1 WILLIAM R. TAMAYO, REGIONAL ATTORNEY 2 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
SAN FRANCISCO DISTRICT 3 350 EMBARCADERO, SUITE 500
SAN FRANCISCO, CA 94105-1260
4
JOHN STANLEY, ACTING, SUPERVISORY TRIAL ATTORNEY 5 MOLLY KUCUK, TRIAL ATTORNEY 6 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
909 FIRST AVENUE, SUITE 400 7 SEATTLE, WA 98104
TEL: (206) 220-6892 8 FAX: (206) 220-6911
Molly.Kucuk@eeoc.gov
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ATTORNEYS FOR PLAINTIFF

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IN THE UNITED STATES DISTRICT COURT

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FOR THE WESTERN DISTRICT OF WASHINGTON

AT TACOMA
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EQUAL EMPLOYMENT OPPORTUNITY

16 COMMISSION,

CIVIL ACTION NO.

17

Plaintiff,
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COMPLAINT

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v.

JURY TRIAL DEMAND

20 HOWARD S. WRIGHT CONSTRUCTION CO.,
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Defendant.
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NATURE OF THE ACTION

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This is an action under Age Discrimination in Employment Act of 1967, as amended, 29

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U.S.C. section 621 et seq. (“ADEA”), to correct unlawful employment practices on the basis of

COMPLAINT- Page 1 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883
Facsimile: (206) 220-6911 TDD: (206) 220-6882

age and to provide appropriate relief to Cecil Cheeka, who was adversely affected by such
1
2 practices. The Equal Employment Opportunity Commission (“the EEOC") alleges that 3 defendant Howard S. Wright Construction Co. (referred to herein as “Howard S. Wright” or

4 “defendant”) violated the ADEA by discriminating against Mr. Cheeka on the basis of age when

5 it terminated him from his journeyman ironworker position.

6
7
1.
8
9

JURISDICTION AND VENUE 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 7(b) of the ADEA, 29

10

U.S.C. §626(b), which incorporates by reference Sections 16(c) and 17 of the Fair Labor

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Standards Act of 1938 (the “FLSA”), as amended, 29 U.S.C. §§216(c) and 217.

12 2.
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3.
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The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Western District of Washington.
PARTIES Plaintiff, the Equal Employment Opportunity Commission, is the agency of the United States of America charged with the administration, interpretation and enforcement of the ADEA and is expressly authorized to bring this action by Section 7(b) of the ADEA, 29

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U.S.C. § 626(b), as amended by Section 2 of Reorganization Plan No. 1 of 1978, 92 Stat.

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4.
22 23 24

3781, and by Public Law 98-532 (1984), 98 Stat. 2705. At all relevant times, defendant Howard S. Wright has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 11(b), (g) and (h) of the ADEA, 29 U.S.C. §§ 630(b), (g) and (h).

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COMPLAINT- Page 2 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883
Facsimile: (206) 220-6911 TDD: (206) 220-6882

5.
1 2 3

At all relevant times, defendant Howard S. Wright has continuously been doing business in the state of Washington and has continuously had at least 20 employees.
CONCILIATION

4 6. Prior to institution of this lawsuit, the Commission’s representatives attempted to

5 6 7 8 9
10 7.

eliminate the unlawful employment practices alleged below and to effect voluntary compliance with the ADEA through informal methods of conciliation, conference, and persuasion within the meaning of Section 7(b) of the ADEA, 29 U.S.C. §626(b).
STATEMENT OF CLAIMS More than thirty days prior to the institution of this lawsuit, Cecil Cheeka filed a charge

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of discrimination with the Commission alleging a violation of the ADEA by Howard S.

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8.

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16

17

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Wright. All conditions precedent to the institution of this lawsuit have been fulfilled. On or about December 14, 2004 defendant engaged in unlawful employment practices at its worksites in Olympia, Washington in violation of Section 623 (a) of the ADEA, 29 U.S.C. §§ 623 (a). These practices include discriminating against Mr. Cheeka by terminating him from his journeyman ironworker position after only four days because of his age.

