IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

United States District Court 6outhern District of Texas
FILED
SEP 2 9 1999
Michael N. Milby, Clerk

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

Plaintiff,

)

)

v.

)

)

)

J. HOLT ENTERPRISES, d/b/a Sirloin Stockade )

_____________D_e_f_en_d_an_t.___________))

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Civil
COMPLAINT
JURY TRIAL DEMAND

NATURE OF ACTION This is an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I of the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of sex, female, and to provide appropriate reliefto Donna Butler, and a class ofother similarly situated females, who were adversely affected by such practices. The Commission alleges that the women were sexually harassed by male supervisors while employed by J. Holt Enterprises d/b/a Sirloin Stockade.
JURISDICTION AND VENUE 1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§451, 1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant to Sections 706(f)(1) and (3) ofTitle VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§2000e-5(f)(l) and (3)("Title VII") and Section 102 ofTitle I ofthe Civil Rights Act of 1991,42 U.S.C. §1981A. 2. The employment practices alleged to be unlawful were and are being committed within the jurisdiction ofthe United States District Court for the Southern District ofTexas, Corpus Christi Division.

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PARTIES

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

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

enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and

(3) ofTitle VII, 42 U.S.C. §2000e-5(f)(1) and (3).

4. At all relevant times, Defendant J. Holt Enterprises has continuously been a Texas

corporation, doing business in the State of Texas and the City of Kingsville, and has continuously

had at least fifteen employees.

5. At all relevant times, Defendant J. Holt Enterprises has continuously been an

employer engaged in an industry affecting commerce within the meaning ofSection 701 (b), (g), and

(h) ofTitle VII, 42 U.S.C. §§2000e-(b), (g), and (h).

STATEMENT OF CLAIMS

6. More than thirty days prior to the institution of this lawsuit, Donna Butler filed a

charge with the Commission alleging violations of Title VII by J. Holt Enterprises. All conditions

precedent to the institution of this lawsuit have been fulfilled.

7. Since at least October 1997, Defendant J. Holt Enterprises has engaged in unlawful

employment practices at its Sirloin Stockade restaurant located in Kingsville, Texas, in violation of

Section 703(a)(1) of Title VII, 42 U.S.C. §2000e-2(a)(l). The unlawful practices include the

following:

a.

Butler was subjected to unwelcome verbal and sexual harassment by the restaurant

manager, Ronnie Holt, and the restaurant assistant manager, Jose Soliz;

b. Other similarly situated females employed by J. Holt Enterprises, at their Sirloin

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Stockade restaurant in Kingsville, Texas, were sexually harassed by Ronnie Holt, Jose Soliz and/or by one other male manager, Brad Woodard; 8. The effect of the practices complained of in paragraph seven above has been to deprive Butler and other similarly situated females of equal employment opportunities and to otherwise adversely affect their status as employees, because of their sex, female. 9. The unlawful employment practices complained of in paragraph seven were and are intentional. 10. The unlawful employment practices complained of in paragraph seven above were and are being done with malice or reckless indifference to the federally protected rights ofButler and other similarly situated females.
PRAYER FOR RELIEF
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Wherefore, the Commission respectfully requests that this Court:
A. Grant a permanent injunction enjoining Defendant J. Holt Enterprises, its officers,
successors, assigns, and all persons in active concert or participation with it, from engaging in conduct which discriminates on the basis of sex, including sexually harassing any employee, or creating a sexually hostile work environment.
B. Order Defendant J. Holt Enterprises to institute and carry out policies, practices, and
programs which provide equal employment opportunities for its employees and which eradicate the effects of its past and present unlawful employment practices.
C. Order Defendant J. Holt Enterprises to make whole Butler and other similarly situated
females who were subjected to sexual harassment by providing them with compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph
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seven above, including but not limited to medical and/or insurance expenses, in amounts to be determined at trial.
D. Order DefendantJ. Holt Enterprises to make whole Butler and other similarly situated females who were subjected to sexual harassment by providing them with compensation for past and future non-pecuniary losses resulting from the unlawful practices complained ofin paragraph seven above, including, but not limited to, emotional pain, suffering, stress, humiliation, loss ofcredit, and loss of enjoyment of life, in amounts to be determined at trial.
E. Order Defendant J. Holt Enterprises to pay Butler and other similarly situated females who were subjected to sexual harassment punitive damages for its malicious and reckless conduct described in paragraphs seven, eight, nine and ten 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 Commission its costs in this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its complaint. Respectfully submitted, C. GREGORY STEWART General Counsel Designate GWENDOLYN YOUNG REAMS Associate General Counsel
ROBERT B. HARWIN Regional Attorney State Bar No. 076083 (District of Columbia)
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LINDA GUT Supervisory rial Attorney Texas State Bar No. 08642750 Southern District No. 14464
CYN HIAM. C 0 Trial Attorney Texas State Bar No. 00790420 EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION San Antonio District Office 5410 Fredericksburg Road Suite 200 San Antonio, Texas 78229 (210) 281-7619 (210) 281-7669 (Fax) ATTORNEYS FOR PLAINTIFF
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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

