cae

1. Hewyt Mahon Johnson

625 Dilger Avenue Unit 222

Waukegan, Iinois 60085
\ | (847) 596-2653

March 18, 2005

Mark Fuss, Region Sales Manager
Orkin Pest Control

1119 Glen Rock Avenue
Waukegan, Illinois 60085

(847) 662-4316

(847) 244-9032 fax

Subject: Employment Records
SS# SE Date of Birth: >
Dear Mr. Fuss:

Pursuant to federal and state laws, please make available copies of gil information used in
making decisions relevant to my employment.

Such information include but are not limited to ail pages of my original employment
application, background investigation results, physical, and drug screen results, questionnaire
results, disclosures, forms, memos, and notes.

Very truly yours,

Irenn H. Johnson



U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Chicago District Office
500 West Madison Street, Suite 2000
Chicago. 11. 60661
(312) 869-8000
PTY (312) 869-2001
FAX (312) 869-8077

In the matter of:
EEOC Charge No. 210-2006-01523

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

AND

irenn Johnson Charging Party
7017 60" Avenue

#101

Kenosha, WI 53142

vy.

Orkin, LLC Respondent
2170 Piedmont Road NE
Atlanta, GA 30324

Vv.

Rollins, Inc. Respondent
2170 Piedmont Road NE
Atlanta, GA 30324

‘, CONCILIATION AGREEMENT

An investigation having been made under Title VII of the Civil Rights Act of 1964, as amended.
(Title VII) by the U.S. Equal Employment Opportunity Commission (“EEOC”) and EEOC
having found that the evidence obtained in the investigation establishes reasonable cause to
believe that Respondents violated Title VII by maintaining an arbitration policy, which the
EEOC believes retaliates against employees, including Charging Party, by preventing them from
engaging in protected activity and retaliating against them for engaging in protected activity, and
Respondents having expressly denied that their arbitration policy was or is in any way, unlawful
or that they in any way discriminated or retaliated against any employee, the Parties do resolve
and conciliate this matter as follows:



JOHNSON will take any and all required steps or actions necessary to dismiss and will
move to dismiss, with prejudice, the DISPUTE, in its entirety, against the COMPANY,
now pending before the Equal Employment Opportunity Commission and the IDHR in
Chicago, Illinois.

The PARTIES hereto acknowledge and agree thal, contingent upon the. execution of this
Agreement, they and the EEOC have agreed to the terms of the Conciliation Agreement
referenced herein. The PARTIES agree and acknowledge that such Conciliation
Agreement is incorporated within this Agreement and is a necessary term of this
Agreement.

Other than those payments referenced herein, each party will be liable for its own costs,
attomeys’ fees, and expenses of litigation associated with the DISPUTE.

JOHNSON acknowledges full accord and satisfaction of, and forever discharges, acquits,
teleases, and promises not to sue the COMPANY on any and all charges, claims,
demands, rights, actions, causes-of action, damages, or claims of damage relating to the
employment and/or the termination of his employment by the COMPANY, whether
known or unknown, that JOHNSON now has or may have against the COMPANY
arising up to the effective date of this Agreement, including, without limitation, all
charges, claims of money; demands, rights, and causes of action arising under Title VII of
the Civil Rights Act of 1964, as amended, the Civil Rights Act of 1991, the Equal Pay
Act, 42 U.S.C. §1981, the Americans with Disabilities Act (ADA), the Family and
Medical Leave Act, the Employee Retirement Income Security Act (ERISA), the
Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) as amended, The
Illinois Human Rights Act: all other comparable Illinois statutes and laws, municipal
laws, ordinances and/or regulations; and any other federal Jaw. state law, municipal law,
local law,.common law, or action arising in law, in equity, in contract (whether express or
implied), or in tort, including, without limitation, any claim arising under state laws
which are in the nature of claims for wrongful discharge, retaliation, emotional distress,
defamation, invasion of privacy, harassment, discrimination, breach of duty, negligence
and other claims related to or arising out of his employment.

JOHNSON acknowledges full accord and satisfaction of, and forever discharges, acquits,
releases, and promises not to sue the COMPANY on any ‘and all charges, claims,
demands, rights, actions, attorneys fees, litigation costs, causes of action, damages, or
claims of damage, whether known or unknown, that he now has or may have against the
COMPANY arising up to the effective date of this Agreement, including without
limitation, all charges, claims of money, demands, rights, and causes of action arising
under any federal law, state law, municipal Jaw, local law, common faw, or action arising
in contract (whether express or implied) in tort or in equity.

JOHNSON represents that he has not filed any charges or actions against the COMPANY
(other than the DISPUTE referenced above) and that he will accept no damages or other
monies with respect to any claims that arose before and up to the effective date of this
Agreement.



Exhibit A



EXHIBIT 2


EXHIBIT 10



EXHIBIT 9



PREJUDGMENT INTEREST

12. $89, 901 (Total Back Pay) @ 10% (Loss of use interest rate) = $8,990.10 (Loss of use interest)
13. Total prejudgment interest $8,990.00

COMPENSATORY & PUNITIVE DAMAGES

14. Title VII of the Civil Rights Act of 1964 (as amended) $300,000

15. The Illinois Human Rights Act (as amended) $509,745

TOTAL CLAIM

$1,075,595.00



EXHIBIT 8



$,|

June 8, 2005

Claim Amount: $7,500 (Seven _
five hundred dollars and

00/100 cents),

Complainant: Irenn Hewyt Mahon Johnson
Employee SS# 334-68-7107
D.O.B June 25, 1974
625 S. Dilger Ave #222
Waukegan, IL 60085
(847) 596-2653

Respondent: Orkin Exterminating, Inc. -
2170 Piedmont Road, N.E.
Atlanta, Georgia 30324

NN NN a ae a a

Complaint I: Intentional tort of conspiracy; Respondent conspired to deprive
complainant of his rights to employment pursuant the Hlinois Human
ct.