19 9. The effect of the practices complained of in paragraph 8 above has been to deprive Mr.

20

Cheeka of equal employment opportunities and otherwise adversely affected his status as

21
an employee because of the discrimination that occurred.
22
10. The unlawful employment practices complained of in paragraph 8 above were and are
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willful within the meaning of Section 7 (b) of the ADEA, 29 U.S.C. § 626 (b).
24

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COMPLAINT- Page 3 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883
Facsimile: (206) 220-6911 TDD: (206) 220-6882

PRAYER FOR RELIEF
1

2

Wherefore, the Commission respectfully requests that this Court:

3 A. Grant a permanent injunction enjoining defendant and it officers, agents, successors,

4

assigns, and all persons in active concert or participation with them, from engaging in

5

discrimination against any of their employees.

6
B. Order defendant to institute and carry out policies, practices, and programs which prevent
7
its employees from being subjected to discrimination and which eradicate the effects of
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past and present unlawful employment practices.
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10 C. Order defendant to make whole Mr. Cheeka by providing appropriate back pay in an

11

amount to be determined at trial, an equal sum as liquidated damages, prejudgment

12

interest, front pay and other affirmative relief necessary to eradicate the effects of its

13

unlawful employment practices described above.

14
D. Grant such further relief as the Court deems necessary and proper in the public interest.
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E. Award the Commission its costs of this action.
16

JURY TRIAL DEMAND
17

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The Commission requests a jury trial on all questions of fact raised by its complaint.

19

DATED this 28th day of August, 2006.

20
WILLIAM R. TAMAYO 21 Regional Attorney

RONALD S. COOPER General Counsel

22 JOHN STANLEY Acting Supervisory Trial Attorney
23
MOLLY KUCUK 24 Trial Attorney
25

JAMES L. LEE Deputy General Counsel
GWENDOLYN Y. REAMS Associate General Counsel

COMPLAINT- Page 4 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883
Facsimile: (206) 220-6911 TDD: (206) 220-6882

BY: /s/ William R. Tamayo_________ 1 EQUAL EMPLOYMENT OPPORTUNITY 2 COMMISSION
San Francisco District Office 3 350 The Embarcadero, Ste. 500
San Francisco, California 94105-1260 4 Telephone (415) 625-5645
Facsimile (415) 625-5657
5

Office of the General Counsel 1801 “L” Street NW Washington, D.C. 20507

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Attorneys for Plaintiff

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COMPLAINT- Page 5 of 5

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION
Seattle Field Office 909 First Avenue, Suite 400 Seattle, Washington 98104-1061 Telephone: (206) 220-6883
Facsimile: (206) 220-6911 TDD: (206) 220-6882

 
 1
25778
2

Honorable Ronald B. Leighton

3

4

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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

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AT TACOMA

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EQUAL EMPLOYMENT OPPORTUNITY CIVIL ACTION NO. C06-5492-RBL
11 COMMISSION

12

Plaintiff,

13

v.

[PROPOSED] CONSENT DECREE

14

HOWARD S. WRIGHT CONSTRUCTION CO.

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Defendant.

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I. INTRODUCTION

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1. This action origin ated when Cecil Cheek a filed a charge of discrim ination with

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the Equal E mployment Opportunity Comm ission ("EEOC” or “Commission"). Mr. Cheeka

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alleged that Howard S. Wright Construction Co. (“HSWCC” or “Defendant” or “the Com pany”)

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discriminated against him based on his age (t hen 60 years old), in violation of the Age

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Discrimination in E mployment Act (“ADEA”) when he was term inated by HS WCC in

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December 2004.

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2. On May 15, 2006, the EEOC issued a lette r of determ ination with a fi nding of

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reasonable cause to believe that HSWCC violat ed the ADEA. Thereaf ter, EEOC attempted to

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conciliate the charge and conciliation was unsuccessful.