Unltsd States Distr icl Court
Southem District ef Texas FILED
MAR 2 1 2000

EQUAL EMPLOYMENT OPPORTUNITY

} •

MICHAeL N. ~BY ClERK

COMMISSION,

}

Plaintiff,

)

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v.

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} Civil Action.No. C-99-401

)

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J. HOLT ENTERPRISE d/b/a SIRLOIN }

STOCKADE,

)

_______________D__e_fe_n_d_a_n_t_.__________

)
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JOINT MOTION TO ENTER CONSENT DECREE
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TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW, Plaintiff Equal Employment Opportunity Commission

("EEOC") and Defendant J. Holt Enterprises d/b/a Sirloin Stockade

(~Holt Enterprises"), and file this, their Joint Motion to Enter

Consent Decree in the above-captioned civil matter. In support of

this Motion, the parties respectfully show the Court as follows:

EEOC and Holt Enterprises have resolved, compromised, and

settled all matters at issue in this litigation, as evidenced by
•
their signatures on the Consent Decree accompanying this Motion.

WHEREFORE, PREMISES CONSIDERED, Plaintiff Equal Employment

Opportunity Commission and Defendant Holt Enterprises respectfully

request that this Court enter the Consent Decree attached to this

Motion.

Dated: - - - - - - -

Respectfully submitted,

C. GREGORY STEWART General Counsel

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GWENDOLYN YOUNG REAMS Associate General Counsel

ROBERT B. HARWIN Regional Attorney D.C. State Bar No. 076083

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LINDA GUTIERREZ

Supervisory Trial Attorney

Texas State Bar No.· 08642750

Southern District No. 14464

Attorney State Bar No. 10144696 Southern District No. 17078
LAUREN R. WOOD State Bar No. 24008299 Southern District No. 24159

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Trial Attorney and Attorney in Charge Texas State Bar No. 00794465 Southern District No. 23969

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COX & SMITH INCORPORATED

EQUAL EMPLOYMENT OPPORTUNITY

112 East Pecan Street

COMMISSION

Suite 1800

San Antonio District Office

San Antonio, Texas 78205

5410 Fredericksburg Rd, Ste 200

Telephone: (210) 554-5500

San Antonio, Texas 78229-3555

Telecopier: (210) 226-8395

Telephone: (210)281-7637

Telecopier: (210) 281-7669
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ATTORNEYS FOR DEFENDANT

ATTORNEYS FOR PLAINTIFF

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

•

Plaintiff,

)

)

v.

