 404-562-6842 Email: suzanne.carelli@eeoc.gov ATTORNEY TO BE NOTICED

V. Defendant AAA Parking

represented by Alston Dayton Correll, III Kilpatrick Stockton-Atlanta 1100 Peachtree Street Suite 2800 Atlanta, GA 30309-4530 404-815-5910 Fax: 404-541-3237

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Email: acorrell@kilpatrickstockton.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Courtney B. Thompson Kilpatrick Stockton LLP 1100 Peachtree Street Suite 2800 Atlanta, GA 30309 404-815-6500 Fax: 404-541-4761 Email: cothompson@kilpatrickstockton.com ATTORNEY TO BE NOTICED

Date Filed 09/21/2006
12/13/2006
12/13/2006
12/13/2006 01/10/2007 01/11/2007 01/12/2007 01/12/2007 01/12/2007 01/12/2007 01/22/2007

# Docket Text
1 COMPLAINT with Jury Demand filed. Consent form to proceed before U.S. Magistrate and pretrial instructions provided. , filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(hfm) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 09/25/2006)
2 ANSWER to Complaint by AAA Parking. Discovery ends on 5/14/2007.(Correll, Alston) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 12/13/2006)
3 CERTIFICATE OF SERVICE re 2 Answer to Complaint (Amended) by AAA Parking. Related document: 2 Answer to Complaint filed by AAA Parking,.(Correll, Alston) (Entered: 12/13/2006)
4 NOTICE of Appearance by Courtney B. Thompson on behalf of AAA Parking (Thompson, Courtney) (Entered: 12/13/2006)
5 Guidelines for Discovery and Motion Practice. Signed by Judge E. Clayton Scofield III on 1/9/07. (rsh) (Entered: 01/10/2007)
6 NOTICE of Appearance by Suzanne Julia Carelli on behalf of Equal Employment Opportunity Commission (Carelli, Suzanne) (Entered: 01/11/2007)
7 Initial Disclosures by Equal Employment Opportunity Commission.(Carelli, Suzanne) (Entered: 01/12/2007)
8 Certificate of Interested Persons by AAA Parking. (Thompson, Courtney) (Entered: 01/12/2007)
9 Joint PRELIMINARY REPORT AND DISCOVERY PLAN filed by AAA Parking. (Thompson, Courtney) (Entered: 01/12/2007)
10 Initial Disclosures by AAA Parking.(Thompson, Courtney) (Entered: 01/12/2007)
Clerks Notation re 8 Certificate of Interested Persons - Reviewed by District Judge Jack Camp on 1/22/2007. (ds) (Entered: 01/22/2007)

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01/23/2007 01/26/2007 02/09/2007 02/12/2007 03/13/2007 03/13/2007 03/27/2007 04/09/2007 04/10/2007 04/10/2007 05/22/2007 06/07/2007 06/07/2007

NOTICE of Undeliverable Electronic Mail re: Clerks Notation for LOA/CIP. Mail returned for S. Robert Royal due to no longer employed with the agency. (aar) (Entered: 01/23/2007)
11 NOTICE by Equal Employment Opportunity Commission of Withdrawal of Counsel for Plaintiff (Carelli, Suzanne) (Entered: 01/26/2007)
12 SCHEDULING ORDER and Instructions Regarding Summary Judgment Motions. Signed by Judge E. Clayton Scofield III on 2/7/07. (rsh) (Entered: 02/09/2007)
13 CERTIFICATE OF SERVICE Interrogatory, Request for Production of Documents by Equal Employment Opportunity Commission.(Carelli, Suzanne) (Entered: 02/12/2007)
14 CERTIFICATE OF SERVICE Deposition Notice by Equal Employment Opportunity Commission.(Carelli, Suzanne) (Entered: 03/13/2007)
15 CERTIFICATE OF SERVICE Deposition Notice by Equal Employment Opportunity Commission.(Carelli, Suzanne) (Entered: 03/13/2007)
16 CERTIFICATE OF SERVICE of Discovery Responses by AAA Parking.(Thompson, Courtney) (Entered: 03/27/2007)
17 CERTIFICATE OF SERVICE by AAA Parking.(Thompson, Courtney) (Entered: 04/09/2007)
18 NOTICE to Take Deposition of Valerie Risinger filed by Equal Employment Opportunity Commission (Attachments: # 1 Certificate of Service)(Carelli, Suzanne) (Entered: 04/10/2007)
19 NOTICE to Take Deposition of Angie Howard filed by Equal Employment Opportunity Commission (Attachments: # 1 Certificate of Service)(Carelli, Suzanne) (Entered: 04/10/2007)
20 PROPOSED CONSENT ORDER Consent Decree. (Carelli, Suzanne) (Entered: 05/22/2007)
21 CONSENT DECREE in the amount of $29,500.00 to be paid by dft to Ms. Moussa within 10 days. See decree for further specific directives. Case ordered closed. Signed by Judge Jack T. Camp on 6/5/07. (rsh) (Entered: 06/07/2007)
Civil Case Terminated. Judge E. Clayton Scofield, III terminated from case. (rsh) (Entered: 06/07/2007)