26 CONSENT DECREE

27

EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1

3. The Commission filed its Com plaint on August 28, 2006, i n the United States

2 District Court for the Western District of W ashington at Ta coma. The Com plaint alleges that

3 HSWCC discharged Mr. Cheeka in violation of the ADEA.

4

4. The parties want to conclude fully and finally all claims arising out of the EEOC’s

5 Complaint and Mr. Cheeka’s charge of disc rimination filed with EEOC. The EEOC and

6 HSWCC enter in to this Consent Decree to further the objectives of equal em ployment

7 opportunity as set forth in the ADEA.

8 II. NON-ADMISSION OF LIABILITY AND NON-DETERMINATION BY THE COURT

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5. This Consent Decree is not an adju dication or finding on the m erits of this case

10 and shall not be construed as an admission by HSWCC of a violation of the ADEA.

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III. SETTLEMENT SCOPE

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6. This Consent Decree is the f inal and com plete resolution of all alleg ations of

13 unlawful employment practices contained in Mr. Cheeka’s discri mination charge, in the EEOC's

14 administrative determination, and in the Com plaint filed herein, including all claim s by the

15 parties for attorney fees and costs.

16

IV. MONETARY RELIEF

17

7. HSWCC agrees to (a) pay Mr. Cheeka $6,560.40, which amount is characterized

18 as wages from which lawful deductions will be made and on which amount HSWCC will pay

19 lawfully required taxes, (b) to make benefit contributions on Mr. Cheeka's behalf totaling

20 $2,928.20, and (c) to pay Mr. Cheeka $9,488.60, which is characterized as liquidated damages.

21

V. AFFIRMATIVE AND OTHER RELIEF

22 A. General Provisions

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8. HSWCC, its officers, agents, and employees will not engage in practices which

24 unlawfully discriminate against applicants and/or employees on the basis of age. In recognition

25

26 CONSENT DECREE

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EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1 of its obligations under the ADEA, HSWCC will institute the policies and practices set forth

2 below.

3 B. Anti-Discrimination Policies and Procedures

4

9. Defendant shall carry out anti-discrimination policies, procedures and training for

5 management personnel, supervisors, including foremen, and staff e mployees. The affir mative

6 relief requirements outlined th roughout this Consent Decree are lim ited to the State of

7 Washington.

8

10. HSWCC will submit an equal employm ent opportunity (“EEO”) policy that

9 prohibits discrimination against applicants and/or employees on the basis of age with respect to

10 any term, condition or privilege of employment, and addresses HSWCC’s obligation to provide a

11 discrimination-free work environm ent for its empl oyees. Not later th an sixty (60) days after

12 entry of this Consent Decree, HSWCC will dis tribute a written copy of it s EEO policy to all its

13 employees, both management and non-management, in the State of Washington.

14 C. Equal Employment Opportunity Training

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11. HSWCC will provide an annual EEO training se minar to all of its m anagers,

16 supervisors, including f oremen, and staff em ployees. Th is anti-discrimination training will

17 include, at a m inimum, a discuss ion of federal law proh ibiting employment discrimination,

18 including the ADEA, a nd a review of HSWCC’s EEO policies. The training will be aim ed at

19 helping attendees understand how to define and identify employment discrimination, and provide

20 information as to avenues of addressing suspected employment discrimination.

21

12. Not later than One hundred and twenty ( 120) days after entr y of this Consent

22 Decree, HSWCC will provide the EEO training noted in Paragraph 11 to all of its managers and

23 supervisors, including foremen and those responsible for hiring and discharge decisions.

24

13. Not later than one hundred and eighty days (180) afte r entry of this Consent

25 Decree, HSWCC will provide the EEO training noted in Paragraph 11 to staf f employees

26 CONSENT DECREE

27

EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1 employed at the tim e the EEO train ing seminar is scheduled. Thereafter, HSWCC will provide

2 an annual EEO training sem inar(s) for m anagers, supervisors, including forem en, and staff

3 employees in the State of Washington during the duration of the Consent Decree.