) Civil Action No. C-99-401

)

J. HOLT ENTERPRISE d/b/a SIRLOIN )

STOCKADE,

)

_______________D__e_fe_n_d_a_n_t_.__________

)
)

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CONSENT DECREE
The parties to this Consent Decree are the Plaintiff, United
States Equal Employment Opportunity Commission ( "EEOC 11 ), and
Defendant, J. Holt Enterprise d/b/a Sirloin Stockade ("Holt
Enterprises"). This Consent Decree resolves the above-referenced
•
Civil Action No. C-99-401. The EEOC initiated this lawsuit pursuant
to Title VII of the Civil Rights Act of 1964, as amended, and Title
I of the Civil Rights Act of 1991, to correct alleged unlawful
•
employment practices on the basis of sex, female, and to provide
appropriate relief to Donna (Butler) Frasier, and a class of other
similarly situated females, who were adversely affected by such
practices. The EEOC alleges that the women were sexually harassed •
by male supervisors while employed by Holt Enterprises. Holt Enterprises denies the allegations brought by the EEOC as alleged
in the Complaint filed in this Civil Action.

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The EEOC and Holt Enterprises wish to settle this action,
without the necessity of further litigation, pursuant to the terms delineated in this Consent Decree.
IT IS ORDERED, ADJUDGED AND DECREED as follows:
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1. This Court has jurisdiction of the subject matter of this
•
action and the parties, venue is proper, and all administrative
prerequisites to the EEOC's filing of this action have been met. The parties stipulate to the Court's jurisdiction.
2. This Consent Decree resolves all issues raised in EEOC's •
complaint in this case. EEOC waives further litigation of all
issues raised in the above-referenced complaint. EEOC expressly
reserves its right, however, to process and litigate any other charges which may now be pending or may in the future be ' filed
against Holt Enterprises. 3. The duration of this Consent Decree shall be two and one-
half years from the date of its filing with the Court. This Court shall retain jurisdiction of this action during the period of this Consent Decree and may enter such other and further relief as it deems appropriate to ensure implementation and enforcement of its provisions. Any violation of the Consent Decree by Defendant or its agents or assigns shall toll the running of this two and one-
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half year period as of the date of the violation. If the Court subsequently determines this Consent Decree was violated, the two and one-half year period shall recommence and continue from the date of entry of an Order setting out such a violation or until

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such time as ordered by the Court. Should the Court find this Consent Decree was not violated, the two and one-half years period shall recommence, retroactive to the date of the filing of the pleading alleging that a violation had occurred.
• 4 . Defendant Holt Enterpr1• ses, in settlement of this
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dispute, shall pay to Donna (Butler) Frasier, the sum total of $7,700.00 (Seven Thousand and Seven Hundred Dollars); and payment shall be mailed directly to Donna Frasier at 225 N. Madison, Apt. 10 Junction City, Kansas 66441. Payment shall be made by certified
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check. Payment shall be made within 30 days after this Decree has
been entered by the Court. A copy of the check and accompanying transmittal papers shall be contemporaneously forwarded to Robert B . Harw1• n, Regional Attorney, Equal Employment Opportunity Commission, Mockingbird Plaza II, 5410 Fredericksburg Road, Suite 200, San Antonio, Texas 78229.
5. Defendant Holt Enterprises is enjoined from engaging in discriminatory treatment of its employees based on their sex, or any impermissible reason, including sexually harassing any employee, or creating a sexually hostile work environment.
6. Defendant Holt Enterpr1• ses, its agents, officers, employees, servants, successors, and assigns, shall post a notice regarding its practices, policies, and intent not to discriminate against any employee in violation of Title VII. Such notice shall be as set forth in Exhibit A, which is attached to this Decree. A
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copy of Exhibit A shall be posted at Defendant's facilities on all

employee bulletin boards and other areas where employees are likely

to congregate. The notices shall be posted within 10 days of the
filing date of this Decree and shall remain posted for the duration •
of the Decree.