Complaint II: Respondent violated the Personnel Records Review Act (820 ILCS 40)

Complaint I
The tort of conspiracy commenced on March 18, 2005, when respondent and
unknown co-conspirators conspired to canse employment discrimination during the

The complainant is African-American, a member of a protected class. The
respondent knew the complainant was African-American at the initial interview

It is inherently racially discrimi to exclude an individual from employment
due to an arrest Montgomery Ward & Co. v. Fair Employment Practices Comm'n, 49 I.
App. 3d 796 without other informati which indicate that he actually engaged in the

conduct for which he was arrested 775 5/2-103.



#2.10-2006-01523
Page 2 of 5

GE PROVISIONS

I. The Charging Party agrees not to sue’ the Respondents with respect to any allegations
contained in the above-referenced charge. The EEOC agrees not to use the above-
referenced charge, which is also cross-tiled with the Illinois Department of Human
Rights, as a jurisdictional basis for filing a lawsuit against the Respondents. However,
nothing in this Agreement shall be construed to preclude any party to this Agreement
from bringing suit to enforce this Agreement.

2. The EEOC does not waive or in any manner limit its right to process or seek relief in any
other charge or investigation that may be filed or initiated after the date of this
Agreement, including, but not limited to, a charge filed by a member of the Commission
against Respondents which is not based on this charge.

3. The Respondents agree that they shall comply with all requirements of Title VII, and

shall prohibit any form of retaliation against employees exercising their rights under Title
VII.

4. The Respondents agrees that there shall be no. discrimination or retaliation of any kind
against Charging Party or any person because of opposition to any practice declared
unlawful under Title VIT, or because of the filing of a charge, giving of testimony or
assistance, or participation in any manner in any investigation, or proceedings, or hearing,
under Title VII.

5. The EEOC representative to whom all certification and/or notifications required by this
Agreement shall be submitted is Carmella DiNicola, Investigator, 500 W. Madison St.,
Suite 2000, Chicago, Iinois 60661, 312-869-8090, email: carmella.dinicola@ecoc.gov.

CHARGING PARTY RELIEF

6. The Respondent agrees to pay compensatory damages in the amount of Six Thousand
dollars ($6,000.00) within fifteen ( 15) days from the date of the execution of this
Agreement and the Private Agreement. Charging Party shall be responsible for all taxes
that may be due under the law. The payment shall be reflected on an IRS Form 1099,
which will be issued by Respondents to Charging Party. The Respondent shall send said
payment to the Charging Party, via certified mail. return receipt requested, to the
following address:

Irenn Johnson

7017 60" Avenue
#101

Kenosha, W1 $3142



In other words, a general denial or a bare legal conclusion that a defense exists will not suffice. See

Pretzel & Stouffer, 28 F.3d at 46.

19. The Federal Rules of Civil Procedure contemplate that any challenge to the court's jurisdiction
will be brought at a prejudgment stage by way of a Rule 12(b)(2) or 12(b)(5) motion to dismiss. Where
the jurisdictional predicates are so challenged, it is settled that the plaintiff has the burden of

establishing the jurisdictional facts. See, e.g., RAR, Inc. v. Turner Diesel, 107 F.3d 1272, 1276 (7th Cir.

1997). However, in a situation where a party seeks to vacate a default on jurisdictional grounds, the
Seventh Circuit has imposed the burden of proof on the movant, usually the defendant, to establish the
nonexistence of the court's jurisdiction. See Bally Expert Corp. v. Balicar, Ltd., 804 F.2d 398, 401 (7th
Cir. 1986). The fact that the defendant had notice of the original proceedings but chose not to contest
the jurisdictional issue until afterentry of defaultjudgment was significant to the Bally
Expert court. Id. at 401.

20. [The] lack of communication between attorney and client was not a basis for showing of good
cause C.K.S. Engineers, Inc. v. White Mountain Gypsum Co., 726 F.2d 1202, 1207 (7th Cir. 1984).
21. It is held that "routine back-office problems ... do not rank high in the list of excuses for

default ..." Connecticut National Mortgage Co. v. Brandstatter, 897 F.2d 883, 884-85 (7th Cir.1990).

ANALYSIS

22. The Defendant’s proffered reason to vacate the entry of default is not credible and the

meritorious defense fails.
a. First, the Defendant suggests that Ehlers and Fuss, both whom by virtue of their education and
experience hold titles and positions where effective communication has been proven, failed to
accurately communicate how the summons and complaint were received. Their declarations are
unworthy of belief.

b. Secondly, the Defendant failed to assert that the inadvertence or miscommunication between



CONFIDENTIAL GENERAL WAIVER AND RELEASE AGREEMENT

This Confidential General Waiver. Settlement Agreement, Mutual Release of Ail Claims,
and Promise Not ta Sue (“Agreement”) is hereby entered into between Irenn Johnson
(hereinafter “JOHNSON”) on the one hand and Rollins, Inc. and Orkin, LLC, including all of
their licensees, franchisees, parents, subsidiaries, divisions, affiliates, predecessors, directors,
officers, managers, employees, former employees, heirs, executors, trustees, administrators, plan
administrators, employee benelit plans, agents, successors and assigns on the other hand
(hereinafter collectively referred to as the “COMPANYTM). This Agreement is made for the
purpose of compromising and concluding all disputes, including an EEOC charge and an IDHR
charge that exist between JOHNSON and the COMPANY (“PARTIES”),

WHEREAS, JOHNSON was previously employed by the COMPANY:

WHEREAS, JOHNSON filed Charge No. 210-2006-01523 with the Equal Employment
Opportunity Commission (“EEOCTM) on December 19, 2005. JOHNSON also jointly filed this
Charge with the Illinois Department of Human Rights (“IDHR")(hereinafter the disputes, the
EEOC and the IDHR charge are collectively referred to as “the DISPUTE”);

WHEREAS JOHNSON, the EEOC and the COMPANY have agreed to enter into a
Conciliation Agreement resolving all claims related to the DISPUTE; and

WHEREAS. by operation of this Agreement and in conjunction with the above-
referenced Conciliation Agreement, JOHNSON and the COMPANY intend to mutually,
amicably, and finally resolve said DISPUTE as well as all other claims that JOHNSON has or
claims to have against the COMPANY or their privies. including any and all issues and claims
surrounding or involving JOHNSON’S employment with and discharge from employment with
the COMPANY arising up to the date of this Agreement.

