IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

City Crescen t Bu ilding, 3rd Floor

)

10 South Howard Street

)

Baltimore, MD 21201

)

)

Plaintiff,

)

)

v.

)

)

RG’S FOOD SHOPS OF PENNSYLVANIA, )

INC.,

)

10228 Lincoln Highway, Suite 1

)

Everett, PA 15537

)

)

and

)

)

BEDFORD VALLEY PETROLEUM

)

CORPORATION,

)

10228 Lincoln Highway, Suite 1

)

Everett, PA 15537

)

)

Defendants.

)

__________________________________________)

Case No.
COMPLAINT AND JURY TRIAL DEMAND

NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964, as amended (“Title VII”) and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation, and to provide appropriate relief to Charging Party Lisa White, Charging Party Mandy McMillan, Stacy Northcraft and a class of presently unidentified female employees, who were adversely affected by such practices. As alleged with greater particularity in paragraphs 9-13,
1

below, the United States Equal Employment Opportunity Commission (“the Commission”) alleges that Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation (“Defendants”) have committed sex discrimination and retaliation in violation of Title VII by subjecting Lisa White and Mandy McMillan to sexual harassment and by reducing the work hours of Ms. McMillan and ultimately discharging her in retaliation for engaging in conduct protected by Section 704(a) of Title VII. Also, as alleged with greater particularity in paragraph 14, below, the Commission further alleges that Defendants have committed sex discrimination in violation of Title VII by subjecting Stacy Northcraft and a class of presently unidentified female employees to sexual harassment.
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(f)(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 District of Maryland, Northern Division.
PARTIES 3. Plaintiff, the United States 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 this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3).
2

4. At all relevant times, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation, both Pennsylvania corporations, have continuously been doing business in the State of Maryland and the County of Allegany, and have continuously had at least 15 employees.
5. At all relevant times, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation have continuously been employers engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e(b), (g) and (h).
6. At all relevant times, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation have operated in conjunction with one another as an integrated enterprise/single “employer” within the meaning of Title VII. At all relevant times, Defendants have maintained interrelated operations, common management and directors, centralized control of labor relations and personnel, and common ownership and financial control.
7. At all relevant times, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation have continuously been employers engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 8. More than thirty days prior to the institution of this lawsuit, Lisa White and Mandy McMillan (formerly Mandy Duckworth) filed charges of discrimination with the Commission alleging violations of Title VII by Defendant RG’s Food Shops of Pennsylvania, Inc. All conditions
3

precedent to the institution of this lawsuit have been fulfilled. 9. Since at least August 3, 2001 and continuing, Defendants have engaged in unlawful
employment practices in violation of Section 703(a)(1) and (a)(2) and Section 704(a) of Title VII, 42 U.S.C. §§ 2000e-2(a)(1) and (a)(2) and 2000e-3(a).
10. Beginning on or about September 2001 and persisting until on or about March 20, 2002, Lisa White was subjected to a continuing course of unwelcome and offensive harassment because of her sex, female, by Defendants through the conduct of employee William Brant. Such harassment created a hostile work environment on the basis of sex. Defendants had both actual and constructive notice of the unlawful harassment and failed to take reasonable corrective action or action reasonably calculated to prevent the harassment.
11. Beginning on or about August 3, 2003 and persisting until on or about October 1, 2003, Mandy McMillan was subjected to a continuing course of unwelcome and offensive harassment because of her sex, female, by Defendants through the conduct of employee William Brant. Such harassment created a hostile work environment on the basis of sex and culminated in tangible employment action. Defendants also had actual and constructive notice of the unlawful harassment and failed to take reasonable corrective action or action reasonably calculated to prevent the harassment.
12. On or about September 2003, Defendants reduced Mandy McMillan’s hours of work because she engaged in various conduct protected under Section 704(a) of Title VII.
13. On or about October 2, 2003, Defendants discharged Mandy McMillan because she engaged in various conduct protected under Section 704(a) of Title VII.
4

14. Beginning on or about August 3, 2001 and continuing through the present, Stacy Northcraft and a class of presently unidentified aggrieved female employees were and are being subjected to a continuing course of unwelcome and offensive harassment because of their sex, female, by Defendants through the conduct of employee William Brant. Such harassment created a hostile work environment on the basis of sex. Defendants had/have actual and constructive notice of the unlawful harassment and have failed to take reasonable corrective action or action reasonably calculated to prevent the harassment.
15. The effect of the practices complained of in paragraphs 9-14, above, has been to deprive Lisa White, Mandy McMillan, Stacy Northcraft, and a class of presently unidentified aggrieved female employees of equal employment opportunities and otherwise adversely affect their status as employees because of their sex and conduct protected under Section 704(a) of Title VII.
16. The unlawful employment practices complained of in paragraphs 9-14, above, were and are intentional.
17. The unlawful employment practices complained of in paragraphs 9-14, above, were and are done with malice or with reckless indifference to the federally protected rights of Lisa White, Mandy McMillan, Stacy Northcraft, and a class of presently unidentified aggrieved female employees.
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns, and all persons in active concert or participation with them, from engaging in sex discrimination,
5

including sexual harassment, reduction of hours of work and discharge for conduct protected under Section 704(a) of Title VII, and any other employment practice which discriminates on the basis of sex or that constitutes unlawful retaliation.
B. Order Defendants to institute and carry out policies, practices, and programs which provide equal employment opportunities for female persons, and which eradicate the effects of their past and present unlawful employment practices, including but not limited to implementation of a policy prohibiting sexual harassment that comports with the requirements of Title VII, conducting employee training regarding such policy, and effective, reasonably diligent enforcement of such policy.
C. Order Defendants to make whole Mandy McMillan and a class of presently unidentified aggrieved female employees 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 their unlawful employment practices, including but not limited to reinstatement or front pay in lieu thereof.
D. Order Defendants to make whole Lisa White, Mandy McMillan, Stacy Northcraft, and a class of presently unidentified aggrieved female employees by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraphs 9-17, above, in amounts to be determined at trial.
E. Order Defendants to make whole Lisa White, Mandy McMillan, Stacy Northcraft, and a class of presently unidentified aggrieved female employees by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraphs
6