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FILED IN CLERK'S OFFICE U .S .D.C Atlanta

1 1

JUN Q d LOOT

.,a s ~a°r~~=Ers , lark
IN THE UNITED STATES DISTRICT COURT BY, FOR THE NORTHERN DISTRICT OF GE ORGIA
ATLANTA DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,

CIVIL ACTION NO . 1 :06-C V-2278-JTC-ECS

V.
AAA PARKING, D efe nda nt.

CONSENT DECREE This action was instituted on September 21, 2006 by the Equal Employment Opportunity Commission ("EEOC" or the "Commission") against the Defendant AAA Parking, Inc (hereinafter, the "Defendant") pursuant to Title VII of the Civil Rights Act o f 1964, as amended , 42 U. S.C. § 2000e et seq. (hereinafter "Title VII"), and the Civil Rights Act of 1991, 42 U .S.C. § 1981(a), to remedy the alleged wrongful practices identified in the Complaint filed in this action. In its Complaint, the Commission alleged that Anissa Moussa ("Moussa") requested a reasonable accommodation from the Defendant in order to comply with her sincerely held religious beliefs as a Muslim . The Commission further alleged that the Defendant refused to provide Ms . Moussa with a reasonable accommodation, and

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instead, terminated her from her position as cashier at its Atlanta, Georgia facility in violation of Title VII . In its Complaint the Commission also sought make whole relief including, but not limited to, back pay with interest, compensatory and punitive damages, and injunctive and other affirmative relief . The Defendant filed its Answer to the Complaint on December 13, 2006 . In its Answer, the Defendant denied that it had violated Title VII as alleged in the Complaint, and requested that the Court deny any relief to the Commission based on the Complaint .
The parties to this action desire to avoid the additional expense, delay, and uncertainty which would result from the continuance of this litigation, and desire to formulate a plan to be embodied in this Consent Decree which will promote and effectuate the purposes of Title VII . The parties want to conclude fully and finally all claims arising out of the Commission's Complaint and the charges of discrimination filed with the Commission by Ms . Moussa . They enter into this Consent Decree to further the objectives of Title VII and equal employment opportunity. This Consent Decree is not to be deemed or construed to be an admission of liability or wrongdoing by Defendant but constitutes the good faith settlement of a disputed claim .
This Court has jurisdiction over the subject matter of this action and over the
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parties to this action, as the employment practices alleged to be unlawful in the Complaint filed herein occurred within the jurisdiction of the Northern District of Georgia, Atlanta Division .
This Court has reviewed the terms of the proposed Consent Decree in light of the pleadings and the applicable law and regulations, and has approved this Consent Decree as one which will promote and effectuate the purposes of Title VII .
Now, therefore, this Court being fully advised in the premises, it is hereby ORDERED, ADJUDGED, AND DECREED: I. JURISDICTION AND VENUE
Jurisdiction of this Court is pursuant to 28 U.S.C. §§ 451, 1331, 1337, 1343, and 1345. This action is authorized pursuant to Section 7060(1) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U .S .C. § 2000e-5(x(1) and (3), and Section 102 of the Civil Rights Act of 1991 , 42 U.S .C. § 1981(a). II. DISCLAIMER OF VIOLATION
It is understood and agreed that the negotiation, execution, and entry of this Consent Decree by the parties shall not constitute an adjudication or finding on the merits of this case, and shall not be construed as an admission by either party with respect to the claims or defenses asserted in this case . Nothing in this Consent Decree
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shalll be admissible in any other judicial or administrative proceeding for any purpose except to enforce the terms of this Consent Decree . III. N ON-RETALIAT ION PRO VISION
