Case 3:05-cv-01063 Document 1 Filed 05/24/2005 Page 1 of 6

IN THE UNITED STATES DISTRI FOR THE NORTHERN DISTRICT
DALLAS DIVISION

u.s. DISTRICT COURT
NORTHERNDISTRICfOFTEXAS
COT I FTESMAFyI2LE4D200i .

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

)

RENAISSANCE III ORGANIZATION, )

)

Defendant.

)

)

------------------------------ )

~V.s.D~COURT
Dep ty
CIVIL ACTION NO.
COMPLAINT
S-05CV-I OtiSB
JURY TRIAL DEMAND

NATURE OF THE ACTION This an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I of the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of race and to provide relief to Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals. The Commission alleges that Defendant Renaissance III Organization (hereafter "Defendant"), violated Title VII by subjecting Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor and similarly-situated individuals to a racially hostile work environment.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §451, 1331, 1337, 1343, 1345. This action is authorized and instituted pursuant to Section 706(1)(f) and (3) ofthe 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.

Case 3:05-cv-01063 Document 1 Filed 05/24/2005 Page 2 of 6

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 Northern District of Texas.

PARTIES

3. Plaintiff, Equal Employment Opportunity Commission of (the "Commission"), is

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

enforcement of Title VII of the Civil Rights Act of 1964, as amended and is expressly authorized

to bring this action by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. §2000e-5(f)(1) and (3).

4. At all relevant times, Defendant has continuously been and is now doing

business in the State of Texas and the City of Dallas, and has continuously had at least

fifteen employees.

5. At all relevant times, Defendant has continuously been an employer engaged in

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

(b), (g) and (h).

STATEMENTS OF CLAIMS

6.

More than thirty days prior to the institution ofthis lawsuit, Serita Agnew,

Carolyn Jefferson, Hront Reed, Kenny Scott, and Ursula Traylor filed charges with the

Commission alleging violations of Title VII of the Civil Rights Act of 1964, as amended, by the

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

7. Since at least March 1998, the Defendant has engaged in unlawful

employment practices at its Dallas, Texas, facility in violation of Section 703(a) (1) of Title

VII, 42 U.S.C. §2000e-2(a)(1) by subjecting Serita Agnew, Carolyn Jefferson, Hront Reed,

Kenny Scott, Ursula Traylor, and similarly-situated individuals to a racially hostile work

2

Case 3:05-cv-01063 Document 1 Filed 05/24/2005 Page 3 of 6

environment.

8.

The result of the foregoing practices has been to deprive Serita Agnew, Carolyn

Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals of equal

employment opportunities because of their race, Black.

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 done with malice or with reckless indifference to the federally protected rights of Serita

Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated

individuals.

PRAYER FOR RELIEF

Wherefore, the Commission respectfully requests that this Court:

A. Grant a permanent injunction enjoining the Defendant, its officers, members

of its Board of Directors, successors, assigns, and all persons in active concert or participation

with them, from engaging in any employment practice which discriminates on the basis of race,

or which facilitates, condones or encourages employees to create a racially hostile environment.

B. Order the Defendant to institute and carry out policies, practices, and programs

which provide equal employment opportunities for Serita Agnew, Carolyn Jefferson, Hront Reed,

Kenny Scott, Ursula Traylor, and similarly-situated individuals and eradicate the effects of its

past and present unlawful unemployment practices.

C. Order the Defendant to make whole Serita Agnew, Carolyn Jefferson, Hront Reed,

Kenny Scott, Ursula Traylor, and similarly-situated individuals by providing compensation for

3

Case 3:05-cv-01063 Document 1 Filed 05/24/2005 Page 4 of 6
past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including but not limited to, pain and suffering, humiliation, embarrassment, emotional distress, anxiety, and loss of enjoyment of life, in amounts to be determined at trial.
D. Order the Defendant to pay Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals punitive damages for its malicious conduct or reckless indifference described in paragraphs 7 and 10 above, in amounts to be determined at trial.
E. Grant such further relief as the Court deems necessary and proper in the public interest.
F. 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.
4

Case 3:05-cv-01063 Document 1 Filed 05/24/2005 Page 5 of 6
Respectfully submitted, ERIC S. DREIBAND General Counsel JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel
ROBERT A. CANINO Regional Attorney Oklahoma State Bar No. 011782
TOBY W. COSTAS Supervisory Trial Attorney Texas State Bar No. 04855720
Senior Trial Attorney Texas State Bar No. 24044860 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 Houston, 3rd Floor Dallas, Texas 75202 (214) 253-2764 (telephone) (214) 253-2749 (facsimile)
5

~'i <O~JS44 (Rev 11104)

Case 3:05-cv-01063 Document 1 Filed 05/24/2005

\

CIVIL COVER SHEET

Page 6 of 6

CIV~~~)...e The JS 44
provIded

1~urt

the mformation contamed herein neither replace nor supplement the filIng and service of pleadmgs or other papers as required by law, except as This form, approved by the Judicial Conference of the United States m September 1974, IS required for the use of the Clerk of Court for the purpose

of initt i

I' cket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

(1\1
'\J

LAINTIFFS
u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

U L: \I - DEFENDANTS

-

t:>

RENAISSANCE III ORGANIZATION

3 B

(b) County of Residence of FIrst LIsted Plaintiff
(EXCEPT IN U S PLAINTIFF CASES)

County of ReSIdence of FIrst Listed Defendant
,'_---=:-::::±=;;-;-;;:;j~_:~J (IN U S PLAINTIFF CASES ONLY) CONDEMNATION CASES, USE THE LOCATION OF THE VOLVED

(C) Attorney's (Firm Name, Address, and Telephone Number)

Devika S. Dubey, Senior Trial Attorney (214) 253-2764
EEOC Dallas District Office, 207 S. Houston St. 3rd Fl. II. BASIS OF JURISDICTION (Place an "X" 10 One Box Only)