7. To further the ends of this Consent Decree, within 180

days of the date of entry of this Decree, Holt Enterprises shall

provide EEO training to Holt Enterprises managers and/or supervisors of not less than 4 hours. The training shall: (a)
•
explain that sexual harassment discrimination is unlawful; (b)

instruct what conduct may constitute sexual harassment; (c) explain

the damaging effects of sexual harassment on its victims, their

families, their co-workers, and the workplace environment; (d)

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ensure that supervisors and management personnel know how to

enforce the company's anti -harassment policies; and (e) discuss the

unique aspects of enforcing a sexual harassment policy in South

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Texas with low-wage earners. Within 30 days prior to the date

scheduled for this training, Holt Enterprises shall furnish to the EEOC a written report describing the sexual harassment discrimination training to be attended by the employees referred to

in this paragraph, identifying the instructor(s) and describing

his/her/their qualifications to conduct such training, and the EEOC shall have the right to approve the training and the instructor.

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8. Holt Enterprises agrees not to disclose the filing of

this complaint, or the underlying charge filed by Donna (Butler)

Frasier or any named class me~er, to any prospective employers who

may inquire to Holt Enterprises about Donna (Butler) Frasier's or
.
any named class member's work history with Holt Enterprises. This

provision shall survive the expiration of the Decree.

9. The EEOC shall have the right to ensure compliance with

the terms of this Decree and may: (a) conduct inspections of

Defendant Holt Enterprise's facilityi (b) interview employeesi and • (c) examine and copy relevant documents at any time.

10. The terms of this Consent Decree shall be binding upon

the EEOC and Defendant Holt Enterprises, its agents, officers,

employees, servants, successors, and assigns, as to the issues

resolved herein.

11. Each party shall bear its own costs, including attorney• s

fees, incurred in this action.

12. The parties agree that, pursuant to Section 706(k) of

Title VII, 42 U.S.C. §2000e-5 (k), there is no "prevailing party" l' n

this action or proceeding.

The Clerk shall furnish a copy hereof to each attorney of

record.

SO ORDERED.

Signed this

day of ---------------' 2000 .

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H.W. HEAD, JR. United States District Judge
Respectfully Submitted,
C. GREGORY STEWART General Counsel
GWENDOLYN YOUNG REAMS Associate General Counsel

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ROBERT B. HARWIN Regional Attorney D.C. State Bar No. 076083
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LINDA GUTIERREZ Supervisory Trial Attorney Texas State Bar No. 08642750 Southern District No. 14464

BURKE HUBER I

0

Attorney

State Bar No. 10144696

Southern District No. 17078

LAUREN R. WOOD State Bar No. 24008299 Southern District No. 24159

COX & SMITH INCORPORATED 112 East Pecan Street
Suite 1800 San Antonio, Texas 78205 Telephone: (210)554-5500 Telecopier: (210) 226-8395

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CANO Trial Attorney and Attorney in Charge Texas State Bar No. 00794465 Southern District No. 23969
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
San Antonio District Office 5410 Fredericksburg Rd, Ste 200 San Antonio, Texas 78229-3555 Telephone: (210) 281-7637 Telecopier: (210) 281-7669

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ATTORNEYS FOR DEFENDANT

ATTORNEYS FOR PLAINTIFF

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NOTICE TO ALL EMPLOYEES

J. HOLT ENTERPRISE D/B/A SIRLOIN STOCKADE SUPPORTS FEDERAL LAW

REQUIRING THERE BE NO DISCRIMINATION AGAINST ANY APPLICANT OR

EMPLOYEE BECAUSE OF HIS OR HER RACE, COLOR, SEX, NATIONAL ORIGIN,
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RELIGION, AGE OR DISABILITY AND REAFFIRMS ITS COMMITMENT NOT TO

DISCRIMINATE AGAINST ANY APPLICANT OR EMPLOYEE ON ANY TERM OR
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CONDITION OF EMPLOYMENT, NOR TO ALLOW HARASSMENT OF ANY EMPLOYEE

BECAUSE OF HIS OR HER SEX.

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J. HOLT ENTERPRISE D/B/A SIRLOIN STOCKADE WILL NOT DISCRIMINATE

AGAINST ANY EMPLOYEE FOR OPPOSING EMPLOYMENT DISCRIMINATION OR FOR

FILING OR PARTICIPATING IN A CHARGE OF EMPLOYMENT DISCRIMINATION.