9-17, above, including emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment
of life, and other non-pecuniary losses, in amounts to be determined at trial.
F. Order Defendants to pay Lisa White, Mandy McMillan, Stacy Northcraft, and a class
of presently unidentified aggrieved female employees punitive damages for the malicious and
reckless conduct described in paragraphs 9-17, 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 of this action.
JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint.
Respectfully submitted,
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
ERIC S. DREIBAND General Counsel
JAMES LEE Deputy General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel
/s/ GERALD S. KIEL (Bar No. 07770) Regional Attorney EEOC-Baltimore District Office City Crescent Building, 3rd Floor 10 South Howard Street
7

Baltimore, Maryland 21201 Telephone number: (410) 962-4207 Facsimile number: (410) 962-4270/2817
/s/ TRACY HUDSON SPICER (Bar No.08671) Supervisory Trial Attorney EEOC-Baltimore District Office City Crescent Building, 3rd Floor 10 South Howard Street Baltimore, Maryland 21201 Telephone number: (410) 962-4623 Facsimile number: (410) 962-4270/2817
/s/ CECILE C. QUINLAN (Bar No.06072) Senior Trial Attorney EEOC-Baltimore District Office City Crescent Building, 3rd Floor 10 South Howard Street Baltimore, Maryland 21201 Telephone number: (410) 962-4239 Facsimile number: (410) 962-4270/2817
/s/ RONALD L. PHILLIPS Trial Attorney EEOC-Baltimore District Office City Crescent Building, 3rd Floor 10 South Howard Street Baltimore, Maryland 21201 Telephone number: (410) 962-4628 Facsimile number: (410) 962-4270/2817
8

 
 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

LISA M. WHITE, Plaintiff,
v.

CIVIL ACTION NO. WMN 04cv3038

RG’S FOOD SHOPS OF PENNSYLVANIA, INC.,
and
BEDFORD VALLEY PETROLEUM CORPORATION,

Defendants.

COMPLAINT OF LISA M. WHITE

NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964, as amended, (“Title VII”) and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and to provide appropriate relief to Charging Party Lisa M. White who was adversely affected by such practices. As alleged with greater particularity in paragraph 8 below, plaintiff alleges that Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation (“Defendants”) have committed sex discrimination in violation of Title VII by subjecting Lisa M. White to sexual harassment.

1

JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. Sections 451, 1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(l) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5(f)(l) and (3), (“Title VII”) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. Section 1981a.
2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the District of Maryland, Northern Division.
PARTIES 3. Plaintiff, Lisa M. White, is a resident of the State of West Virginia and is authorized to bring this action by Section 706(f)(l) and (3) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-5(f)(l).
4. At all times relevant hereto, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation, both Pennsylvania corporations, have continuously been doing business in the State of Maryland and the County of Allegheny, and have continuously had at least 15 employees.
5. At all times relevant hereto, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation have continuously been employers engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. Section 2000e(b), (g) and (h).
2

6. At all times relevant hereto, Defendants RG’s Food Shops of Pennsylvania, Inc. and Bedford Valley Petroleum Corporation have operated in conjunction with one another as an integrated enterprise/single “employer” within the meaning of Title VII. At all relevant times, Defendants have maintained interrelated operations, common management and directors, centralized control of labor relations and personnel, and common ownership and financial control.
STATEMENT OF CLAIMS
7. More than thirty days prior to the institution of this lawsuit, Lisa White filed a charge of discrimination with the Equal Employment Opportunity Commission (“EEOC”) alleging violations of Title VII by Defendant RG’s Food Shops of Pennsylvania, Inc. All conditions precedent to the institution of this lawsuit have been fulfilled.
8. Beginning on or about September 2001 and persisting until on or about March 20, 2002, Lisa White was subjected to a continuing course of unwelcome and offensive harassment because of her sex, female, by Defendants through the conduct of employee William Brant. Such harassment created a hostile work environment on the basis of sex. Defendants had both actual and constructive notice of the unlawful harassment and failed to take reasonable corrective action or action reasonably calculated to prevent the harassment.
9. The effect of the practices complained of in paragraph 8 has been to deprive Lisa
3

White of equal employment opportunities and otherwise adversely affected her status as an employee because of her sex.
10. The employment practices complained of in paragraph 8 were and are intentional.
11. The unlawful employment practices complained of in paragraph 8 were done with malice or with reckless indifference to the federally protected rights of Lisa White.
PRAYER FOR RELIEF
Wherefore, the Plaintiff respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendants, their officers, successors, assigns and all persons in active concert or participation with them, from engaging in sex discrimination, including sexual harassment and any other employment practice which discriminates on the basis of sex. B. Order Defendants to institute and carry out policies, practices, and programs which provide equal employment opportunities for female persons, and which eradicate the effects of their past and present unlawful employment practices, including but not limited to implementation of a policy prohibiting sexual harassment that comports with the requirements of Title VII, conducting employee training regarding such policy, and effective, reasonably diligent enforcement of such policy. C. Order the Defendants to make whole Lisa White by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 8, above, in amounts to be determined at trial.
4