~I

U S Government Plamtiff

o 3 Federal Question
(U S Government Not a Party)

Citizen of1111s State

N CIPAL P ARTIES(Place an "X" 10 One Box for Plaintiff and One Box for Defendant)

DEF

PTF DEF

01 Incorporated or Pnnclpal Place

04 04

of Busmess In ThIs State

02 U.S. Government Defendant

o 4 DIverSIty
(lnchcate CItIzenshIp of PartIes 10 Item 1Il)

Cmzen of Another State

o 2 0 2 Incorporated and Pnnclpal Place
of Busmess In Another State

o 5 05

CItizen or Subject of a ForeIgn Country

o 3 0 3 ForeIgn Nallon

06 06

IV NATURE OF SUIT (Place an "X" in One Box Only)

CONTRACT
o 110 Insurance

0120 Marine

0

0130 MIller Act

0

o 140 NegotIable Instrument

o 150 Recovery of Overpayment 0

& Enforcement of Judgment

o0151 MedIcare Act 152 Recovery of Defaulted

0

Student Loans

0

TORTS

PERSONAL INJURY 310 Airplane 315 Airplane Product
LIabIlIty
320 Assault, Libel & Slander
330 Federal Employers' LiabIlIty
340 Marine

PERSONAL INJURY
0 362 Personal Injury Med. Malpracllce
0 365 Personal Injury Product Liability
0 368 Asbestos Personal Injury Product LIabilIty
PERSONAL PROPERTY

FORFEITUREIPENALTY
0 610 Agriculture 0 620 Other Food & Drug 0 625 Omg Related SeIzure
of PropertY 21 USC 881
0 630 Liquor Laws 0 640 R.R. & Truck 0 650 Airline Regs 0 660 Occupational
SafetylHealth

o (Excl Veterans)

0 345 Marine Product

153 Recovery ofOverpayment

LiabIlity

of Veteran's Benefits
o 160 Stockholders' SUItS o 190 Other Contract o 195 Contract Product LIabilIty o 196 FranchIse

0 0
0

350 Motor Vehicle 355 Motor VehIcle
Product LIability 360 Other Personal
InjUry

0 370 Other Fraud
0 371 Truth m Lendmg 0 380 Other Personal
Property Damage
0 385 PropertY Damage Product Liability

0 690 Other
LABOR
p 710 Fair Labor Sllmdards
Act
0 720 Labor/Mgmt. RelatIOns 0 730 Labor/Mgmt.Reporting
& DIsclosure Act

REAL PROPERTY
g 210 Land Condemnation
o 220 Foreclosure o 230 Rent Lease & Ejectment

CIVIL RIGHTS ~ 441 VOllng
442 Employment 443 Housmgi

PRISONER PETITIONS 0 740 Railway Labor Act
p 510 Motions to Vacate 0 790 Other Labor LIlIgallon

Sentence

0 791 Empl. Ret. Inc.

Habeas Corpus:

Secunty Act

0240 Torts to Land
o0245 Tort Product LiabIlIty'· 290 All Other Real Property

Accommodallons

0 530 General

0 444 Welfare

0 535 Death Penalty

0 445 Amer. w/DisabllIties - 0 540 Mandamus & Other

Employment

0 550 CIvil RIghts

0 446 Arner wlDlsabililles- 0 555 Pnson Condition Other

0 440 Other CIVIl RIghts

BANKRUPTCY
o0422 Appeal 28 USC 158 423 Withdrawal 28 USC 157
PROPERTY RIGHTS
I-! 820 Copynghts
o0830 Patent 840 Trademark
ISOCIAL SECURITY
II-! 861 HlA (l395fl)
o 862 Black Lung (923) o 863 D1WCIDIWW (405(g» o 864 SSID TItle XVI o 865 RSI (405(g»
FEDERAL TAX SUITS
,0 870 Taxes (U.S. Plamllff
p or Defendant) 871 IRS-Third Party 26 USC 7609

OTHER STATUTES
0 400 State Reapportionment
o 410 Anlltrust o 430 Banks and Bankmg o 450 Commerce o 460 Deportation o 470 Racketeer Influenced and
Corrupt Organlzallons
0 480 Consumer Credit 0 490 Cable/Sat TV 0 810 Selective ServIce 0 850 SecunlleslCommoditiesl
Exchange 0 875 Customer Challenge
12 USC 3410
0 890 Other Statutory Acllons 0 891 Agncultural Acts
0 892 Econonuc StabllIzallon Act 0 893 EnvIronmental Matters
o 894 Energy Allocation Act
P 895 Freedom oflnformallon
Act 0 900 Appeal of Fee DeternunatlOn
Under Equal Access
to Justice
0 950 Constitutionality of State Statutes

V. ORIGIN
1\r 1 Origmal 1\ Proceedmg

o (Place an "X" in One Box Only)

2 Removed from

0 3 Remanded from

State Court

Appellate Court

0 4 Reinstated or 0 Reopened

Transferred from

5 another district 0 6 Multtdistnct

(Specify)

Litigation

Cite the U S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

A al to Ulstnct
o 7 JtJ:e from Magistrate Judgment

VI. CAUSE OF ACTION Brief description of cause: Defendant subjected class to a racially hostile work environment.

VII. REQUESTED IN COMPLAINT:

D CHECK IF TillS IS A CLASS ACTION
UNDER F.R.C P. 23

VIII. RELATED CASE(S) IF ANY

(See instruc\1ons)'

JUDGE

DEMANDS

CHECK YES only If demanded in complamt:

JURY DEMAND:

~Yes DNo

DOCKET NUMBER

RECEIPT #

AMOUNT

APPLYING IFP

--------

-------------

JUDGE

MAG. JUDGE

 
 Case 3:05-cv-01063 Document 12 Filed 12/16/2005 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

)

DALLAS AFRICAN AMERICAN RESOURCE )

CENTER, FORMERLY D/B/A

)

RENAISSANCE III ORGANIZATION, )

)

Defendant.