Defendant agrees that it, including its officers, agents, managers, supervisors, successors or assigns, and all those in active concert or participation with it, will not retaliate against any person because that person is a beneficiary of this Consent Decree, or has provided information or assistance, or has participated in any other manner, in any investigation or proceeding relating to this Consent Decree . Defendant agrees that it will not discriminate against any employee for engaging in protected activity under Title VII . Defendant acknowledges its obligation not to retaliate or take any adverse action against any employee or applicant in the future because any such individual has filed a charge or opposed a practice believed to be in violation of Title VII . IV. INSTRUCTION TO MANAGEMENT
Within thirty (30) days from the entry of this Decree, Defendant shall certify, in writing, to the EEOC that all management and supervisory personnel who are currently employed at its Atlanta, Georgia facilities have been instructed as to the terms of this Consent Decree (other than the monetary amount of the settlement), and
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the full meaning of the provisions of the Notice to be posted, and that Defendant has reaffirmed with these employees that employment decisions are not to be made on any basis that is prohibited by Title VII . All written certification required by this Section shall be addressed to Robert K . Dawkins, Regional Attorney, EEOC Atlanta District Office, 100 Alabama Street SW, Suite 4R30, Atlanta, Georgia 30303 . V. TRAINING
During the term of this Consent Decree, the Defendant shall hold at least one training session, the cost of which is to be borne by Defendant, to be attended by every employee (non-supervisory and supervisory employees) assigned to its Atlanta, Georgia facilities on their rights and obligations arising under Title VII , including, but not limited to, the Defendant's obligations under Title VII when making employment decisions regarding religious accommodation . The above referenced training shall be completed within one hundred and twenty (120) days of the entry of this Consent Decree.
The D fendant shall provide written certification to the Commission of training 7
completed pursuant to this Section within fifteen (15) days following completion of training . The certification shall include the name(s) and qualifications of the person(s) providing instruction, names and job titles of attendees, length of training,
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S
training topics, and any other pertinent information about the training . If written materials are utilized, the Commission shall be supplied with a copy prior to the training .
All written notice and certification required by this Section of the Consent Decree shall be addressed and forwarded to Robert K . Dawkins, Regional Attorney, EEOC Atlanta District Office, 100 Alabama Street SW, Suite 4R30, Atlanta, Georgia 30303 . VI. REPORTING REQUIREMENT
Every six (6) months for the duration of this Consent Decree, Defendant shall certify in writing to the Regional Attorney whether any person employed at any of Defendant's Atlanta, Georgia facilities has requested a religious accommodation from management, whether orally or in writing . For each person who has made such a request, the summary report shall state in writing, the following information :
(a) The date of the request(s) ; (b) The specific accommodation that was requested ; (c) The name and title ofthe Defendant official(s) who received the request ; (d) Whether the person's initial accommodation was granted and, if not, the
reason(s) why the Defendant failed to grant his/her initial request;
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(e) What accommodation, if any, was granted by the Defendant in response to the request ; and
(f) I If the Defendant failed to grant any type of accommodation, the reason(s) why the Defendant failed to grant an accommodation .
The required report shall be addressed and forwarded to Robert K . Dawkins, Regional Attorney , EEOC Atlanta District Office , 100 Alabama Street SW , Suite 4R30, Atlanta, Georgia 30303 . VIL REASONABLE ACCOMMODATION POLICY AND PROCEDURES
The Defendant agrees to implement and maintain a written policy and related procedures for reasonably accommodating the sincerely held religious beliefs of its employees that are consistent with Title VII and the relevant caselaw . The written policy and procedures shall cover employees at all of the Defendant's Atlanta, Georgia facilities . The Defendant is to implement the written policy and procedures within thirty (30) days after the entry of this Consent Decree . The Defendant shall provide a copy of its written religious accommodation policy and procedures to the Regional Attorney at the above-referenced address within forty-five (45) days of the entry of this Consent Decree .