D. Order the Defendants to make whole Lisa White by providing compensation for past and future non-pecuniary losses resulting from the unlawful employment practices described in paragraph 8, above, in amounts to be determined at trial.
E. Order the Defendants to pay Lisa White punitive damages for the malicious and reckless conduct described in paragraph 8, above, in amounts to be determined at trial.
F. Grant such further relief as the Court deems necessary and proper in the public interest.
G. Award the Plaintiff her costs and attorney’s fees.

JURY TRIAL DEMAND

The Plaintiff requests a jury trial on all questions of fact raised by her complaint.

Respectfully submitted,

LISA M. WHITE By Counsel

Harry P. Waddell

Digitally signed by Harry P. Waddell DN: CN = Harry P. Waddell, C = US, OU = Law Office of Harry P. Waddell Date: 2004.11.15 16:05:10 -05'00'

_________________________

HARRY P. WADDELL

300 West Martin Street

Martinsburg, West Virginia 25401

(304) 263-4988

(304) 262-2498 (fax)

Bar No. 25919

5

6

 
 Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

EQUAL EMPLOYMENT OPPORTUNITY COMMISSIO~, et al.
Plaintiffs,
v.
RG'S FOOD SHOPS OF PENNSYLVANIA, INC.
and
BEDFORD VALLEY PETROLEU:\l CORPORA TION,
Defendants.

)

)

)

Case No.:W~lN-04CV3038

)

)

)

)

)

)

)

)

)

)

)

)

)

)

CONSE~T DECREE This action was instituted on September 22. 2005, by Plaintiff, the Equal Employment Opportunity Commission ("Commission" or "EEOC"), against Defendants RG's Food Shops of
Pennsylvania, Inc. and Bedford Valley Petroleum Corporation ("Defendants"), pursuant to Title VII
ofthe Civil Rights Act of 1964, as amended ("Title \l II"), and Title I ofthe Civil Rights Act of 1991. The Commission's Complaint alleges that Defendants discriminated against Lisa White. Mandy McMillan (fom1erly Duckworth), Stacy Northcraft and a class of similarly situated female employees, by engaging in the unlawful employment practice of subjecting them to sexual harassment, including but not limited to creating and maintaining a hostile work environment, and retaliation and discharge against Ms. Mc1\-1illan, in violation of Title VII, Sections 703 and 704. On January 27,2005, Claimant Lisa White intervened in this lawsuit, alleging violations of Title VII

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 2 of 12
and Title r of the Civil Rights Act of 1991 by Defendants.
The Parties desire to resolve this action and all issues raised by the Complaint without the time and expense of further contested litigation, The parties also desire to formulate a plan to be embodied in this Decree that vvill promote and effectuate the PUllJOSCS of Title VII.
Defendants have stipulated that forpuqJoses of this litigi.ition. they constitute a single and/or joint cmployenvithin the meaning ofTitle VII. For the purposes ofresolving this action, Defendants admit that the Court has jurisdiction over this action and the parties, venue is proper, and that all statutory and jurisdictional prerequisites to suit have been satisfied.
The Court has examined this Decree and finds that it is reasonable andjust and in accordance with the Federal Rules of Civil Procedure and Title VII. Therefore, upon due consideration of the record herein and being fully advised of the premises, it is ORDERED, ADJUDGED AND DECREED:
1. This Decree constitutes a full discharge and satisfaction of any and all claims which have been alleged in the Complaint filed by the EEOC in this Title VII action based on the EEOC's determinations ofdiscrimination for the cbarges filed by Lisa White and Mandy McMi lIan, including the class of similarly situated female employees.
INJUNCTION AGAINST DISCRIMINATION 2. Defendants, its officers, agents, assigns and all persons acting or claiming to act on its behalf and interest, are hereby enjoined and restrained from violating Title VII by engaging in any employment practice that discriminates against any person because of sex by subjecting them to sexual harassment and creating and maintaining a hostile work environment and shall take the actions set f01111 in this Consent Decree to maintain a workplace free from sex discrimination.
2

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 3 of 12
3. Defendants, its offkers, agents, assigns, and all persons acting or claiming to act on its behalf and interest, are hereby enjoined and restrained from discriminating or retaliating against any
vn person because ofopposition to any practice declared unlawful under Title ofthe Civil Rights Act
of 1964, as amended, or because of the filing of a charge against Defendants alleging any such practice, giving testimony or assistance, or participation in any manner in any investigation, proceeding or hearing under Title VU, including any person \vho participated in any manner in this action.
SEXlJAL HARASSMENT POLley 4. Within thirty (30) days of the entry of this Decree, Defendants shall institute, implement and distribute to all its managers and employees a revised written policy on sexual harassment. The revised policy shall include at a minimum, a clear explanation of prohibited conduct, designation of a contact person to whom the prohibited conduct should be reported, with the contact person's name, title and phone number, a complaint procedure that provides accessible avenues of complaint, assurance that the employer will take all reasonable measures to protect confidentiality, conduct an impartial investigation, refrain from retaliating against any person who participates in such investigation, and take prompt and appropriate corrective action. The revised policy is to be reviewed by the Commission. Within fourteen (14) days of the entry of the Decree, Defendants shall forward to the Commission its proposed revised policy ror review, Upon the Commission's review of1hi5 revised policy on sexual harassment. Defendants shall distribute a copy of this policy to all its managers and employees. Within forty five (45) days of the entry of the Decree, Defendants shall forward to the Commission's attorney of record, at the EEOC's Baltimore District Office, \vritten certification that this policy on sexual harassment referenced herein has been distributed to all of its
3