)

)

_________________________________________ )

CIVIL ACTION NO. 3:05-CV-1063-B AMENDED COMPLAINT ECF
JURY TRIAL DEMAND

NATURE OF THE ACTION This an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I of the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of race and to provide relief to Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals. The Commission alleges that Defendant Dallas African American Resource Center, formerly d/b/a Renaissance III Organization (hereafter “Defendant”), violated Title VII by subjecting Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor and similarly-situated individuals to a racially hostile work environment.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §451, 1331, 1337, 1343, 1345. This action is authorized and instituted pursuant to Section 706(1)(f) and (3) of the

Case 3:05-cv-01063 Document 12 Filed 12/16/2005 Page 2 of 5
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 Northern District of Texas.
PARTIES 3. Plaintiff, Equal Employment Opportunity Commission of (the “Commission”), is an agency of the United States of America charged with the administration, interpretation and enforcement of Title VII of the Civil Rights Act of 1964, as amended and is expressly authorized to bring this action by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. §2000e-5(f)(1) and (3). 4. At all relevant times, Defendant has continuously been and is now doing business in the State of Texas and the City of Dallas, and has continuously had at least fifteen employees. 5. At all relevant times, Defendant has continuously been an employer engaged in industry affecting commerce under Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §2000e(b), (g) and (h).
STATEMENTS OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, and Ursula Traylor filed charges with the Commission alleging violations of Title VII of the Civil Rights Act of 1964, as amended, by the Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least March 1998, the Defendant has engaged in unlawful employment practices at its Dallas, Texas, facility in violation of Section 703(a) (1) of Title
2

Case 3:05-cv-01063 Document 12 Filed 12/16/2005 Page 3 of 5
VII, 42 U.S.C. §2000e-2(a)(1) by subjecting Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals to a racially hostile work environment.
8. The result of the foregoing practices has been to deprive Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals of equal employment opportunities because of their race, Black.
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 done with malice or with reckless indifference to the federally protected rights of Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining the Defendant, its officers, members of its Board of Directors, successors, assigns, and all persons in active concert or participation with them, from engaging in any employment practice which discriminates on the basis of race, or which facilitates, condones or encourages employees to create a racially hostile environment. B. Order the Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals and eradicate the effects of its past and present unlawful unemployment practices.
3

Case 3:05-cv-01063 Document 12 Filed 12/16/2005 Page 4 of 5
C. Order the Defendant to make whole Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including but not limited to, pain and suffering, humiliation, embarrassment, emotional distress, anxiety, and loss of enjoyment of life, in amounts to be determined at trial.
D. Order the Defendant to pay Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, Ursula Traylor, and similarly-situated individuals punitive damages for its malicious conduct or reckless indifference described in paragraphs 7 and 10 above, in amounts to be determined at trial.
E. Grant such further relief as the Court deems necessary and proper in the public interest.
F. 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.
4

Case 3:05-cv-01063 Document 12 Filed 12/16/2005 Page 5 of 5
Respectfully submitted, JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel s/Robert A. Canino ROBERT A. CANINO Regional Attorney Oklahoma State Bar No. 011782 s/Toby W. Costas TOBY W. COSTAS Supervisory Trial Attorney Texas State Bar No. 04855720 s/Devika S. Dubey DEVIKA S. DUBEY Senior Trial Attorney Texas State Bar No. 24044860 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Dallas District Office 207 Houston Street, 3rd Floor Dallas, Texas 75202 (214) 253-2764 (telephone) (214) 253-2749 (facsimile)
5

 
 r "

U.s.DISTRICTCOUR

troR'I'BERNDISTRlCI'OFTEXAS

QR\G\ ~~ ~ ~\..1~~:,!:"yt".,. INTHEUNITEDSTATESDISTRICTCO

FILED

JJL I FOR THE NORTHERN DISTRICT OF T xYlS:,';,

7 2006

--.J DALLAS DIVISION

:i:;;~;?'; '}<-:i.' ~.< [-;~v~,'"
a...--_ _

·.f u.s.n (uRK.
:~:~'~,:'',i:'"'"'"' _ B1 _ _~F~

C_OU_RT

. ".;~",

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

CIVIL ACTION NO.

Plaintiff,

)

)

3:05-CV-I063-B

v.

)

)

)

RENAISSANCE III ORGANIZATION, )

)

Defendant.

)

)

---------------)

CONSENT DECREE

This Consent Decree is made and entered into between the Plaintiff, the Equal Employment Opportunity Commission ("EEOC"), and the Defendant, Renaissance III Organizationl (hereinafter

collectively referred to as "the parties").

On May 24, 2005, the Equal Employment Opportunity Commission instituted a lawsuit in

the Northern District of Texas, Dallas Division, Civil Action Number 3:05-CV-1063-B against

Defendant, alleging that the Defendant violated Title VII ofthe Civil Rights Act of 1964 (Title VII)

when it subjected Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, and Ursula Traylor

IDefinition of "Defendant": Although Defendant is presently not conducting business, the terms of this Consent Decree shall apply to Defendant when and if during the three-year duration of the Decree it: (1) begins to conduct business; (2) re-establishes itself under a different name and begins to conduct business; (3) re-establishes itself as another business engaged in business activities similar to those conducted while named Renaissance III Organization. The terms shall also apply to any business entities that are characterized as "successor" companies to Renaissance III and to any business entities that become affiliated with Defendant. Any time frames contained in this Decree with regard to non-monetary injunctive remedial and prospective relief are subject to the above conditions regarding re-establishment of the business.