IF YOU BELIEVE YOU ARE BEING DISCRIMINATED AGAINST IN ANY TERM OR

CONDITION OF YOUR EMPLOYMENT BECAUSE OF YOUR RACE, RELIGION, COLOR,

NATIONAL ORIGIN, SEX, AGE, OR DISABILITY, OR THAT YOU ARE BEING SUBJECTED

TO HARASSMENT BECAUSE OF YOUR SEX OR HAVING ENGAGED IN TITLE Vll-

PROTECTED ACTIVITY, YOU ARE ENCOURAGED TO SEEK ASSISTANCE FROM

SUPERVISORY PERSONNEL, THE PERSONNEL DEPARTMENT, OR FROM THE UNITED

STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, 5410 FREDERICKSBURG ·

ROAD, SUITE 200, SAN ANTONIO, TEXAS 78229-3550, (210) 281-7600 OR 1-800-669-4000.

NO RETALIATORY ACTION MAY BE TAKEN AGAINST YOU FOR SEEKING
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ASSISTANCE, FILING A CHARGE, OR COMMUNICATING WITH THE UNITED STATES

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION.

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EEOC ENFORCES TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, WHICH
PROHffiiTS EMPLOYMENT DISCRIMINATION BASED ON RACE, COLOR, RELIGION, SEX
ORNATIONALORIGIN; THEAGEDISCRIMINATIONINEMPLOYMENT ACT; THE EQUAL
PAY ACT; PROHffiiTIONS AGAINST DISCRIMINATION AFFECTING INDIVIDUALS WITH •
DISABILITIES; SECTIONS OF THE CIVIL RIGHTS ACT OF 1991, AND TITLE I OF THE
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AMERICANS WITH DISABILITIES ACT, WHICH PROHffiiTS DISCRIMINATION AGAINST
PEOPLE WITH DISABILITIES IN THE PRIVATE SECTOR AND STATE AND LOCAL
GOVERNMENTS.
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EXHIBIT "A"

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

Plaintiff,

)

v. •

)
) Civil Action No. C-99-401

)

J. HOLT ENTERPRISE d/b/a SIRLOIN )

STOCKADE,

)

_______________D__e_fe_n_d_a_n_t_.__________

)
)

FINAL JUDGMENT ORDER ENTERING CONSENT DECREE

On this day came on to be heard the parties' Joint Motion to

Enter Consent Decree. After reviewing the Consent Decree, the

Court finds that all issues in the Complaint have been disposed of,

that the parties are in agreement, and that the Consent Decree

should be entered.

It is therefore ordered that the Consent Decree is hereby

entered.

Signed this

day of _____________ ,2000.

H.W. HEAD, JR. United States District Judge

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 DC CM/ECF LIVE- US District Court-Texas Southern - Docket Report

Page 1 of 3

U.S. District Court SOUTHERN DISTRICT OF TEXAS (Corpus Christi)
CIVIL DOCKET FOR CASE #: 2:99-cv-00401

CLOSED

Equal Employment Op v. J. Holt Enterprises Assigned to: Chief Judge Hayden Head Demand: $0 Cause: 28:1331 Federal Question: Other Civil Rights

Date Filed: 09/29/1999 Date Terminated: 03/24/2000 Jury Demand: None Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by Cynthia Cano Law Office os Jeffrey A Goldberg 9901 IH-10 West Ste 690 San Antonio, TX 78230 210-690-2200 Fax: 210-690-0438 Email: cmc_goldberglaw@sbcglobal.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

Linda Gutierrez EEOC 5410 Fredericksburg Rd Ste 200 San Antonio, TX 78229-3555 210-281-7637 Fax: 210-281-7669 fax ATTORNEY TO BE NOTICED