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 4 of 12
managers and employees and posted in the designated places. POSTING OF POLlCY AND NOTICE
5. Upon entry of this Decree, Defendants will post immediately in a conspicuous place in and about its facilities, including all places \vherc notices to employees are customarily posted, and maintain for the term of the Consenl Decree, copies of the EEOC poster, "Equal Employment Opportunity Is The Law (Fom1 EEOC-P/E-l), a copy ofthe revised sexual harassment policy referred 10 in paragraph 4 above, and the Notice attached hereto as Exhibit "A" and made a palt hereof which shall be signed by responsible officials of Defendants with the date of actual posting to be shown thereon. Should these postings or notices become defaced, marred or otherwise made unreadable, Defendants will ensure that new readable copies are posted in the same manner heretofore specified.
6. The revised sexual harassment policy and notices shall be posted and maintained throughout the period of this Decree. Exhibit "A" shall also be distributed to each employee of Defendants. \Vithin forty five (45) days of entry of this Decree, Defendant shall fonvard to the Commission's attomey ofrecord, at the EEOC's Baltimore District Office, a copy ofthe signed Notice attached hereto as Exhibit "A" written certification that the sexual harassment policy and the notice referenced herein have been posted, a statement ofthe location{s) and date(s) ofpostings and that the signed Notice, attached hereto as Exhibit "A," has been distributed.
TRAINING 7. Within ninety (90) days of the entry of this Decree, Defendants will present training to its entire management and employee workforce conceming sexual harassment, sex discrimination, prohibition against retaliation and other laws enforced by the Commission. All persons responsible for the implementation and administration of the sexual harassment policy referred to in paragraph
4

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 5 of 12
4 above, shall also be required to attend the training. The trainer's credentials and an outline of program materials shall be fonvarded to the EEOC's attorney of record (30) thirty days prior to such training being conducted and the Commission shall provide any suggestion within ten (10) days of the training. A representative ofthe Commission shall be invited to attend such training. The training shall include an explanation of Title VII and its prohibitions against sexual harassment, the responsibilities of human resources and managerial personnel who are infornled or othenvise kno\v of incidents of harassment, recognition of harassment, and the prohibition against retaliating against employees who allege an incident of sex harassment or other discrimination. The training shall also address the methods for reporting an incident of sex harassment. The training shall explain to all employees that, in addition to reporting an incident to management, they have a right to file a charge of discrimination \vith the Commission and shall explain where such charges can be tiled and the applicable time frame for doing so. In addition, the training shall inform all employees that the employer will take all reasonable measures to protect confidentiality, that an impartial investigation will be conducted in response to a complaint and if the investigation finds that an employee has engaged in conduct that violates the employer's anti-harassment policy: (i) penalties \:vill depend on the nature of the offense, (ii) any and all breaches of the policy arc considered serious, and (iii) appropriate discipline will be imposed even for a first offense, ranging from a verbal \varning up to and including discharge. The training for Defendants' management \vorkforce shall be no less than ninety (90) minutes in duration. The training for Defendants' non supervisory employee workforce shall be no less than sixty (60) minutes in duration and will be provided to employees at their respective store sites by the Defendants' Human Resource manager, as guided and instructed by the trainer to be identified as set forth above.
5

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 6 of 12
8. Defendants also agrec to provide, within tcn (10) days of hire, to each newly-hired cmployee, including all managerial employees and all employees responsible for the administration of Defendants' sexual harassment policy, an orientation to its sexual harassment and equal employment opportunity policies, including review of a videotape of the training referenced in paragraph 7 above.
9. After entry of the Decree, Defendants shall forward to the Commission's attorney of record, at the EEOC's Baltimore District Office, a list of all employees who have attended and completed training within ten (10) days of the completion of such training. For the duration of this Consent Decree, Defendants shall keep a record of all employees who receive the training described herein. Dcfendants will report to the Commission's attorney of record those employees who have received the training at six (6) month intervals during the term of this Decree.
1~'DlVIDUAL RELIEF 10. Defendants have agreed to pay total damages in the amount of one hundred and five thousand (S 105,(00) in full settlement of this case. Within five (5) days of the execution of this Decree by the Parties, Defendants shall pay monetary damages in full settlement of this case in accordance with the provisions set forth below: a, Defendants will pay to :'viandy McMillan damages in the total amount of thirty eight thousand dollars ($38,000), consisting of five thousand dollars ($5,000) in back wages and thiliythree thousand dollars (S33,000) in compensatory damages. Defendants will issue a W2 Fonl1 for the back \'vage amount listed above, less amounts to be withheld by Defendants for applicable federal and state income taxes as required by law. Defendants shall take no withholding from the compensatory monetary amount listed above and will issue a Form
6