NOW THEREFORE, in consideration of the mutual promises set forth in this Agreement,
JOHNSON and the COMPANY agree as follows:



EXHIBIT 4



IRENN H. JOHNSON
7017 60TM AvE #101
KENOSHA, WI 53142
October 1, 2010

Olgetree Deakins Attorneys at Law
ATTN: Jon M. Gumbel

191 Peachtree St. NE, Suite 4800
Atlanta, GA 30303

‘VIA ELECTRONIC TRANSMISSION

Re: Johnson v. Orkin; Request to reproduce

Mr. Gumbel,

I received your letter dated September 27, 2010, in that you contend in good faith that you have
participated in conciliations efforts on the behalf of Orkin/ Rollins.

I respectfully request that you reproduce all relevant material in your possession regarding this
charge of employment discrimination based on race and retaliation. Such information will
specifically include documents regarding conciliation efforts and other supporting information in
opposition of said claim.

Although, you have made it clear that Orkin/ Rollins maintains a very strong defense, your belief
that the EEOC has issued its cause determination based solely on allegations of your arbitration
policy, and not on the merits of my claim of discrimination and retaliation may be inaccurate and
contrary to the findings. Never-the-less, there can be no misunderstanding as to the findings that
there is a reasonable cause to believe Title VII has been violated.

For that reason, I am interested in a swift resolution of this claim.
Regards,

IRENN JOHNSON



EXHIBIT 5



As consideration for this Agreement, the COMPANY will pay to JOHNSON a total sum
of SIX THOUSAND AND 00/100 DOLLARS ($6,000.00). This settlement amount will
be paid by check made payable to Irenn Johnson within fifteen (15) days of the
COMPANY'S receipt of the fully executed original of this Agreement or the
COMPANY'S receipt of the fully executed, above-referenced Conciliation Agreement
with the EEOC, whichever is fully executed later. This settlement amount is for alleged
emotional damages or other compensatory damages associated with the DISPUTE. In
light of the nature of the payments described hercin, there will be no amounts deducted or
withheld from that settlement payment, but an IRS form 1099 will be issued to
JOHNSON in regards to same. It is expressly understood by JOHNSON and the
COMPANY that the six thousand dollars ($6,000.00) paid to JOHNSON by the
COMPANY as consideration for this Agreement shall not constitute any additional
money paid above and beyond the same six thousand dollars ($6.000.00) committed by
the COMPANY as consideration {or the Conciliation Agreement entered into between
JOHNSON, the COMPANY and the EEOC. The PARTIES agree that a total of six
thousand dollars ($6,000.00) and no more shall be paid by the COMPANY as
consideration for both this Agreement and the above-referenced Conciliation Agreement.

It is expressly understood and agreed by JOHNSON that the COMPANY does not
represent or guarantee that taxes should not be paid on any portion of these settlement
payments. JOHNSON further agrees to pay any and all appropriate taxes related to his
receipt of the settlement amount and acknowledges that he will hold the Company
harmless and indemnify the Company from any liability or costs they incur (including
attorneys’ fees) as a result of JOHNSON’S failure to pay any such taxes or otherwise
resulting from the payment in this manner.

JOHNSON acknowledges that the consideration described above is sufficient
consideration for this Agreement and the Conciliation Agreement, and is above and
beyond anything to which he would otherwise be entitled from the COMPANY.

JOHNSON hereby settles all differences between the COMPANY and him, including,
without limitation, claims involving his wages, hours, working conditions, and all other
terms and conditions of employment during his employment by the COMPANY and
occurring up to the date of this Agreement including, but not limited to those involving
the termination of his employment and all other matters related to his employment with
the COMPANY. JOHNSON acknowledges full accord, satisfaction, settlement, and
release of any and all charges. demands, rights, actions, causes of action, damages, or
claims of damage, including, but not limited to, actual, compensatory, exemplary,
liquidated, punitive, injunctive, and nominal damages as well as any related costs and
attorneys’ fees associated therewith, of whatsoever kind and nature which he has or may
have against the COMPANY by reason of, or related to, without limitation, his
employment or the termination of his employment from the COMPANY. This includes.
without limitation, any claims which were or which could have been asserted in the
DISPUTE,



a Hi Ko bh i ee ll lh hulu lO

— —

. GhoicePoint - Search Results for Johnson, trenn 39405 /107 i

CASEID 4199629 aoe,

[ : OPTION INFORMATION 1
Report option: 2112 Report name: BACKGR CUS PK2
mponents Remarks Consideration Score
National Criminal Fil YES
Felom ludi i anor YES
Social Security Verification NO
Comments

| NOTIFICATION

Start Date End Date Name mponent

Asterisk (*) dates are automatically calculated by the system.

PUBLIC RECORDS _
Record ordered National Criminal File Search Results RECORD FOUND
Type of Search NATIONAL CRIMINAL FILE SEARCH
Date of Search 03/09/2005

Address Covered WAUKEGAN, LAKE, IL

CourtName/Type § DATABASE SEARCH (XDB) - COOK CIRCUIT COURT-CRIMINAL
Location COOK, ILLINOIS, IL COOK COUNTY

Name Searched IRENN H JOHNSON

Case Reference# 1992CR07956019536

Name on File JOHNSON, IREEN

Address on File NOT PROVIDED .

SS# on File DOB on File 06/25/1974
Charge CRIMINAL TRESPASS TO LAND

Charge Type MISDEMEANOR

Disposition PENDING NEXT COURT DATE Date 03/31/2005
Sentence

tee pokes dt ee change Hinois-sibesconterdorkin.com Inbox CRC.EMLJohnson.? 20.0 4) 2005



Case: 1:12-cv-00141 Document #: 18-7 Filed: 04/30/12 Page 2 of 11 PagelD #:94

GENERAL OFFICE PROCEDURE MANUAL VOLUME I Paget: 1-15.2

Dispute Resolution EMective Date: 2/15/05

th A. Dispute: The term “dispute,” as used in this Policy, includes (1) all

Definitions claims, actions or suits arising out of or in connection with any applicant’s
application for employment and the Company’s actions with respect to that
application, and (2) all claims, actions or suits arising out of or in connection
with any employee’s employment, inclading but not limited to the terms and
conditions of any employee’s employment and the termination or cessation of
that employment.