("Charging Parties") to a racially hostile work environment because of their race (Black). Specifically, the EEOC contends that Executive Director Donald Sneed barraged the Charging Parties with unwanted racial slurs and intimidation including use of the terms "nigger," references to slavery and frequent use of the word "Black" as an adjective coupled with an insult.
The parties hereto desir e to compromise and settle the differences embodied in the aforementioned lawsuit, and intend that the terms and conditions be set forth in this Consent Decree.
NOW, THEREFORE, in consideration !of the mutual promises and agreements set forth herein, the sufficiency ofwhich is hereby acknowledged, the parties agree as follows, the court finds appropriate, and therefore, it is ORDERED, ADJUDGED AND DECREED that:
1. This Court has jurisdiction to enforce the provisions set forth in this Consent Decree. 2. This Consent Decree resolves all issues, including all like and related issues, raised
in EEOC Charge Numbers 310-2003-07250 (Serita Agnew); 310-2003-07251 (Carolyn Jefferson); 310-2003-07218 (HrontReed); 310-2003-07252 (Kenny Scott); and 310-2004-01624 (Ursula Traylor). This Decree further resolves all issues raised in the Complaint filed by the Commission in this civil action. The Commission does not waive processing or litigating charges or cases other than the above-referenced charges, the Complaint, and the racial harassment claims. 3. Defendant agrees not to allow employees to be subjected to a racially hostile work environment and agrees to take proactive steps to ensure a workplace free of racebased comments, epithets, or slurs. 4. Should Defendant conduct any business operations and have more than one
2

employee, it agrees to post the Notice appended hereto as Attachment "A" on the employee bulletin boards at its office after the entry of this Consent Decree. Defendant will report to the EEOC that it has complied with this requirement within 30 days after posting the notice. 5. Should Defendant conduct any business operations and have more than one employee, it agrees to conduct annual training for all employees and members ofthe Board ofDirectors (ifapplicable)1 advising them ofthe requirements and prohibitions of Title VII ofthe Civil Rights Act of 1964. The training will inform the employees and any Board members ofthe complaint procedure for individuals who believe that they are being discriminated against by Defendant. This annual training will also advise employees and any Board members of the consequences imposed upon Defendant for violating Title VII. The training will also include a specific discussion or instruction relating to racial harassment, the reporting requirements regarding complaints of racial harassment, and the appropriate investigation of racial harassment claims. The training shall be at least two (2) hours in duration. No less than 10 days before the training is conducted, Defendant (or its successor or affiliate) agrees to give written notice to the EEOC as to the date and location of the training, the name and qualifications ofthe person(s) providing the training and the substance ofthe training. All materials used in conjunction with the training shall be forwarded to the EEOC. Within 20 days following the training, Defendant shall submit to the EEOC confirmation that the training was conducted, and a list of attendees.
3

6. Defendant agrees that Donald Sneed shall never hold an ownership, supervisory,

managerial, Executive Director, Board member, or any other leadership role with it,

any of its successors, affiliates, or with any company that owns or is owned by

Defendant.

7. If Donald Sneed, at any time, becomes employed by Defendant, it agrees that:

a. Donald Sneed shall be excluded from any role in the receipt ofreports

of discrimination;

b. Donald Sneed shall be excluded from any role in the investigation of

reports of discrimination;

c. Donald Sneed shall have no authority to impose any employment

actions on employees (including hiring, promotions, demotions,

compensation, firing, transfer);

d. Donald Sneed shall have no supervisory authority over any employee;

e. Donald Sneed's permanent personnel file shall contain a

memorandum stating that Defendant has received complaints alleging

that he racially harassed African-American employees during his

tenure as Executive Director of the agency; and

f.

Donald Sneed shall be required by ownership, management, or the

Board, if applicable, to undergo immediate psychiatric counseling to

address any psychological/physiological issues relating to his racial

harassment of individuals ofhis own race. Such counseling shall end

4

only when the treating physician recommends that no further sessions are medically necessary. 8. Defendant agrees to pay Charging Parties the gross sum of $200,000.00 in full and final settlement of the claims asserted in this dispute. This $200,000.00 represents a compromise of damages sought under Title VII ofthe Civil Rights Act of 1991 for the claims asserted by the EEOC on behalf of Charging Parties Serita Agnew, Carolyn Jefferson, Hront Reed, Kenny Scott, and Ursula Traylor. Payment is made without any admission of liability by Defendant and is made solely in order to compromise the disputed claims for the purpose ofavoiding litigation. Payment shall be made in the form offive (5) separate checks ofequal amounts. The checks shall be mailed to Devika S. Dubey, Senior Trial Attorney, 207 S. Houston Street, 3rd Floor, Dallas, Texas 75202 within 10 days after entry of this Consent Decree. 9. It is understood that this agreement does not constitute an admission by Defendant of any violation of Title VII of the Civil Rights Act of 1964. The Parties acknowledge that the Charging Parties and Defendant have entered into a separate and independent settlement and release agreement to which the EEOC is not a party and that is not incorporated into .this Consent Decree. 10. Should Defendant conduct any business operations and have more than one employee, it agrees to provide to each employee (including all management employees), each member of the Board of Directors, and each new hire at its facility a copy of its complaint procedures for reporting and investigating claims of racial
5

harassment. 11. Should Defendant conduct any business operations and have more than one
employee, it agrees to report to the EEOC its compliance with the arrangements set forth in paragraphs 4 and 5 above. All reports to the EEOC required by this Decree shall be sent to Robert A. Canino, Regional Attorney, 207 S. Houston Street, 3rd Floor, Dallas, Texas 75202. 12. Defendant agrees that it shall immediately notify the EEOC in writing if Defendant: (1) begins to conduct business; (2) re-establishes itself under a different name and begins to conduct business; or (3) re-establishes itself as another business engaged in business activities similar to those conducted while named Renaissance III Organization. Defendant also agrees that it shall immediately give written notice to the EEOC if a successor company is established or if any business entity becomes affiliated with Defendant. Notice ofthe matters described in this paragraph shall be given to the EEOC within 30 days of Defendant's knowledge of any such matters. Upon receiving such notification from Defendant, the Defendant recognizes the EEOC's right to petition the Court to modify the duration ofany term ofthis Consent Decree. 13. If Defendant fails to tender payment or otherwise fails to timely comply with the terms of paragraph 8 above, Defendant shall:
1. Pay interest at the rate calculated pursuant to 26 U.S.C. § 6621 (b) on any untimely or unpaid amounts; and
6