4

14. For the duration of this Consent D ecree, HSWCC will notify the EEOC of the

5 completion of the training sem inars and will sp ecify the names and job titles of the m anagers,

6 supervisors and employees who participated in and completed the training. This information will

7 be provided as part of the annual report HSWCC submits to the EEOC.

8 D. Non-Disclosure of Information

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15. HSWCC will not disclose any inform ation or make reference to any charge of

10 discrimination or this lawsuit in responding to reference requests concerning Mr. Cheeka.

11 E. Policies Designed to Promote Accountability

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16. HSWCC shall impose discipline, up to and including te rmination of employment,

13 upon any supervisor or manager who discriminates against any applicant and/or employee on the

14 basis of age, or who retaliates against any pers on who complains abou t or partic ipates in any

15 investigation or proceeding concerning any alle gation of age based discrim ination. HSWCC

16 shall communicate this policy to all of its managers and supervisors, including foremen.

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17. HSWCC shall continue to advise all m anagers and supervisors of the duty to

18 ensure compliance with anti-discrimination laws and the Company’s EEO policy. To the extent

19 HSWCC conducts perf ormance reviews, the Com pany will ho ld managers and superviso rs,

20 including foremen, accountable for EEO enforcement and compliance.

21 F. Reporting

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18. HSWCC will report to the EEOC for a peri od of two (2) years. The repo rts shall

23 be in writing and subm itted on an annual basis during the tw o year reporting period. The

24 reporting period will run from the date of the en try of this Consent Decree by the U nited States

25 District Court for the Western District of Washington.

26 CONSENT DECREE

27

EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1

19. These annual reports shall contain the following information and attachments:

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a. Certification that HSWCC has:

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1. Continued to m aintain its writte n EEO policies and procedures and

annually distributed copies of its EEO policy to all current and newly

4

hired employees and as described in Paragraph 10;

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2. Complied with the training provisions enumerated in this Consent Decree,

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as provided in Paragraphs 11-14;

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4. Continued to prom ote policies and procedures to prom ote EEO

accountability by managers and supervisors, as required by Paragraph 16-

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17.

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5. Complied with all other provisions of this Consent Decree.

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b. Copies of the followin g documents will be included with each ann ual report

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submitted to the Seattle office of the EEOC:

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1. A copy of the Com pany’s EEO polic y and procedures developed and implemented in accordance with the provisions of this Consent Decree;

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2. Copies of the EEO training m aterials utilized during the applicable

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reporting period;

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3. A sign-in sheet or list of the HSWCC names and job titles of the

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managers, supervisors and e mployees who completed EEO training and the dates the training was conducted during the previous reporting period.

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20. If applicable, HSWCC will subm it a statement with its report to th e EEOC

18 specifying the areas of noncom pliance, the reason for the noncompliance, and the steps that will

19 be taken to bring HSWCC into compliance.

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21

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26 CONSENT DECREE

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EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1 G. Posting

2

21. HSWCC will post a Notice to All E mployees. This Notice is attached as Exhibit

3

1 to this Consent Decree. The Notice sha ll be posted on a centrally located bulletin board at all

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HSWCC facilities for six months, which will run from the date of the entry of this Consent

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Decree by the United States District Court for the Western District of Washington.

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VI. ENFORCEMENT

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22. If the EEOC determ ines that HSWCC has not complied with the term s of this

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Consent Decree, the EEOC will provide written notification of the alleged breach to HSWCC.

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The EEOC will no t petition the Court for enforcement of this Consent D ecree for at least thirty

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(30) days after providing written notification of the alleged breach. The 30-day period following

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the written notice shall be used by the EEOC a nd HSWCC for good faith e fforts to resolve the

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dispute.

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VII. RETENTION OF JURISDICTION

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23. The United States District Court for th e Western District of W ashington shall

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retain jurisdiction over this matter for the duration of this Consent Decree.