The term “dispute” further Includes any such claims asserted by employees
against the Company and/or all persons acting as its legal agents, The term
“dispute” is expressly limited to any legal cause of action which otherwise
exists under federal, state or municipal constitutional, statutory or common
law. °

The term “dispute” excludes statutory claims that are subject to the exclusive
jurisdiction of a state or federal agency and which allow resort to a court only
through appeal or for enforcement Proceedings such as claims for workers
compensation or unemployment insurance benefits and charges filed with the
National Labor Relations Board; claims expressly excluded by applicable
law; claims that are expressly required to be arbitrated under a different
procedure pursuant to the terms of any employee benefit plan or otherwise;
claims cognizable under the Employee Retirement Income Security Act
(ERISA); any criminal complaint or action, or; any action initiated by the
Company for purposes of preventing or stopping any unfair or unlawful
competition or solicitation of its customers, and/or misappropriation of its
trade secrets,

B. Company: The term “Company,” as used in this Policy, includes,
collectively, Rollins, Inc. and Orkin, Inc., together with their related and
affiliated companies and entities, and those acting as its and their agents,
managers, or representatives,

C. Employee: The term “employee,” as used in this Policy, includes the
Company’s current, future and former employees and applicants who have
signed an agreement to arbitrate and are bound by the Company’s Dispute
Resolution Policy, together with any others claiming through or on behalf of
stich individuals,

PROPERTY OF ORRIN INC, 2170 PIEDMONT ROATL NIE ATLANTA, GA 30524

EXHIBIT F



35. | WHEREFORE I, Irenn Johnson, Plaintiff, request a final judgment order, as set forth in the
computation of damages (see Exhibit 11), in the amount of $1,075,595.00 and whatever relief the court

determines as appropriate.

aygor2 . AiG.

Dated Irenn H.
Pro Se

7017 60 Avenue #101
Kenosha, Wisconsin 53142
262-577-5412 Phone

10



It is my desire to reach a silent and swift resolution as to avoid the continuous exertion of
valuable resources in pursuit of a remedy.

RESPECTFULLY,

3/30/2011,

TRENN HEWYT MAHON JOHNSON

Signed by: JOHNSON. IRENN. HEWYT. 1293119313

CF:
1. Carmella DiNicola, Federal Investigator, Chicago EEOC
2. Orkin/ Rollins



COIDAWEwWNH

GENERAL RELEASE

1. This release agreement (“Agreement”) is hereby entered into between Irenn H. Johnson
(“Johnson”), plaintiff, and Rollins, Inc and Orkin, LLC, respondent, hereinafter collectively referred to
as (“Orkin”).

2. This agreement is made for the purpose of compromising and concluding all disputes, including
charges with Equal Employment Opportunity Commission (“EEOC”), file No. 210-2006-01523 and
Illinois Department of Human Rights (“IHDR”).

3. Johnson, the EEOC, and Orkin has agreed to enter into a Conciliation Agreement resolving all
claims related to all charges. This agreement in conjunction with the Conciliation Agreement is
intended to resolve any and all claims surrounding or involving Johnson's employment with Orkin.

4. In consideration for this agreement, Orkin will pay Johnson a total sum of One Hundred Forty-five
Thousand Three Hundred Eighteen Dollars and Fifty-two cents ($145,318.52). This settlement amount
will be paid by check made payable to Irenn Johnson within fifteen (15) days of Orkin's receipt of the
fully executed original of this agreement. This settlement amount is for alleged compensatory damages,
medical bills, back pay, and/or front pay or other damages associated with the dispute. There will be no
amounts deducted or withheld from that settlement payment, but IRS form 1099 will be issued to
Johnson in regards to the same. It is expressly understood by Johnson and Orkin that the total sum
referenced above shall be paid by Orkin as consideration for both this agreement and the Conciliation
Agreement.

5. Johnson hereby settles all differences and agrees to release Orkin from all claims, suits, or actions in
any form or on any basis, due to anything that was done or not done at any time, on account of or
relating to his employment with Orkin, including all claims and causes of actions arising under Title
VII of the Civil Rights Act of 1964, as amended; the Civil Rights Act of 1991; the Equal Pay Act; 42.
USS.C. 1981; the Americans with Disabilities Act (ADA); the Family and Medical Leave Act; the
Employee Retirement Income Security Act (ERISA); the Illinois Human Rights Act; and all other
comparable federal, state, or common law.

6. Johnson agrees to take action necessary to dismiss and will dismiss all charges against Orkin with
the EEOC and IDHR in its entirety.

7. All parties agree that contingent upon the execution of this agreement, they and the EEOC have
agreed to the terms of the Conciliation Agreement referenced herein. The parties agree and
acknowledge that such Conciliation Agreement is incorporated within this agreement and is a necessary
term of this agreement.

8. Other than those payments referenced herein, each party will be liable for its own costs, attorneys’
fees, and expenses of litigation associated with the dispute.

9. Johnson acknowledges that this agreement or the Conciliation Agreement referenced herein in no
way constitutes an admission by Orkin that it has violated any federal, state, or common law, or any
other law whatsoever, and instead represents a good faith effort to resolve contested and disputed
claims.



inadvertence prevented a timely filed pleading pursuant Rule 12, and it had actual knowledge of
litigation, it therefore failed to show good cause. Furthermore, seeing that it has no valid meritorious
defense and it willfully chose not to conduct its litigation with the degree of diligence and expediency,
Seventh Circuit precedent has repeatedly upheld the trial court's denial of a motion to vacate a default.
25. Because the Defendant failed to justify vacating the entry of default, it is appropriate to
promptly endeavor to determine the amount of applicable damages.

DAMAGES

26. "Title VII makes it unlawful for any employer to discriminate against an employee for opposing

a practice made unlawful by the Act.” Fine v. Ryan Intern. Airlines, 305 F.3d 746, 751 (7th Cir.
2002) (citing 42 U.S.C. § 2000e-3(a)).