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VIII. NOTICES T O BE POSTED Defendant shall post at each of its Atlanta, Georgia facilities the Notice
attached hereto as Exhibit A for thirty-six (36) calendar months immediately following the Court's entry of this Consent Decree . The posting required by this Section shall be conspicuously made in the employee work area(s) so that each employee at the Defendant's Atlanta, Georgia facilities will observe at least one such posting when at the facility . The Defendant shall certify the completion of the posting to the Commission within thirty (30) days from the entry of this Consent Decree. All written certification required by this Section shall be addressed to Robert K. Dawkins, Regional Attorney, EEOC Atlanta District Office, 100 Alabama Street SW, -Suite 4R30, Atlanta, Georgia 30303 .
The Commission shall be allowed to enter upon Defendant's Atlanta, Georgia facilities to confirm the Defendant's compliance with this Section of the Consent Decree. The Commission shall provide the Defendant with ten (10) calendar days notice prior to its entry upon any such facility . Should the Notice become defaced , marred, or otherwise unreadable, Defendant shall ensure that a new, readable copy of the Notice is posted in the same manner as heretofore specified within five (5) business days after learning of the defacement, etc .
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IX. C HARGING PARTY'S INDIVIDUAL RELIEF The Defendant, in settlement of all claims alleged by the Commission in its
Complaint, shall pay Ms. Moussa within ten (10) days of the entry of this Consent Decree the gross amount of $29,500, by two separate checks made payable to her, as follows: one check in the amount of $5,000, minus statutorily required deductions, and one check in the amount of $24,500 for non-wage compensatory damages . The checks will be forwarded to Ms . Moussa at 2300 East Franklin, Apt . 313, Minneapolis, Minnesota 55406 . Ms . Moussa will be responsible for paying income taxes, if any. Within five (5) working days of issuing the checks to Ms . Moussa, the Defendant will mail a copy of the checks to Robert K . Dawkins, Regional Attorney, EEOC Atlanta District Office, 100 Alabama Street SW, Suite 4R30, Atlanta, Georgia 30303 . X. TERM OF DECREE AND PERIOD OF JURISDICTION
This Consent Decree shall continue to be effective and binding upon the parties to this action for a period of thirty-six (36) calendar months immediately following the entry of the Decree, provided that all remedial benefits required hereby have been received or offered prior to its expiration and provided further, that all required reports and certifications are submitted at least thirty (30) days before the expiration
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date of the Consent Decree. If required reports are not submitted within thirty (30) days of the expiration date or if the remedial benefits are not received or offered, the Consent Decree will be automatically extended until these provisions are completed .
Upon the Court's execution and entry of this Consent Decree, this case shall be dismissed with prejudice . However, this Court shall retain jurisdiction over this action for the purposes of clarifying and enforcing this Consent Decree and for any other appropriate or equitable purposes for thirty-six (36) calendar months from the date of entry of this Consent Decree , unless the Court acts or the Commission has, prior to the expiration of said thirty-six (36) calendar month period, moved to enforce compliance with the Consent Decree. If the Court acts or the Commission has moved to enforce compliance with this Consent Decree within this period, this Court shall retain jurisdiction of this action until all issues relating to all such motions which are made during the thirty-six (36) month period have been resolved . At the expiration of the thirty-six (36) month period of jurisdiction, if all obligations have been performed by the parties under this Consent Decree, and no disputes regarding compliance remain unresolved, then the Decree shall operate as an automatic dismissal with prejudice .
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XI. COMPLIANCE OFFICIAL The Defendant has designated its Director of Human Resources to be the