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 7 of 12
1099 above to Mandy McMillan reflecting this payment. b. Defendants will pay to Stacy Northcraft compensatory damages in the amount of thirty thousand dollars ($30,000). Defendants shall take no withholding from this monetary amount and will issue a Form 1099 to Stacy Northcraft reflecting this payment. c. Defendants will pay to Lisa White in conjunction with settlement of her claims as Intervenor in this case, compensatory damages in the amount of thirty two thousand dollars (S32,OOO). Defendants shall take no \vithholding from this monetary amount and will issue a Form 1099 to Lisa White reflecting this payment. d. Defendants agree that checks in these amounts shall be forwarded to the above-named individuals by overnight mail at an addresses to be supplied by the Commission. Within five (5) days of this payment Defendants shall send to the Commission's attorney of record a copy of1he checks along \vith a copy of the overnight delivery receipt. e. Defendants will establish a monetary fund in the amount of Jive thousand dollars (S5.000) to remedy allegations ofdiscrimination by the unidentified class. The Commission will usc due diligence to identify the class claim,mts within thirty (30») days of the entry of this Decree. The Commission will identi fy to Defendants the name, address and amount of the fund to be distributed to the identi fied claimant within sixty five (35) days of the entry of this Decree. In the event that there are any funds that have not been distributed, the remainder will be donated to a charity designated by the Commission. 11. Defendants shall remove any records or documents relating to the filing of charges of discrimination by.' Lisa White and Mandy McMillan orthe Commission's lawsuit against Defendants, from any and all personnel or other employment files of Lisa White, Mandy McMillan, and Stacy
7

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 8 of 12
NOJ1hcratl \vherever maintained. Reference requests regarding these individuals shall be answered by Defendants in neutral terms limited to position, rate of pay, and dates of employment
BREACH PROVISION 12. If any party to this Decree believes that any other party has breached a material provision ofthis Decree. it shall so notify the party (s), in writing, ofthe alleged breach. Upon receipt ofwritten notice, a party(s) shall have fifteen (15) days to either correct the alleged breach, and so inform the other party(s), or deny the alleged breach, in writing;
a. lrthe parties remain in dispute they shall attempt in good faith to resolve their dispute; b. If the parties can not in good faith resolve their dispute, the party alleging a breach may file with the Court a motion to correct and remedy the breach; c. Each party shall bear its own costs, expenses and attomey's fees incurred in connection with such action; and d. Jurisdiction and venue to resolve any dispute arising under this Decree resides in the United States District Court for the District of Maryland.
TERM OF CONSENT DECREE 13. This Decree shall remain in full force and effect for a period of three (3) years from the date of approval and entry of this Decree by the Court. 14. The Court shall retain jurisdiction of this action to ensure compliance with this Decree. In all other respects, upon approval and entry by the Court ofthis Decree. this action is di smissed with prejudice and the Clerk of the Court is directed to remove this action from the Court's calendar.
)1ISCELLANEOUS 15. The Commission reserves the right to monitor compliance with the provisions of this
8

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 9 of 12
Decree. As part of such review, the EEOC may require written reports concerning compliance, inspect Defendants' premises, interview w'itnesses, and examine and copy documents.
16. The Commission, and Defendants shall bear their own costs, expenses and attorneys' fees incurred in connection \vith this action.
17. The undersigned counsel ofrecord, on behalf of their respecti,le clients, and Defendants representative hereby consent to the entry ofthe foregoing Consent Decree.

BY CONSENT:

FOR DEFENDANTS:

FOR PLAr~TlFF:

RG's FOOD SHOPS OF PENNSYLVANIA,
I~C.

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

I HEREBY CERTIFY THAT I AM

AUTHORIZED TO BIND THE ABOVE

ENTITY TO THE TERMS OF THIS

CONSENTDE;CREE BY MY SIGNATURE

. ' j~EH3Y MY/SIGNATURE DO SO.

/"

.

GWE)JDOLTh' YOUNG REAMS Associate General Counsel

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GEM D S. KIEL

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HuJ1 Title fI2.6:s~ ". r L...v....J/ eli -"37 Regional Attomey

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Phone No. 81¥-fc:.l~-51 'S76

9

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 10 of 12

BEDFORD VALLEY PETROLEU1VI CORPORATION

I HEREBY CERTIFY THAT I AM

AUTHORIZED TO BIND THE ABOVE

ENTITY TO THE TERMS OF THIS CONSENT DK~~E BY MY SIGNATURE

CECILE C. QUINLAN

ANT TYB/YI:Nrt SIGNAT8RE DO SO. ~>/

Senior Trial Attomey EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

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10 So. Howard Street, 3rd FI.

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Baltimore Maryland 21201

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962-4239

Phone No. 8"/y-fA:) '3 -51.5:7

. 'vVADDELl, ESQ. 300 West Martin Street Martinsburg, West Virginia 25401

13 SO ORDERED this

lit Day of

~ 2005.

THE HONORABL~ WILLIA.v11v1. .NICKERSON Senior Uni ted States District Judge

10

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 11 of 12

EQUAL

,:~~'\Jf.\'-~M~{R~.
'~.

EMPLOYMENT OPPORTUNITY

COMMISSION

POSTED PURSUANT TO A CONSENT DECREE BETWEEN THE EEOC ANDRG's FOOD SHOPS OF PA,
INC. AND BEDFORD VALLEY PETROLEUM, INC.