2. Bear any additional costs incurred by the EEOC caused by the noncompliance or delay of the Defendant.
14. The parties agree to bear their own costs associated with this action, including attorney's fees.
15. The Commission has the right to specifically enforce the terms of this Decree. Nothing in this Consent Decree can preclude further actions by the EEOC or any other person to remedy any other alleged violations ofTitle VII by Defendant, or any of its successors or affiliates.
16. The effective date of this Decree shall be the date upon which it is signed by the Court.
17. The term ofthis Decree shall be for three (3) years from the effective date. The Court shall retain jurisdiction to enforce the terms ofthis Decree until the expiration ofthe term of the Consent Decree unless a request for modification of the duration of any term of the Decree is made by the EEOC pursuant to Paragraph No. 11, at which time the Court will determine the additional time necessary to reasonably ensure compliance.
7

· .

APPROVED AS TO FORM AND CONTENT:
FOR THE PLAINTIFF, EQUAL EMPLOYMENT OPPORTUNITY COMMIS ION:

FOR THE DEFENDANT, RENAISSANCE III ORGANIZATION:

ROBERT A. CANINO

Regional Attorney

Oklahoma State Bar No. 011782

,-'-1.&111.1
-ToBft.

J2s~A~ S

Supervisory Trial Attorney Texas State Bar No. 04855720

~/ se~ DEVI S. D EY
Texas State Bar No. 24044860

f'
SO ORDERED, ADJUDGED AND DECREED this /3 day ~~'4--:' 2006.

L ANEJ.BOYL DISTRICT JUDGE

8

NOTICE AS REOUIRED UNDER TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, AS AMENDED
This NOTICE to all employees of [Defendant or Defendant successor/affiliate] and is being posted as part of a Consent Decree between Renaissance III Organization and the U.S. Equal Employment Opportunity Commission.
1. Federal Law requires that there be no discrimination against or harassment of any employee or applicant for employment because of that person's race, color, religion, sex, national origin, age or disability with respect to hiring, compensation, promotion, discharge or other terms, conditions or privileges of employment. Federal law also prohibits retaliation in any way against any person because ofthat person's opposition to any practice declared unlawful under Title VII or because of the filing of a charge, giving testimony, or assisting or participating in any manner in any investigation, proceeding or hearing.
2. Renaissance III Organization or its successor/affiliate strongly supports and will comply with such Federal Law in all aspects and it will not take any action against employees because they have exercised their rights under the law by filing charges with the United States Equal Employment Opportunity Commission.
3. Renaissance III Organization or its successor/affiliate will not tolerate racial harassment, race-based harassment and/or discrimination in the workplace. Employees are now put on notice that the first violation of the company's harassment policy will subject an employee found to have violated the policy to disciplinary action.
4. Employees may report violations of the company's harassment policy to [designated company official/department/telephone number/extension] and/or the Dallas District Office ofthe United States Equal Employment Opportunity Commission, 207 South Houston Street, Third Floor, Dallas, Texas 75202 (214-253-2700).
5. This NOTICE will remain posted until July 1,2009 as provided in the Consent Decree.
Attachment "A"

 
 E.E.O.C. v. Renaissance III Organization, Not Reported in F.Supp.2d (2006)

2006 WL 832504 Only the Westlaw citation is currently available.
United States District Court, N.D. Texas, Dallas Division.
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Plaintiff, v.
RENAISSANCE III ORGANIZATION Defendant.
No. 3-05-CV-1063-B. | March 30, 2006.
Attorneys and Law Firms
Robert A. Canino, Jr., Devika S. Dubey, Toby W. Costas, Equal Employment Opportunity Commission Dallas District Office, Dallas, TX, for Plaintiff.
Mark E. Smith, Touchstone Bernays Johnston Beall & Smith, Jerry Lee Ewing, Jr., Walters Balido & Crain, Dallas, TX, for Defendant.
Opinion

MEMORANDUM ORDER

KAPLAN, Magistrate J.

*1 Plaintiff Equal Employment Opportunity Commission has filed a motion to quash 21 subpoenas issued by Defendant Dallas African American Resource Center, formerly d/b/a Renaissance III Organization, to former employers of the charging parties in this Title VII racial harassment case. Each subpoena requires the production of:

[A]ny and all files, notes, papers,

employment and/or personnel records,

payroll and/or earning records,

insurance records, worker’s

compensation

records,

correspondence, and any other

tangible documents[.]