27. Pursuant to the damages limitation (damages cap) imposed by 42 U.S.C. § 1981a(b)(3), the
Civil Rights Act of 1991. Under the damages cap, the sum of compensatory and punitive damages is
limited based on the number of persons employed by the employer. Damages are capped at $200,000
for employers with between 200 and 500 employees, and at $300,000 for employers with more than
500 employees. 42 U.S.C. § 1981a(b)(3)(C) and (D). The County asserted that the number of
employees should be determined at the time damages were awarded.

28. Section 1981a(b)(1) provides, "A complaining party may recover punitive damages under this
section against a respondent ... if the complaining party demonstrates that the respondent engaged in a
discriminatory practice or discriminatory practices with malice or with reckless indifference to the
federally protected rights of an aggrieved individual." 42 U.S.C. § 1981a(b)(1). The terms "malice" and
"reckless indifference” refer to the employer's knowledge that it may be violating federal law. Cooke v.
Stefani_ Management Services, Inc.. 250 F.3d_564, 568 (7th Cir. 2001); Kolstad, 527 U.S. at 535.
In Kolstad v. American Dental Ass'n, 527 U.S. 526 (1999), the Supreme Court rejected the requirement

that punitive damages be available only in "extraordinarily egregious" cases, and instead found an



Ehlers, Fuss, and Blanchard were the direct and proximate cause of the Defendants failure to timely
respond or otherwise file a pleading.
c. Lastly, the defendant had actual knowledge of the court proceedings as evident by the informal
appearance of counsel at the Status Hearing and receipt of the summons and complaint served
certified mail to the counsel on March 21, 2012 and received on March 27, 2012.
23. The Defendant lacks a meritorious defense because this issue is not subject to the Dispute
Resolution Policy. Sec. II(A) defines the term “dispute” and states in pertinent part, [t]he term
“dispute” excludes statutory claims that are subject to the exclusive jurisdiction of a state or federal
agency.... See Defendant’s Exhibit F. The Illinois Supreme Court has held that courts have no
jurisdiction to hear independent actions for civil rights violations. The legislature intended by the Act to

avoid direct access to the courts for the redress of civil rights violations Mein v. Masonite Corp., 109

I.2d_ 1, 7, 92 Il.Dec. 501, 485 N.E.2d 312 (1985). Illinois courts, and hence, federal courts,

consistently find that cases based upon state common-law claims “inextricably linked" to civil-rights
violations are subject to the Act and thus, Illinois circuit courts do not have original jurisdiction over
such claims. The administrative process under the Act must be completed before a circuit court can

exercise jurisdiction over these types of claims. See, e.g., Quantock v. Shared Mktg. Servs., Inc., 312

F.3d 899, 905 (7th Cir.2002): Talley v. Wash. Inventory Serv., 37 F.3d 310 (7th Cir.1994); Nanda v.

Bd. of Trustees, 219 F.Supp.2d 911, 916 (N.D.II.2001); Johnson _v, Baxter Healthcare Corp., 907

F.Supp. 271 (N.D.IIL.1995); Geise v. Phoenix Co. of Chicago, Inc., 159 Ill.2d 507, 203 Ill.Dec. 454

639 N.E.2d 1273 (1994); Welch v. Ill. Sup.Ct., 322 Ill. App.3d 345, 256 Ill.Dec. 350, 751 N.E.2d 1187

(2001). Because complaints alleging violations of Title VII and Illinois Human Rights must first be
filed with the EEOC and the Illinois Department of Human Rights respectively, this claim is therefore
not a dispute as defined and therefore excluded from mandatory arbitration.

24. Given that the Defendant’s declarations are unworthy of belief, it failed to assert how



EXHIBIT 3



requested various forms of relief, including a declaratory judgment; an injunction; an order directing
that the effects of the alleged practices be eliminated; compensatory damages for lost wages and other
lost benefits; compensation for emotional and psychological damage; punitive damages; and costs,
including reasonable attorney's fees. (Complaint at ff] A-I.) The jury found for the City on the
Plaintiffs’ Title VII discrimination claim, but found for the Plaintiffs on their Title VII retaliation claim.
As a result of the retaliation verdict, the jury awarded the Plaintiffs compensatory damages in the

amounts of $250,000.00 for Lipman, $50,000.00 for O'Sullivan, and $25,000.00 for Roche, for a total

of $325,000.00. See 833*833_ O'Sullivan v. City of Chicago, 478 F.Supp.2d 1034 (N.D.II1.2007);
O'Sullivan v. City of Chicago, 2007 WL 671040 (N.D.III.2007): O'Sullivan y. City of Chicago. 474
F.Supp.2d 971 (N.D.II1.2007). The City was also enjoined from further retaliation. See O'Sullivan v.
City of Chicago, 2007 WL 951941 (N.D.II1.2007).

33. In Blount v. Stroud 232 IL.2d 302 904 N.E.2d 1 (2009), The principal issue on appeal is

whether the circuit court had subject matter jurisdiction over plaintiffs claims or, stated differently,
whether plaintiff's sole source of redress was through the administrative procedures set forth in the
Illinois Human Rights Act (Act) (775 ILCS 5/1-101 (West 2000)). The jury retumed a verdict in favor
of plaintiff on her retaliation claims, awarding $257,350 in back pay, $25,000 for pain and suffering,
and $2,800,000 as punitive damages.

CONCLUSION

34, Because the Defendant has 500 or more employees and engaged in discriminatory practices
with malice or with reckless indifference to my federally and state protected rights by initially failing to
hire me due to my race and arrest record, maintaining a policy that discriminates against members of a
protected class, forcing me to sign an arbitration policy that limited my rights pursuant Title VII of the
Civil Rights Act, and retaliating against me for opposing discriminatory conduct, compensatory &

punitive damages, back pay, and future pay are therefore appropriate.



$.-

Therefore, despite being qualified, the respondent attempted to deny complainant
employment because he is African-American. The conspiracy ceased when the
complainant was hired on April 21, 2005.

Complaint I

On March 18, 2005, complainant provided a written request for employment
records pursuant to the common-law right to access personal records. This request was
not made available.

On April 25%, complainant provided a second written request pursuant the Illinois
Personnel Record Review Act. The respondent refused to acknowledge the written
request and has failed to release the records within seven days without offering an
explanation or reason for the delay.

The respondent has currently failed to comply with the request, which is a
continuing injury and an intentional disregard of the complainant’s right to access
employment records.