Defendant's Compliance Official who shall be responsible for the Defendant's compliance with this Consent Decree. The Compliance Official is to be responsible for coordinating and overseeing Defendant's compliance with the specific terms of this Consent Decree . XII. PROCEDURE FOR ENFORCING COMPLIANCE
The Commission will attempt to resolve any dispute regarding the enforcement of this Consent Decree by informal mediation and consultation before seeking enforcement through the judicial process . The Commission will notify , in writing by first class mail and facsimile , the Defendant's Compliance Official if it has any reason to believe that any act or omission by Defendant is in violation of the Consent Decree . Defendant shall have thirty (30) days after the receipt of such notification to cure any such alleged deficiency, and to notify the Commission, by written report addressed to the Regional Attorney at the EEOC's Atlanta District Office, of the measures taken to cure the alleged deficiencies .
If upon receipt of Defendant's report, the Commission concludes that the deficiency has not been satisfactorily cured by the Defendant, the Commission shall
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seek to resolve the alleged deficiency through good faith conciliation or mediation . If the alleged deficiency is not resolved within thirty (30) days after the initiation of such good faith conciliation or mediation process, then the Commission may seek enforcement of this Consent Decree through the judicial process .
Nothing in this agreement shall be deemed to prohibit any matter which occurred during the term of this Consent Decree, and which constitutes a dispute as contemplated by this Section , from being fully and completely resolved in the manner described in this Section, even if the term of the Consent Decree expires prior to thirty (30) days after the initiation of good faith conciliation or mediation as set forth in this Section . XIII. OTHER ACTIONS
The Commission shall not commence or prosecute Defendant for any action or other proceeding based upon any claims, demands, causes of action, obligations, damages or liabilities which arose out of Ms . Moussa's claims that she was denied a reasonable religious accommodation and discharged by the Defendant in violation ofTitle VII, as embodied in EEOC Charge Number 110-2006 -00132, which was filed with, and investigated by, the EEOC's Atlanta District Office . This Consent Decree in no way affects the Commission's right to process any pending or future charges
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that may be filed against Defendant in accordance with standard Commission procedures, and to commence and prosecute civil actions pursuant to Section 706(f) of Title VII (or any other statutes enforced by the Commission) on any such charges . Nothing in This Consent Decree shall be construed to limit or reduce Defendant's obligation to fully comply vTi th Title VIT of the Civil Rights Act of 1964, as amended ; the Equal Pay Act of 1963, as amended ; the Age Discrimination in Employment Act of 1967, as amended ; the Americans with Disabilities Act of 1990 ; or the regulations promulgated pursuant thereto . Nothing herein shall preclude the Commission from bringing an action to enforce the provisions of this Consent Decree .
The EEOC and Defendant shall eachb bear their own respective costs and attorney's fees for this action .
The parties hereto and undersigned attorneys of record for the parties in the above-styled action hereby consent to the entry of the foregoing Consent Decree .

Counsel for Plaintiff-

.111 OBERT 1t _'DAWK.tNS
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Regional Attomey I1fich i `~ari Bar Number : P3820
EQUAL EMPLOYMENT OPPORTUNITY CQ%t%!-1ISSION- Atlanta District Office 100 Alabama Street, SW, Su t~ 4R30 A t.I~~nta . ~' -or aia 30303

?~ef~?z~':arlt : Counsel for Defendants :

~o W. Laterwec-, Vice i'r~sidcllt
ALSTON D . COiZR-ILL, Ill' Georgia Bar ?4i zffliE;er: B<>u4()
KILPY-kTRICK STOCKTON, LLP 11(}U Peachtree St .vet, Suite ?x(30 Atlanta, Georgia 30309-4530 Telephou: (404) 815-650 Facsimile : (404) 815-6555

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APPROVED, DC?tiL,, and S1Gi,~LU this -S day of , 210 0 7 .

District Judge U.S. District Court of Georgl.l Northem District o f G eor-*a, Mama Divi sion
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