(Plf.Mot., Exh. A). Plaintiff argues that the subpoenas seek irrelevant information and serve no purpose other than to harass, oppress, and invade the privacy of the charging parties. Defendant counters that the employment records of these individuals are reasonably calculated to lead to the discovery of admissible evidence. The parties have briefed their respective positions in a joint status report filed on March 29, 2006, and the motion is ripe for determination.
Fed.R.Civ.P. 26(b) allows a party to obtain discovery “regarding any matter, not privileged, that is relevant to a claim or defense of any party [.]” The information sought need not be admissible at trial “if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.” Fed.R.Civ.P. 26(b)(1). As the party seeking discovery, defendant must establish this threshold burden. See Vardon Golf Co., Inc. v. BBMG Golf Ltd., 156 F.R.D. 641, 650 (N.D.Ill.1994) (“To place the burden of proving that the evidence sought is not reasonably calculated to lead to the discovery of admissible evidence on the opponent of discovery is to ask that party to prove a negative. This is an unfair burden, as it would require a party to refute all possible alternative uses of the evidence, possibly including some never imagined by the proponent.”). No such showing has been made here. In its portion of the joint status report, defendant states only “[t]hese employment records will likely contain information which will or could affect the value of these employees’ claim.” (Jt. Stat. Rep. at 2). Such a conclusory assertion, unsupported by any facts, evidence, or citations to legal authority, amounts to nothing more than a fishing expedition and does not justify the wholesale production of confidential employment records. Even if the discovery sought by defendant is reasonably calculated to lead to the discovery of admissible evidence, the court finds that the privacy interests of the charging parties far outweigh any likely benefit to defendant in obtaining the records its seeks. See Fed.R.Civ.P. 26(b)(2)(iii).
For these reasons, plaintiff’s motion to quash [Doc. # 29] is granted.
SO ORDERED.
	  

1

 
 District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

ADR, CLOSED, ECF, JURY, KAPLAN, PTRL
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:05-cv-01063

Equal Employment Opportunity Commission v. Renaissance III Organization Assigned to: Judge Jane J Boyle Referred to: Magistrate Judge Jeff Kaplan Cause: 42:1981 Job Discrimination (Race)

Date Filed: 05/24/2005 Date Terminated: 07/17/2006 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Robert A Canino, Jr Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2750 Email: robert.canino@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Devika Seth Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2764 Fax: 214/253-2749 FAX Email: devika.seth@eeoc.gov ATTORNEY TO BE NOTICED

Toby W Costas Equal Employment Opportunity Commission Dallas District Office 207 S Houston 3rd Floor Dallas, TX 75202 214/253-2760 Fax: 214/253-2749 FAX Email: toby.costas@eeoc.gov ATTORNEY TO BE NOTICED

V.

1 of 6

6/20/2007 3:43 PM

District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

Defendant Renaissance III Organization
Mediator ADR Provider

represented by Jerry Lee Ewing, Jr Walters Balido & Crain Founders Square Suite 600 900 Jackson St Dallas, TX 75202 214/749-4805 Fax: 214/760-1670 FAX Email: jerry.ewing@wbclawfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Mark E Smith Touchstone Bernays Johnston Beall & Smith 4700 Renaissance Tower 1201 Elm St Dallas, TX 75270-2196 214/741-1166 Fax: 214/741-7548 FAX Email: mark.smith@tbjbs.com TERMINATED: 04/13/2006
represented by Walter Rip E Parker Gilbert Mediation Group 3131 McKinney Ave Suite 125 Dallas, TX 75204 214/303-4500 Fax: 214/303-4501 Email: rparker@gmgtexas.com ATTORNEY TO BE NOTICED

Date Filed 05/24/2005 05/24/2005 05/24/2005 05/24/2005

#

Docket Text

1 COMPLAINT against Renaissance III Organization filed by Equal Employment Opportunity Commission.(svc, ) (Entered: 05/26/2005)
DEMAND for Trial by Jury by Equal Employment Opportunity Commission. (svc, ) (Entered: 05/26/2005)
2 Summons Issued as to Renaissance III Organization. (svc, ) (Entered: 05/26/2005)
***Magistrate Judge Kaplan chosen by random selection to handle matters that may be referred in this case. (svc, ) (Entered: 05/26/2005)

2 of 6

6/20/2007 3:43 PM

District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

05/24/2005 07/11/2005 07/14/2005 07/14/2005 08/15/2005 08/18/2005
10/17/2005 12/13/2005 12/15/2005 12/16/2005 01/13/2006
01/17/2006
01/17/2006

3 CERTIFICATE OF INTERESTED PERSONS by Equal Employment Opportunity Commission. (svc, ) (Entered: 05/26/2005)
4 Original ANSWER to Complaint with Jury Demand by Renaissance III Organization.(jyg, ) (Entered: 07/12/2005)
5 Order Regarding Intention to Administer Case Electronically - see order for specifics. (Signed by Judge Jane J Boyle on July 14, 2005) (jyg, ) (Entered: 07/14/2005)
6 STATUS REPORT ORDER: Joint Status Report due by 8/15/2005. See order for specifics. (Signed by Judge Jane J Boyle on July 14, 2005) (jyg, ) (Entered: 07/14/2005)
7 STATUS REPORT JOINT by Renaissance III Organization. (Smith, Mark) (Entered: 08/15/2005)
8 SCHEDULING ORDER: Amended Pleadings due by 12/16/2005. Discovery due by 3/31/2006. Docket Call set for 9/18/2006 Judge Jane J Boyle. Pretrial Conference set for 9/15/2006 10:00 AM before Judge Jane J Boyle. Joinder of Parties due by 12/16/2005. Motions due by 6/1/2006. (Signed by Judge Jane J Boyle on 8/18/05) (svc, ) (Entered: 08/19/2005)
9 Order Designating Case for ECF - see order for specifics. (Signed by Judge Jane J Boyle on October 17, 2005) (jyg, ) (Entered: 10/18/2005)
10 Unopposed MOTION to Amend/Correct COMPLAINT by Equal Employment Opportunity Commission (Attachments: # 1 Exhibit Amended Complaint)(Dubey, Devika) (Entered: 12/13/2005)
11 ORDER granting 10 Unopposed MOTION to Amend/Correct COMPLAINT. (Signed by Judge Jane J Boyle on 12/15/05) (svc, ) (Entered: 12/15/2005)
12 AMENDED COMPLAINT against Renaissance III Organization filed by Equal Employment Opportunity Commission.(Dubey, Devika) (Entered: 12/16/2005)
13 MOTION Application For Order To Show Cause Why Donald Sneed Should Not Be Held In Contempt by Equal Employment Opportunity Commission (Attachments: # 1 Exhibit Exhibit A-Subpoena Donald Sneed# 2 Exhibit Exhibit B-Proof of Service Donald Sneed# 3 Exhibit Exhibit C-NonAppearance Affidavit Donald Sneed# 4 Exhibit Exhibit D-Subpoena Donald Sneed# 5 Exhibit Exhibit E-Proof of Service of Donald Sneed)(Dubey, Devika) (Entered: 01/13/2006)
14 ORDER OF REFERRAL AND STANDING ORDERREFERRING DISCOVERY MOTIONS... The EEOC's Application for Order to Show Cause Why Donald Sneed Should Not beHeld in Contempt (doc. 13), filed January 13, 2006, is REFERRED to United States MagistrateJudge Jeff Kaplan for hearing, if necessary, and recommendation or determination, to this Court.See 28 U.S.C. 636(b) (1993). All other discovery motions in this case are prospectively referredto Magistrate Judge Kaplan for determination. (Signed by Judge Jane J Boyle on 1/17/06) (svc, ) (Entered: 01/17/2006)
15 STANDING ORDER FOR ELECTRONIC FILINGS RELATED TO MATTERSREFERRED TO THE UNITED STATES MAGISTRATE JUDGE. (svc, ) (Entered: 01/17/2006)