In accordance with Black's Law Dictionary &* edition and
Injury, the violation of one’s legal rights is recognized as injury for which the law
provides a compensational remedy. For that reason, I seek relief for $7,500.00

JOTARY SEAL
—— Whos N /
” Date
CHRISTINAY. HOM

Sworn exter me on tis aay of
NOTARY PUBLIC, STATE OF ILLINOIS

MY COMMISSION EXPIRES9.26.1"
_ . q LG Ole Seovonenemensersenseseestentecceued

“OFFICIAL SEar,”



UNITED STATES DISTRICT COURT MAY y 9 202
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION cue MAS 6. BRUTON
®: DISTRICT Coury
IRENN H, JOHNSON )
Plaintiff, )
)
v. ) Civil Action No.: 12-CV-00141
) Judge Ruben Castillo”
ORKIN, LLC; ORKIN PEST CONTROL; )
ORKIN EXTERMINATING, INC )
Defendant.

MOTION IN OPPOSITION TO VACATE DEFAULT ENTRY AND TO DISMISS AND TO
COMPEL ARBITRATION AND MOTION FOR FINAL JUDGMENT

COMES NOW, I, Irenn H. Johnson, Plaintiff, and pursuant Rule 55 and Rule 60 of the Federal
Rules of Civil Procedure respectfully request the court to deny the Defendant’s Motion To Vacate
Entry of Default and For Leave To File Motion To Dismiss and To Compel Arbitration on the grounds
that without regard to whether or not the default entered by the court constitutes a " default judgment"
or "entry of default," the Defendant has not presented a sufficient basis to vacate the default order
under Rule 55(c) or Rule 60(b) of the Federal Rules of Civil Procedure. Pursuant Title VII of the Civil
Rights Act (as amended), and the Illinois Human Rights Act I hereby request the court to enter a
judgment for the total damages as set forth in the complaint and whatever relief the court determines as
appropriate.

In support of this motion, I, Irenn H. Johnson, Plaintiff, first being, duly sworn states under the oath
the following as true and correct.
UNDISPUTED FACTS
1 On March 7, 2005, I completed an employment application with the Defendant, who has over
500 employees, and was interviewed by Mark Fuss (“Fuss”), Regional Sales Manager and Call Center
Manager on March 9. He offered me a position contingent the results of a background check, physical,

and drug test. Due to the inherent financial volatile nature of the business, | expressed concerns
1



EXHIBIT 7



EXHIBIT 1



Signed and sworn to beforg-me on this

Mey
BY _ day of April 2012.
q

Notaty Public

[SEAL]

NOTARY PUBLIC

My commission expires

2 ,
on: é ~f-IY4

11



EXHIBIT F



#210-2006-01523
Page 4 of 5

15.

regards to the revisions to the ADR Policy referenced above. The purpose of this training
is to educate Respondent Orkin’s Human Resources Managers as to the amendments to
and application of the revisions to the ADR Policy.

The Respondents agree that within thirty (30) days of the execution of this Agreement
they shail submit the following information in writing for the EEOC to review:
a, name, address and telephone number of the proposed trainer;
b. qualifications of trainer:
c Proposed date(s) of the training:
d, proposed schedule and content of the training: and
e, list of proposed attendees

Within fifteen (15) days after the training is given, Respondents shall submit to the
EEOC a list setting forth the name and title of all Human Resources Managers who
attended the training.

NOTICE REQUIREMENT

Within twenty-one (21) days of the execution of this Agreement, Respondents shall sign
and conspicuously post a copy of the Notice attached as Exhibit A on all employee
bulletin boards at Orkin's HMlinois Region office locations. Respondents shall ensure that
the Notices are not covered, defaced. or otherwise altered in any way for the duration of
the posting period. These Notices shall remain posted for three (3) months following the
posting thereof, Respondents shall certify to EEOC within thirty (30) days of the date of
this Agreement that the Notice has been properly posted.

REPORTING

Upon the EEOC’s request and to ensure compliance with this Agreement, the Respondent
shall provide EEOC with the documents required to be maintained by Respondent as per
the terms of this Agreement.

DURATION OF CONCILIATION AGREEMENT

This Agreement shall remain in effect for a period of eighteen (18) months trom the date
of its execution. The execution date shail be the date on which the EEOC District
Director executes this agreement.

BREACH OF AGREEMENT
In the event that the terms of this Agreement are not fulfilled, this Agreement may be
specifically enforced in court and may be used as evidence in a subsequent proceeding in
which one of the parties alleges a breach of this Agreement.



IRENN HEWYT MAHON JOHNSON
7017 60" Ave #101
Kenosha, Wisconsin 53142
H:262.577.5412 C:262.705.0630 E:lrenn.Johnson@Gmail.com

WRITTEN RESPONSE DEMANDED

WITHIN 30 DAYS OR
BY APRIL 30, 2011
30 March 2011

Olgetree Deakins

Attn: Jon M. Gumbel

191 Peachtree Tower St. NE, Suite 4800
Atlanta, GA 30303

SUBJECT: Johnson v. Orkin; Rollins
Request for Conciliation

Mr. Gumbel,

On September 27, 2010, you stated that “on behalf of Rollins/Orkins, [you) have participated in
good faith and in a timely fashion with respect to the conciliation process”. Unfortunately, at present,
there’s no meeting of the minds or any contractual execution, thus, this matter has yet to be
successfully resolved.

| have evidence to support the fact that Orkin/ Rollins has engaged in unlawful discrimination
when they: initially denied me employment based solely on the fact of my arrest record; denied me
equal and adequate training as other members outside my protected class; and conspired to prevent
me from filing a discrimination charge with the Equal Employment Opportunity Commission and the
Department of Human Rights, all in contravention to Title VI! of the Civil Rights Act, as amended, and
the Illinois Human Rights Act respectively.