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VIII. DURATION AND TERMINATION

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24. This Consent Decree shall be in effect fo r two (2) years from the date of entry of

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the Decree. If the EEOC petiti ons the Court for breach of this Consent Decree, an d the Court

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finds HSWCC to be in violation of the terms of the Consent Decree, the Court m ay extend the

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duration of this Consent Decree.

21

Dated this 20th day of

April , 2007.

22

23 WILLIAM R. TAMAYO
Regional Attorney
24 U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
25 SAN FRANCISCO DISTRICT OFFICE

26 CONSENT DECREE

27

EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

28

RONALD S. COOPER General Counsel
JAMES L. LEE Deputy General Counsel

10848 10848-06 il052601

1 350 The Embarcadero, Suite 500
San Francisco, California 94105-1260
2
3

GWENDOLYN YOUNG REAMS Associate General Counsel

4
KATHRYN B. OLSON
5 Supervisory Trial Attorney
MOLLY KUCUK
6 Trial Attorney

7 EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
8 Seattle Field Office
909 First Avenue, Suite 400
9 Seattle, Washington 98104

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Office of the General Counsel 1801 "L" Street, N.W. Washington, D.C. 20507

10

BY:__/s/ Kathryn Olson_______________
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Attorneys for Plaintiff Equal Employment Opportunity Commission

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PAUL M. NORDSLETTEN DAVIS GRIMM PAYNE & MARRA

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701 Fifth Avenue, Suite 4040 Seattle, WA 98104

16 BY: /s/Paul M. Nordsletten_______________________

17 Attorneys for Defendant 18 Howard S. Wright Construction Co.

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26 CONSENT DECREE

27

EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

1

EXHIBIT 1

2

NOTICE TO ALL EMPLOYEES

3 This notice is being posted pursuant to an agreement between Howard S. Wright Construction
Co. (“HSWCC”) and the U.S. Equal Employment Opportunity Commission (“EEOC”), entered
4 as the result of a resolution of a lawsuit in the United States District Court, EEOC v. Howard S.
Wright Construction Company, CIVIL ACTION NO. 03-5492-RBL.
5
Title VII o f the Civil Rights Act of 1964, as amended, the Age Discrim ination in
6
Employment Act of 1967, the Equal Pay Act of 1963, and the Americans with Disabilities Act of
7
8 1990 are enforced by the EEOC and require the following:

9
That there be no di scrimination against any e mployee or applicant for

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employment because of the em ployee's race, sex, color, religion, national origin,
11

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age (40 and above), or disability with respect to hiring, firing, com pensation, or

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other terms, conditions or privileges of employment.

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It is an unlawful em ployment practice fo r an employer to retaliate against any
15

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employees or applicants for employment because they have opposed a practice or

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because they have made a charge, testified, assisted, or participated in any manner

18

in an investigation, proceeding, or hearing under these statutes.

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HSWCC has posted this notice because th e company supports and will com ply
20 21 with these federal laws in all r espects. HSWCC has instituted a training program to train
22 its managers, supervisors and em ployees regarding the requirem ents of the above

23 statutes.

24

25

26 CONSENT DECREE

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EEOC v. HOWARD S. WRIGHT CONSTRUCTION CO. (C06-5492 RBL)

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10848 10848-06 il052601

 
 WAWD CM/ECF Version 3.0.4 - Docket Report

https://ecf.wawd.uscourts.gov/cgi-bin/DktRpt.pl?799376623546594-L_...

CLOSED, JURYDEMAND
U.S. District Court United States District Court for the Western District of Washington (Tacoma)
CIVIL DOCKET FOR CASE #: 3:06-cv-05492-RBL

Equal Employment Opportunity Commission v. Howard S Wright Construction Company Assigned to: Hon. Ronald B. Leighton Cause: 29:621 Job Discrimination (Age)