This Notice is being posted ! unwelcome flirtation, lewd written or for sexual favors, or the

pursuant to a Consent Decree spoken 'words, sexual jokes and physical or verbal conduct of a

bet\veen the Equal Employment offensive or sexual suggestive sexual nature by a supervisor or

Opportunity Commission (EEOC) gestures.

co-worker creates a hostile

and .RG's Food Shops of

working environment.

Pennsylvania, Inc. (RG's Food Harassment on the basis of sex is a

Shops) and Bedford Valley violation of Title VlI. Unwelcome The conduct need not be

Petroleum Corporation (Bedford sexual advances, requests for sexual offensive to all employees or

Valley).

favors, and other verbal or physical speci ficaUy directed at the

conduct of a sexual nature constitute employee who is complaining

Sexual harassment is a fonn ofsex sexual harassment when:

to create a sexually hostile

discrimination under Title VII of

work environment.

the Civil Rights Act of 1964, as (1) submission to such conduct is

amended, 42 U.S.c. §2000e et.~. made either explicitly or implicitly a ! RG's Food Shops and Bedford

Sexual Harassment may be defined condition of an individual's Valley strictly forbids any

as unwanted sexual ~dvances or employment,

emplo}'ee from engaging in any

demands experienced in an

oflhe above described conduct.

employment relationship. The (2) submission or rejection of such The Company will conduct a

Ul1\vanted behavior may include, conduct by an individual is used as prompt, speedy and thorough

but is not limited to. verbal abuse the basis for employment decisions investigation of any complaint

and humiliation, leers, indecent affecting such individual. or

and will take appropriate

suggestions, physical touching and

disciplinary measures against

sexual assault. Harassment can be (3) such conduct has the purpose or the aflending party. All

overt or subtle, and behavior that effect of unreasonably interfering complaints of sexual

may be appropriate in a non-work \vith an individual's work harassment and any infol111ation

setting may be unacceptable in the performance or creating an developed during the course of

workplace.

intimidating, hostile or offensive the investigation of these

\vorking environment.

complaints will be kept as

Examples of sexual harassment

confidential as reasonably

prohibited by RG 's Food Shops and An employee may have a claim of possible, unless administrative

Bedford Valley policy include, but sexual harassment where his or her charges or litigation is filed.

are not limited to:

advancement or job security depends

on giving in to sexual advances to a We will enforce a policy on

OfTensive or unwelcome tOl1ching supervisor or co-worker or when sexual harassment to prevent

or other physical contact, unwelcome sexual advances, request sexual harassment in the

Case 1:04-cv-03038-WMN Document 34 Filed 12/13/2005 Page 12 of 12

workplace. If a employee is found a charge, the giving of testimony or

to have engaged in sexual assistance, or the participation in any

harassment, that employee will be investigation, proceeding, or hearing

subject to disciplinary measures under Title VII.

appropriate to the severity of the

offense, up to and including RG's Food Shops and Bedford Valley

discharge.

I will ensure that supervisory

employees and all other employees

abide by the requirements of the

Any employee who feels she or he company's sexual harassment policy

is the victim of sexual harassment and commit that sexual harassment

should report the harassment to his and retaliation will not be condoned.

or her immediate supervisoL In the

event that the employee's

snpen'isor is the party committing

the sexual harassment, or the A copy of this l\'otice will be posted

employee is not comfortable \vith in a conspicuous place where

this option, the employee should employee notices arc ordinarily

report the harassment to the Human placed and will be replaced if it

Resource Manager, Cindy Reiley or becomes defaced, marred or

Vice President of Sales, Gary otherwise made unreadable.

RummeH ( tel 11 800-654-4328 or

814-623-5151) or anv other

mem ber of management. .

Additionally, anyone who observes or lcams of conduct that violates RG's Food Shops' or Bedford Valley's sexual harassment policy should rep0l1 it immediately to any available supervisor or to the Human Resource Manager, Cindy Reiley or Vice President of Sales, Gary Rummell ( tel # 800-6544328 or 814-623-5151).

Date Posted: Date Expires: By:

Any supervisor who docs not take prompt and appropriate action to respond to a complaint of sexual harassment will be subject to disciplinary measures,
YOll also have the right to file a charge with the Equal Employment Opportunity Commission, Baltimore District Office, lOS. Howard Street, 3 rd Floor, Baltimore, MD 2120 I, 410-9623933.
RG's Food Shops and Bedford Valley will not discriminate or retaliate in any manner against any person because ofopposition to any practice declared unlawful under Title VII or because of the filing of

(Name and Title) RG's Food Shops of' Pennsylvania, Inc.
By:
(Name and Title) Bedford Valley Petro leu m Corporation

EXHIBIT A

 
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CASREF, CLOSED
U.S. District Court District of Maryland (Baltimore) CIVIL DOCKET FOR CASE #: 1:04-cv-03038-WMN

Equal Employment Opportunity Commission v. RG's Food Shops of Pennsylvania, Inc. et al Assigned to: Judge William M Nickerson Cause: 42:2000 Job Discrimination (Sex)

Date Filed: 09/22/2004 Date Terminated: 04/03/2006 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Ronald L Phillips Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14102092737 Fax: 14109624270 Email: ronald.phillips@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cecile Celeste Quinlan Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624260 Fax: 14109624270 Email: cecile.quinlan@eeoc.gov ATTORNEY TO BE NOTICED

Gerald S Kiel US Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624207 Fax: 14109624270 Email: gerald.kiel@eeoc.gov ATTORNEY TO BE NOTICED