Given that | am failing to recognize a realistic and sincere effort to bring this matter to a close,
as a matter of law, | am entitled to bring forth a civil claim for compensatory damages pursuant 42
U.S.C. 1985(3), 42 U.S.C.1983, and 775 ILCS 5/10-102. Specifically, $300,000 pursuant 42
U.S.C.1981(a), up to $78,000 for back pay plus interest pursuant 42 U.S.C.2000 et seq.; up to
$78,000 for back pay plus interest pursuant 775 ILCS 5; and it is not unreasonable to claim and or be
awarded $300,000 for pain and suffering based on current case law or pursuant 775 ILCS 5/10-
102(c)(1). The total amount | may legally claim is upward of $756,000.



AO 398 (Rev. 01/09) Notice of a Lawsuit and Request 10 Waive Service of a Summons

UNITED STATES DISTRICT COURT
for the
Northern District of Illinois

IRENN H. JOHNSON
Plaintiff
ve
ORKIN, LLC; ORKIN PEST CONTROL
Defendant

Civil Action No.

weer

NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS

To: ORKIN, LLC; ORKIN PEST CONTROL 2170 PIEDMONT ROAD NE, ATLANTA, GA 30324
(Name of the defendant or - if the defendant is a corporation, partnership, or association - an officer or agent authorized to receive service)

Why are you getting this?

A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above.
A copy of the complaint is attached,

This is not a summons, or an officia: notice from the court. It is a request that, to avoid expenses, you waive formal
service of a summons by signing and returning the enclosed waiver. To avoid these expenses, you must return the signed
waiver within _30 days (give at least 30 dayy, or at least 60 days if the defendant is outside any judicial district of the United States)
from the date shown below, which is the date this notice was sent. Two copies of the waiver form are enclosed, along with
a stamped, self-addressed envelope or other prepaid means for returning one copy. You may keep the other copy.

What happens next?

If you return the signed waiver, { will file it with the court. The action will then proceed as if you had been served
on the date the waiver is filed, but no summons will be served on you and you will have 60 days from the date this notice
is sent (see the date below) to answer the complaint (or 90 days if this notice is sent to you outside any judicial district of
the United States).

If you do not return the signed waiver within the time indicated, | will arrange to have the summons and complaint
served on you, And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.

Please read the enclosed statement about the duty to avoid unnecessary expenses.
I certify that this request is being sent to you on the date below.

Signaniré gfthe attorney or unrepresented party

IRENN H. JOHNSON
Printed name

7017 60TH AVE #101, KENOSHA, WI 53142

Address

IRENN.JOHNSON@GMAIL.COM
E-mail address

___262-577-5412/ 262-705-0630 C
Telephone number



88
89
90
91

92

10. Johnson agrees and acknowledges that he will not apply for employment with Orkin, LLC and that
he forever waives and relinquishes any and all claims, rights or interests in reinstatement or future
employment that he presently has or might in the future have with Orkin, LLC.

11. In lieu of waiving and relinquishing any and all claims, rights or interests in reinstatement or future
employment that he presently has or might in the future have with Orkin, LLC, Orkin agrees and
acknowledges that the total payment referenced in paragraph 4 addresses that to which he would have
been entitled.

12. If the scope of any provision contained in this agreement is too broad to permit enforcement of
such provision to its full extent, then such provision shall be enforced to the maximum extent permitted
by law. If any provision of the agreement is held to be prohibited by or invalid under applicable law,
such provision, to the extent of such prohibition or invalidity, shall be deemed not to be a part of the
agreement, and shall not invalidate the remainder of such provision or the remaining provision of the
agreement.

13. All parties agree not to disclose or publish any communication regarding the terms or conditions of
this release or any facts related in any way to this dispute which are untrue to any third party without a
legal basis for having to release said information, or as required by law, unless all parties agree in
writing to do so.

14. In the event any party violates any provision of this agreement, the other party may present this
agreement to a court of competent jurisdiction to obtain an injunction and/or other appropriate relief.

15. All parties agree that any disputes arising from this agreement shall be enforced pursuant the rules
and laws of the State of Illinois if appropriate.

16. With the exception of the Conciliation Agreement referenced herein, this agreement constitutes the
entire agreement between the parties with respect to the subject matter hereof and supersedes any prior
agreements addressing the subject matter hereof. Other than the Conciliation Agreement referenced
herein, all parties warrants that no promise or agreement not expressed herein has been made.

17. This agreement may not be changed, modified, amended, or altered in any way except by a writing
signed by all parties.

FOR THE COMPANY DATE



award proper so long as the employer discriminates "in the face of a perceived risk that its action will
violate federal law.” Id. at 533, 536.

29. Relief which may be granted in a civil action under subsection (A) if the court finds that a civil
rights violation has occurred or is about to occur, the court may award to the plaintiff actual and
punitive damages, and may grant as relief, as the court deems appropriate, any permanent or
preliminary injunction, temporary restraining order, or other order, including an order enjoining the
defendant from engaging in such civil rights violation or ordering such affirmative action as may be
appropriate 775 ILCS § 5/10-102(c).

30. The IHinois common law of retaliatory discharge has been preempted in the employment

context by the Illinois Human Rights Act, 775 ILCS § 5/1-101, et seq. See Corluka v. Bridgford Foods

of Hl., Inc., 671 N.E.2d 814, 817 (Ill. App. Ct, 1996). The Illinois Human Rights Act makes it "a civil

rights violation for a person, or for two or more persons to conspire, to: [rJetaliate against a person
because he has opposed that which he or she reasonably and in good faith believes to be unlawful
discrimination, [or] sexual harassment in employment." 775 ILCS § 5/6-101(A).

31. | When a violation of the Act has occurred, the complainant should be placed in the position in
which he would have been but the discrimination Clark v. Illinois Human Rights Commission, 141 Ill
App 3d 178, (1 Dist 1986). The purpose of a damage award is to make the complainant whole.

32. In O'Sullivan v. City of Chicago, the complaint, fairly read, stated five separate claims against
the City, the Police Department, and Perry (the Joint Defendants), including (1) a violation of 42 U.S.C.
§ 1983; (2) a violation of 42 U.S.C. § 1981; (3) a violation of the Illinois Human Rights Act (IHRA),
775 ILCS 5/1-101 et seq.; (4) discrimination in violation of Title VII of the Civil Rights Act of 1964
(Title VID), 42 U.S.C.2000e; and (5) retaliation in violation of Title VII. (Complaint at {f[ 25-29.) It is
important to note, however, that although Plaintiffs pleaded a variety of legal claims, all relied upon the

same two sets of facts — the discriminatory and retaliatory actions by Perry. The complaint also



an

Request for information: Employee Records for Irenn Johnson
SS# Date of Birth:

April 25, 2005

Human Resources:

Pursuant to the Illinois Personnel Record Review Act 820 ILCS 40, please make
available copies of ail information used in making decisions relevant to my employment.