3 of 6

6/20/2007 3:43 PM

District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

01/17/2006 01/17/2006 01/25/2006 01/25/2006 01/27/2006
01/27/2006 02/08/2006 02/28/2006 03/01/2006 03/06/2006 03/13/2006 03/15/2006 03/17/2006

16 ORDER TO SHOW CAUSE... Show Cause Hearing set for 1/27/2006 08:30 AM before Magistrate Judge Jeff Kaplan. (Signed by Judge Jeff Kaplan on 1/17/06) (order mailed to Donald Sneed at 119 PalmDrive, Lancaster, Texas 75146)(svc, ) (Entered: 01/17/2006)
17 STANDING ORDER ON ALL DISCOVERY MOTIONS...See order for specifics. (Signed by Judge Jeff Kaplan on 1/17/06) (svc, ) (Entered: 01/17/2006)
18 AFFIDAVIT of Service for Subpoena served on Donald Sneed on January 23, 2006. (Dubey, Devika) (Entered: 01/25/2006)
19 RESPONSE to Motion re 13 MOTION Application For Order To Show Cause Why Donald Sneed Should Not Be Held In Contempt filed by Renaissance III Organization. (Smith, Mark) (Entered: 01/25/2006)
20 ORDER on Motion 13...Donald Sneed is ordered to appear for deposition on February 6, 2006at 9:30 a.m. at the Dallas office of the U.S. Equal Employment Opportunity Commission, 207 SouthHouston Street, 3rd Floor, Dallas, Texas 75202. Sneed is warned that the failure to comply with thisorder may constitute a contempt of court, which would subject him to arrest and incarceration untilhe is deposed by plaintiff. In addition, the court may impose monetary sanctions if Sneed fails tocomply with this order. See order for specifics. (Signed by Judge Jeff Kaplan on 1/27/06) (svc, ) Modified on 7/17/2006 (lrl, ). (Entered: 01/27/2006)
21 Minute Entry for proceedings held before Judge Jeff Kaplan : Show Cause Hearing held on 1/27/06. (Court Reporter Randy Wilson.) (svc, ) (Entered: 01/27/2006)
22 NOTICE of Change of Address by Jerry Lee Ewing, Jr, counsel for Renaissance III Organization. Walters, Balido & Crain 900 Jackson St., Ste 600 Dallas, TX 75202 (svc, ) (Entered: 02/09/2006)
23 Designation of Experts by Renaissance III Organization. (Ewing, Jerry) (Entered: 02/28/2006)
24 Designation of Mediator by Equal Employment Opportunity Commission, Renaissance III Organization.(Ewing, Jerry) (Entered: 03/01/2006)
25 ORDER REFERRING CASE to ADR. Type of ADR: Mediation. ADR Provider Rip E Parker appointed (Signed by Judge Jane J Boyle on 3/6/06) (svc, ) (Entered: 03/07/2006)
26 ***UNFILED PER 3/17/06 ORDER***MOTION to Strike Defendant's Expert Witness by Equal Employment Opportunity Commission (Dubey, Devika) Modified on 3/17/2006 (svc, ). (Entered: 03/13/2006)
27 MOTION to Quash and Incorporated Brief by Equal Employment Opportunity Commission (Attachments: # 1 Exhibit Exhibit A- Defendant's Subpoena Duces Tecum)(Dubey, Devika) (Entered: 03/15/2006)
28 ORDER...Plaintiff's 26 motion to strike expert witnesses is stricken from the record of this case. (Signed by Judge Jeff Kaplan on 3/17/06) (svc, ) Modified on 3/17/2006 (svc, ). (Entered: 03/17/2006)

4 of 6

6/20/2007 3:43 PM

District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

03/29/2006 03/29/2006 03/29/2006 03/30/2006 03/30/2006 03/30/2006 03/30/2006 03/30/2006 03/31/2006
04/04/2006
04/06/2006 04/10/2006