Gwendolyn Young Reams U S Equal Employment Opportunity

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District of Maryland (CM/ECF Live 3.0) - Docket Report
Intervenor Plaintiff Lisa M White V. Defendant RG's Food Shops of Pennsylvania, Inc.
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Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624260 Fax: 14109622817
Michele Hansen Cabrera Law Offices of David C Gardner 600 Jefferson Plz Ste 308 Rockville, MD 20852 13017628475 Fax: 13012179297 Email: mcabrera@davidgardnerlaw.com TERMINATED: 09/08/2005 ATTORNEY TO BE NOTICED
Tracy Hudson Spicer Equal Employment Opportunity Commission City Crescent Bldg 10 S Howard St Third Fl Baltimore, MD 21201 14109624623 Fax: 14109624270 Email: tracy.spicer@eeoc.gov ATTORNEY TO BE NOTICED
represented by Harry P Waddell Law Office of Harry P Waddell 300 W Martin St Martinsburg, WV 25401 13042634988 Fax: 13042622498 Email: Hwad50@aol.com ATTORNEY TO BE NOTICED
represented by Eyana Jenice Smith Seyfarth Shaw LLP 815 Connecticut Avenue NW Ste 500 Washington, DC 20006 12028285380 Fax: 12028285393 Email: esmith@seyfarth.com ATTORNEY TO BE NOTICED
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Defendant Bedford Valley Petroleum Corporation

Helen G Kirsch 4710 Chevy Chase Blvd Chevy Chase, MD 20815 13016568142 TERMINATED: 09/13/2005 ATTORNEY TO BE NOTICED
Kristen D Krizner The Krizner Group 1660 Metropolitan Circle Tallahassee, Fl 32308 18503863747 Fax: 18509071246 Email: kkrizner@thekriznergroup.com ATTORNEY TO BE NOTICED
Michele Hansen Cabrera (See above for address) TERMINATED: 09/08/2005 ATTORNEY TO BE NOTICED
William T Krizner The Krizner Group 1660 Metropolitan Circle Tallahassee, Fl 32308 18503863747 Fax: 18509071246 Email: bkrizner@thekriznergroup.com ATTORNEY TO BE NOTICED
represented by Bridnetta D Edwards Reed Smith LLP 1301 K St NE Ste 1100 East Washington, DC 20005 12024149200 Fax: 12024149299 Email: bedwards@reedsmith.com ATTORNEY TO BE NOTICED
Eyana Jenice Smith (See above for address) ATTORNEY TO BE NOTICED
Helen G Kirsch (See above for address) TERMINATED: 04/19/2005 ATTORNEY TO BE NOTICED

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Kristen D Krizner (See above for address) ATTORNEY TO BE NOTICED
Michele Hansen Cabrera (See above for address) TERMINATED: 09/08/2005 ATTORNEY TO BE NOTICED
William T Krizner (See above for address) ATTORNEY TO BE NOTICED

Date Filed 09/22/2004 09/22/2004 09/23/2004
09/23/2004
11/16/2004 01/12/2005 01/12/2005 01/13/2005 01/13/2005 01/27/2005

#

Docket Text

1 COMPLAINT against Bedford Valley Petroleum Corporation, RG's Food Shops of Pennsylvania, Inc. , filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(raf, Deputy Clerk) (Entered: 09/23/2004)
JURY TRIAL DEMAND by Equal Employment Opportunity Commission. (raf, Deputy Clerk) (Entered: 09/23/2004)
2 NOTICE OF LAWSUIT AND REQUEST FOR WAIVER of Service sent to Bedford Valley Petroleum Corporation on 9/23/04 by Equal Employment Opportunity Commission. (Attachments: # 1 Waiver of Service)(raf, Deputy Clerk) (Entered: 09/23/2004)
3 NOTICE OF LAWSUIT AND REQUEST FOR WAIVER of Service sent to RG's Food Shops of Pennsylvania, Inc. on 9/23/04 by Equal Employment Opportunity Commission. (Attachments: # 1 Waiver of Service)(raf, Deputy Clerk) (Entered: 09/23/2004)
4 MOTION to Intervene by Lisa M White. Responses due by 12/3/2004 (Attachments: # 1 Exhibit proposed complaint)(Waddell, Harry) (Entered: 11/16/2004)
5 NOTICE by Equal Employment Opportunity Commission of Paper Filing (Spicer, Tracy) (Entered: 01/12/2005)
6 MOTION for Alternative Service by Issuance of Summons to Defendants by Equal Employment Opportunity Commission. Responses due by 1/29/2005 (Spicer, Tracy) (Entered: 01/12/2005)
7 PAPERLESS ORDER granting 6 Motion for Alternative Server. Signed by Judge William M Nickerson on 1/13/05. (cae, Chambers) (Entered: 01/13/2005)
8 Summons Issued 20 days as to RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. (mcb, Deputy Clerk) (Entered: 01/13/2005)
9 ORDER granting 4 Motion of Lisa White to Intervene. Signed by Judge William M Nickerson on 1/27/05. (mcb, Deputy Clerk) (Entered: 01/27/2005)

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01/27/2005 01/27/2005 02/03/2005
02/03/2005 03/01/2005 03/01/2005 03/01/2005 03/15/2005 03/29/2005 03/29/2005 03/29/2005 03/29/2005 04/15/2005 04/29/2005 05/24/2005 06/23/2005