Date Filed: 08/28/2006 Date Terminated: 05/07/2007 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Plaintiff
Equal Employment Opportunity Commission

represented by John Freeman Stanley EQUAL EMPLOYMENT OPPORTUNITY COMMISSION SEATTLE DISTRICT OFFICE 909 FIRST AVE STE 400 SEATTLE, WA 98104-1061 206-220-6883 Fax: 206-220-6892 Email: JOHN.STANLEY@EEOC.GOV LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kathryn Blaire Olson EQUAL EMPLOYMENT OPPORTUNITY COMMISSION SEATTLE DISTRICT OFFICE 909 FIRST AVE STE 400 SEATTLE, WA 98104-1061 206-220-6883 Email: kathryn.olson@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

Molly P Kucuk US EQUAL OPPORTUNITY COMMISSION 909 1ST AVE STE 400 SEATTLE, WA 98104 206-220-6892 Email: molly.kucuk@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED

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WAWD CM/ECF Version 3.0.4 - Docket Report
V. Defendant Howard S Wright Construction Company

https://ecf.wawd.uscourts.gov/cgi-bin/DktRpt.pl?799376623546594-L_...
William R. Tamayo EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office 350 The Embarcadero Suite 500 San Francisco, CA 94105-1260 415-625-5645 Fax: 415-625-5657 LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Paul Milton Nordsletten DAVIS GRIMM PAYNE & MARRA 701 FIFTH AVE STE 4040 SEATTLE, WA 98104 206-447-0182 Fax: FAX 206-622-9927 Email: pnordsletten@davisgrimmpayne.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 08/28/2006 08/28/2006 08/28/2006
09/18/2006 10/02/2006 11/15/2006

#

Docket Text

1 COMPLAINT (Summons(es) issued) (Receipt waived) (Attachments: # 1 Civil Cover Sheet # 2 Case Opening Info Sheet)(DN, ) (Entered: 08/28/2006)
2 ORDER REGARDING DISCOVERY AND DEPOSITIONS by Judge Ronald B. Leighton. (DN, ) (Entered: 08/28/2006)
3 ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT FRCP 26f Conference Deadline is 11/13/2006.Initial Disclosure Deadline is 11/20/2006. Joint Status Report due by 11/27/2006; by Judge Ronald B. Leighton. (DN, ) (Entered: 08/28/2006)
4 SERVICE OF SUMMONS and Complaint returned executed upon defendant Howard S Wright Construction Company on 9/12/2006 (CAR, ) (Entered: 09/19/2006)
5 ANSWER to Complaint by Howard S Wright Construction Company.(Nordsletten, Paul) (Entered: 10/02/2006)
6 JOINT STATUS REPORT AND DISCOVERY PLAN filed by all parties. Est. Trial Days: 5 by Plaintiffs Equal Employment Opportunity Commission, Equal Employment Opportunity Commission.(Kucuk, Molly) (Entered: 11/15/2006)

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12/01/2006
04/20/2007 05/07/2007

7 MINUTE ORDER SETTING TRIAL, PRETRIAL DATES AND ORDERING MEDIATION; Length of Trial: *5 DAYS*. Jury Trial is set for 10/29/2007 at 09:30 AM before Hon. Ronald B. Leighton. Joinder of Parties due by 1/2/2007; Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 5/2/2007; Motions due by 6/11/2007; Discovery completed by 7/2/2007; Dispositive motions due by 7/31/2007; Settlement conference to be held by 8/30/2007; 39.1 mediation to be completed by 10/1/2007; 39.1 Settlement Report due by 10/9/2007; Motions in Limine due by 10/1/2007; Pretrial Order due by 10/12/2007; Pretrial Conference set for 10/19/2007 at 08:30 AM in B Courtroom before Hon. Ronald B. Leighton. Trial briefs to be submitted by 10/17/2007; Proposed voir dire/jury instructions due by 10/17/2007; s/Jean Boring as authorized by Judge Ronald B. Leighton. (JAB, ) (Entered: 12/01/2006)
8 Proposed MOTION to Approve Consent Judgment by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Proposed Order)(Olson, Kathryn) (Entered: 04/20/2007)
9 ORDER granting 8 Motion to Approve Consent Judgment, signed by Judge Ronald B. Leighton.(DN, ) (Entered: 05/07/2007)

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