29 MOTION to Quash and Incorporated Brief by Equal Employment Opportunity Commission (Dubey, Devika) (Entered: 03/29/2006)
30 Joint Status Report with respect to the EEOC?s 29 MOTION to Quash by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Supplement Joint Status Report-Motion to Quash# 2 Exhibit A (Dubey, Devika) Modified on 3/30/2006 (svc, ). (Entered: 03/29/2006)
31 MOTION to Strike Expert Witness by Equal Employment Opportunity Commission (Attachments: # 1 Supplement Attachment-Joint Status Report on Motion to Strike Expert Witness)(Dubey, Devika) (Entered: 03/29/2006)
32 MOTION to Extend Time Enlarge Time for Discovery by Renaissance III Organization with Joint Status Report. (Ewing, Jerry) (Entered: 03/30/2006)
33 ***UNFILED PER 3/31/06***RESPONSE to Motion re 31 MOTION to Strike Expert Witness filed by Renaissance III Organization. (Ewing, Jerry) Modified on 3/31/2006 (svc, ). (Entered: 03/30/2006)
34 Memorandum Order granting 29 Motion to Quash filed by Equal Employment Opportunity Commission. (See Order for specifics) (Signed by Judge Jeff Kaplan on 3/30/2006) (skt, ) (Entered: 03/30/2006)
35 ***UNFILED PER 3/31/06 ORDER***Response to Motion re 29 MOTION to Quash and Incorporated Brief filed by Renaissance III Organization. (Ewing, Jerry) Modified on 3/31/2006 (svc, ). Modified on 3/31/2006 (svc, ). (Entered: 03/30/2006)
36 Memorandum Order denying 31 Motion to Strike filed by Equal Employment Opportunity Commission. (See Order for specifics) (Signed by Judge Jeff Kaplan on 3/30/2006) (skt, ) (Entered: 03/30/2006)
37 Order Unfiling 35 Response to Motion re 29 MOTION to Quash filed by Renaissance III Organization,, 33 RESPONSE to Motion re 31 MOTION to Strike Expert Witness filed by Renaissance III Organization, due to the following deficiency: Defendant has neither sought nor obtained permission to file aresponse in opposition to plaintiffs' motions (Signed by Judge Jeff Kaplan on 3/31/06) (svc, ) (Entered: 03/31/2006)
38 Memorandum Opinion and Order Granting in part and Denying in Part 32 Motion to Enlarge Time for Discovery filed by Renaissance III Organization. Discovery deadline is extended until May 12,2006 to enable the parties to depose Donald Sneed. In all other respects, the motion is denied. (Signed by Judge Jeff Kaplan on 4/4/06) (svc, ) (Entered: 04/04/2006)
39 Plaintiff EEOC'S Unopposed Motion To Enlarge Time by Equal Employment Opportunity Commission (Dubey, Devika) Modified on 4/7/2006 (svc, ). (Entered: 04/06/2006)
40 ORDER...The proposed order submitted with 39 Motion to enlarge time for filing Daubert motions is deficient and will not be accepted. Counsel for plaintiff is directed to submit an agreedorder in proper form by April 17, 2006. (Signed by Judge Jeff Kaplan on 4/10/06) (svc, ) (Entered: 04/10/2006)

5 of 6

6/20/2007 3:43 PM

District Version 3.0.3 - Docket Report

https://ecf.txnd.uscourts.gov/cgi-bin/DktRpt.pl?814037591286787-L_3...

04/12/2006 04/13/2006 04/14/2006 06/01/2006 06/01/2006
07/10/2006 07/17/2006

41 MOTION to Substitute Attorney. Added attorney Jerry Lee Ewing, Jr for Renaissance III Organization. Motion Filed by Renaissance III Organization (Ewing, Jerry) (Entered: 04/12/2006)
42 ORDER granting 41 Motion to Withdraw and Substitute Attorney. Jerry L. Ewing, Jr. is substituted as lead counsel for Defendant in place of Mark E.Smith. (Signed by Judge Jane J Boyle on April 13, 2006) (jyg, ) (Entered: 04/14/2006)
43 ORDER granting 39 Unopposed Motion to Enlarge Time. The deadline to file Daubert motions is extended to 6/21/2006. (Signed by Judge Jeff Kaplan on 4/14/2006) (kdc, ) (Entered: 04/14/2006)
44 MOTION for Summary Judgment And Brief In Support by Equal Employment Opportunity Commissionmmary and Brief In Support. (Dubey, Devika) Modified on 6/1/2006 (svc, ). (Entered: 06/01/2006)
45 Appendix in Support filed by Equal Employment Opportunity Commission re 44 MOTION for Summary Judgment And Brief In Support (Attachments: # 1 Appendix Excerpts From Serita Agnew Deposition# 2 Appendix Excerpts from Carolyn Jefferson Deposition# 3 Appendix Excerpts from Kenneth Scott Deposition# 4 Appendix Excerpts from the Hront Reed Deposition# 5 Appendix Excerpts from Ursula Traylor Deposition# 6 Appendix Affidavit of Serita Agnew# 7 Appendix Affidavit of Kenny Scott# 8 Appendix Affidavit of Urusla Traylor# 9 Appendix Affidavit of Hront Reed# 10 Appendix Affidavit of Carolyn Jefferson# 11 Appendix Affidavit of William DeLoach)(Dubey, Devika) (Entered: 06/01/2006)
46 ORDER TO SUBMIT FINAL PAPERS: the Court ORDERS the parties to present to the Court a final judgment or agreed order of dismissal on or before July 28, 2006. (Signed by Judge Jane J Boyle on 07/10/06) (psm, ) (Entered: 07/10/2006)
47 CONSENT DECREE...See order for specifics. (Signed by Judge Jane J Boyle on 7/13/06) (svc, ) (Entered: 07/18/2006)

PACER Service Center

Transaction Receipt

06/20/2007 15:45:34

PACER Login: hs0328

Client Code: eeoc

Description: Docket Report Search Criteria: 3:05-cv-01063

Billable Pages: 4

Cost:

0.32

6 of 6

6/20/2007 3:43 PM