10 Intervenor COMPLAINT and Jury Trial Demand , filed by Lisa M White.(mcb, Deputy Clerk) (Entered: 01/27/2005)
11 AFFIDAVIT of Service for complaint served on Defendants' registered agent(s) on 1/19/05, filed by Equal Employment Opportunity Commission. (Quinlan, Cecile) (Entered: 01/27/2005)
12 MOTION for Extension of Time to File Answer Unopposed Motion for Enlargement of Time by RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. Responses due by 2/20/2005 (Kirsch, Helen) (Entered: 02/03/2005)
13 PAPERLESS ORDER granting 12 Motion for Extension of Time to Answer. Signed by Judge William M Nickerson on 2/3/05. (cae, Chambers) (Entered: 02/03/2005)
14 ANSWER to Complaint by Bedford Valley Petroleum Corporation.(Kirsch, Helen) (Entered: 03/01/2005)
15 ANSWER to Complaint by RG's Food Shops of Pennsylvania, Inc..(Kirsch, Helen) (Entered: 03/01/2005)
16 SCHEDULING ORDER: Status Report due by 7/14/2005. Signed by Judge William M Nickerson on 3/1/05. (mcb, Deputy Clerk) (Entered: 03/01/2005)
17 Report re: Deposition hours (Phillips, Ronald) (Entered: 03/15/2005)
18 MOTION for Kristen D. Krizner to Appear Pro Hac Vice by RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. (jnl, Deputy Clerk) (Entered: 03/30/2005)
19 ORDER granting 18 Motion of defendants for Kristen D. Krizner to Appear Pro Hac Vice (fee pd). Signed by Deputy Clerk on 3/29/05. (jnl, Deputy Clerk) (Entered: 03/30/2005)
20 MOTION for William T. Krizner to Appear Pro Hac Vice by RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. (jnl, Deputy Clerk) (Entered: 03/30/2005)
21 ORDER granting 20 Motion of defendants for William T. Krizner to Appear Pro Hac Vice (fee pd). Signed by Deputy Clerk on 3/29/05. (jnl, Deputy Clerk) (Entered: 03/30/2005)
22 NOTICE to Substitute Attorney (Hansen, Michele) (Entered: 04/15/2005)
23 Local Rule 103.3 - Corporate Disclosure Statement by Bedford Valley Petroleum Corporation. (Hansen, Michele) Modified on 5/2/2005 (mcb, Deputy Clerk). (Entered: 04/29/2005)
24 Corporate Disclosure Statement by RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. (Hansen, Michele) (Entered: 05/24/2005)
25 Joint MOTION for Extension of Time and Modification of Scheduling Order and Request for Court Settlement/ADR Conference by Equal Employment Opportunity Commission, RG's Food Shops of Pennsylvania, Inc., Bedford Valley Petroleum Corporation. Responses due by 7/11/2005 (Hansen, Michele)

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06/23/2005 06/24/2005
06/27/2005
08/25/2005 09/08/2005 09/12/2005
09/13/2005
09/13/2005 09/14/2005 09/14/2005 11/29/2005 12/13/2005 12/14/2005

(Entered: 06/23/2005)
26 PAPERLESS ORDER granting 25 Motion for Extension of Time. Signed by Judge William M Nickerson on 6/23/05. (cae, Chambers) (Entered: 06/23/2005)
27 ORDER REFERRING CASE to Magistrate Judge Susan K. Gauvey for Settlement or other ADR Conference. Signed by Judge William M Nickerson on 6/24/05. (mcb, Deputy Clerk) (Entered: 06/27/2005)
28 ORDER SETTING date for a Settlement Conference. Signed by Judge Susan K. Gauvey on 6/27/05. (Attachments: # 1 Mediation Article)(mcb, Deputy Clerk) (Entered: 06/27/2005)
29 NOTICE to Substitute Attorney for Defendants (Smith, Eyana) (Entered: 08/25/2005)
30 Settlement Conference - RESCHEDULING to Wednesday, September 14, 2005, at 9:30 a.m. (Gauvey, Susan) (Entered: 09/08/2005)
31 MOTION to Withdraw as Attorney of Helen G. Kirsch by RG's Food Shops of Pennsylvania, Inc.. Responses due by 9/29/2005 (Smith, Eyana) (Entered: 09/12/2005)
32 PAPERLESS ORDER granting 31 Motion to Withdraw as Attorney. Attorney Helen G Kirsch terminated. Signed by Judge William M Nickerson on 9/13/05. (cae, Chambers) (Entered: 09/13/2005)
Telephone Settlement Conference held on 9/13/2005 before Judge Susan K. Gauvey. (mcb, Deputy Clerk) (Entered: 09/13/2005)
Settlement Conference held on 9/14/2005 before Judge Susan K. Gauvey. (mcb, Deputy Clerk) (Entered: 09/15/2005)
Judge Susan K. Gauvey no longer assigned to case. (mcb, Deputy Clerk) (Entered: 09/15/2005)
33 Request for Status Report Status Report due by 12/9/2005. (cae, Chambers) (Entered: 11/29/2005)
34 SETTLEMENT AGREEMENT Consent Decree by Equal Employment Opportunity Commission. (Quinlan, Cecile) (Entered: 12/13/2005)
35 CONSENT DECREE and Approval. Signed by Judge William M Nickerson on 12/13/05. (mcb, Deputy Clerk) (Entered: 12/14/2005)

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