Robert B Harwin EEOC 5410 Fredericksburg Rd Ste 200 San Antonio, TX 78229-3555 210-229-4830 ATTORNEY TO BE NOTICED

V.
Defendant
J. Holt Enterprises doing business as Sirloin Stockade

represented by Edmund Burke Huber, Jr Ogletree Deakins et al 112 E Pecan St

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Date Filed 09/29/1999 09/30/1999
10/18/1999 10/20/1999
10/26/1999
10/26/1999
11/05/1999 11/05/1999 11/12/1999 11/16/1999

Ste 2600 San Antonio, TX 78205 210-354-1300 Fax: 210-227-2702 fax Email: burke.huber@ogletreedeakins.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Lauren Renee Wood Cox & Smith 112 E Pecan Ste 1800 San Antonio, TX 78205 210-554-5397

#

Docket Text

1 COMPLAINT by Equal Employment Op filed; (drodrigues) (Entered: 10/05/1999)

2 ORDER FOR CONFERENCE AND DISCLOSURE OF INTERESTED PARTIES set scheduling conference for 1:30 1/20/00 before Judge Hayden W. Head Jr. , entered; Parties notified. (drodrigues) (Entered: 10/05/1999)

3 DISCLOSURE OF INTERESTED PARTIES by Equal Employment Op , filed. (drodrigues) (Entered: 10/20/1999)

4 MOTION for Cynthia M. Cano to appear pro hac vice Cynthia Cano for plaintiff Equal Employment Op, Motion Docket Date 11/9/99 [4-1] motion , filed. (drodrigues) (Entered: 10/21/1999)

5 ORDER granting [4-1] motion for Cynthia M. Cano to appear pro hac vice , entered; Parties notified. ( signed by Judge Hayden W. Head Jr. ) (drodrigues) (Entered: 10/28/1999)

6 ORDER striking [3-1] interested party certificate , entered; Parties notified. ( signed by Judge Hayden W. Head Jr. ) (drodrigues) (Entered: 10/28/1999)

7 WAIVER OF SERVICE Returned Executed as to J. Holt Enterprises 10/29/99 , filed. (drodrigues) (Entered: 11/08/1999)

8 CERTIFICATE OF FINANCIAL INTEREST by J. Holt Enterprises , filed. (drodrigues) (Entered: 11/09/1999)

9 DISCLOSURE OF INTERESTED PARTIES by Equal Employment Op , filed. (drodrigues) (Entered: 11/16/1999)

10 ORDER striking [8-1] interested party certificate , entered; Parties notified. ( signed by Judge Hayden W. Head Jr. ) (drodrigues) (Entered:

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12/17/1999 01/10/2000 01/19/2000 03/21/2000 03/24/2000 03/24/2000
03/24/2000

11/18/1999)
11 ORIGINAL ANSWER AND AFFIRMATIVE DEFENSES by J. Holt Enterprises (Added attorney Edmund Burke Huber Jr), filed. (drodrigues) Modified on 03/03/2000 (Entered: 12/17/1999)
12 JOINT DISCOVERY/Case Management Plan by Equal Employment Op, J. Holt Enterprises , filed. (drodrigues) Modified on 03/03/2000 (Entered: 01/12/2000)
13 NOTICE OF SETTLEMENT by Equal Employment Op, J. Holt Enterprises , filed (drodrigues) Modified on 03/03/2000 (Entered: 01/20/2000)
14 JOINT MOTION to enter consent decree by Equal Employment Op, J. Holt Enterprises , filed (fmremp) (Entered: 04/07/2000)
Case closed (drodrigues) (Entered: 03/27/2000)
15 FINAL JUDGMENT ORDER ENTERING CONSENT DECREE granting [14-1] joint motion to enter consent decree , entered. Parties ntfd. ( signed by Judge Hayden W. Head Jr ) (fmremp) (Entered: 04/07/2000)
16 CONSENT JUDGMENT , entered; Parties notified ( signed by Judge Hayden W. Head Jr ) (fmremp) (Entered: 04/07/2000)

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