Such information include but are not limited to my original employment application,

background investigation results, physical, and drug screen results, questionnaire results,
employment agreement, arbitration contract, all disclosures, forms, memos, and notes.

YASS

loyee Signapate Date

Employer Signature - Date



COMPUTATION OF DAMAGES

BACK PAY

1. April 21, 2005 to August 31, 2005 (dates of employment with Orkin) = 132 days.

2. $9,784 (2005 earned wages from Orkin) / 132 days of employment = $74.12 of earned
wages/day.

3. $74.12 of earned wages per day * 365 days per year = $27,054 (Projected Annual Earned
Income).

4. $27,054(Projected Annual Earned Income) / 12 months = $2,254.50 (Projected monthly earned
income).

5. 4 months (Sep 2005 — Dec 2005) * $2,254.50 per month = $9,018 (Projected earned income
through 2005).

6. $9,784 (2005 earned wages from Orkin) + $9,018 (Projected earned income through 2005) =
$18,802 2005 Projected Earned Income.

7.
2005 $9,784.00 $9,784.00 _| $18,802.00 _| $9,018.00
2006 $2,356.00 | $2,356.00 | $27,054.00 _| $24,698.00
2007 $7,525.00 __| $6,695.00 | $14,220.00 _| $27,054.00 _| $12,834.00
2008 $18,645.00 | $3,334.00 | $21,979.00 | $27,054.00 | $5,075.00
2009 $9,972.00 __| $4,975.00 __| $14,947.00 _| $27,054.00_| $12,107.00
2010 $5,309.00 _| $5,309.00 | $27,054.00 | $21,745.00
2011 $13,600.00 _| $9,030.00 | $22,630.00 _| $27,054.00 _| $4,424.00
Totals $59,526.00 | $31,699.00 | $91,225.00 | $181,126.00 | $89,901.00

8. Total Back Pay $89,901.00.

5,875.00 (2005 — 2011 Average projected annual wage) - $13,032.00 (2005 — 2011 Avg
earned anritial wage) = $12,843.00 (Avg lost wages)

10. $12,843.00 (Avg lost wages) * 13 yrs. (Years remaining for retirement at 20 yrs.) = $166,959.00
(Future Pay)

11. Total lost future earnings $166,959.00



17.

19.

20.

2l.

disclosures as are required by law, including any required disclosures to taxing agencies,
and may disclose the terms of this Agreement to a tax advisor, accountant, or to legal
counsel, provided that JOHNSON shall inform such persons that the terms are strictly
confidential and are not to be revealed to anyone else except as required by law.
JOHNSON agrees that any representation to persons not specifically accepted herein
about the termination of this matter other than “the matter has been resolved” is a
violation of this confidentiality covenant.

In the event any party violates any provision of this Agreement, the other party may
present this Agreement to a court of competent jurisdiction to obtain injunctive relief or
other appropriate monetary relief, including costs, and attomeys’ fees.

JOHNSON and the COMPANY agree that the United States District Court for the
Northern District of Ulinois is the sole, proper jurisdiction to enforce this Agreement.
The laws of the State of Illinois-shall govern the interpretation and performance of this
Agreement should any dispute arise concerning or related to this Agreement. JOHNSON
and the COMPANY hereby submit to personal jurisdiction and venue for the United
States District Court for the Northern District of Illinois for any case arising out of or
relating to this Agreement.

With the exception of the Conciliation Agreement referenced herein, this Agreement
constitutes the entire agreement between the parties with respect to the subject matter
hereof and supersedes any prior agreements addressing the subject matter hereof. Other
than the Conciliation Agreement referenced herein, JOHNSON warrants that no promise
or agreement not expressed herein has been made to him, and that in executing this
Agreement he does not rely upon any statement or representation made by the
COMPANY, but relics solely upon his own judgment and/or the judgment of his
attorney(s) that the consideration reccived is received by him in full compromise,
settlement, and satisfaction of all the aforesaid claims and demands whatsoever and that
the consideration expressed herein is the sole consideration for this Agreement and the
Conciliation Agreement referenced herein,

This Agreement may not be changed, modified, amended, or altered in anv way except
by a writing signed by JOHNSON and an authorized representative or officer of the
COMPANY.

JOHNSON acknowledges and agrees (a) that his waiver of rights under this Agreement is
knowing and voluntary and complies in full with the ADA, the FMLA, Title VII of the
Civil Rights Act of 1964, and any and all other applicable federal, state and local laws,
regulations, and orders; (b) that he understands the terms of this Agreement; (c) that the
payment referred to in this Agreement exceeds that to which he would otherwise have
been entitled, and that the actual payment is in exchange for his release of the claims and
other covenants referenced in this Agreement and in the Conciliation Agreement; (d) that
he has been advised via this Agreement that he has the right to consult with his alttomey
prior to executing this Agreement; and (f) he has had at least a reasonable period of time
from the COMPANY'S final offer to consider this Agreement, and he has had sufficient
time to consider his decision to enter into this Agreement.

-5-



TRENN JOHNSON Date

FOR THE COMPANY Date

10871290.1 (OGLETREE)



a Case: 1:12-cv-00141 Document #: 18-2 Filed: 04/30/12 Page 1 of 1 PagelD #:81

OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
Ooletree Attorneys at Law
’ One Ninety One Peachtree Tower
191 Peachtree St. NE, Suite 4800
Deakins ce
Telephone: 404.881.1300
Facsimile: 404.870.1732
www.ogietreedeakins.com
Jon M, Gumbel i
Jon.gumbel@ogietreedeakins.com \
March 19, 2012
Mr. Irenn Johnson .
7017 60" Avertue #101
Kenosha, WI 53142

VIA FEDERAL EXPRESS, US MAIL AND EMAIL (irenn.johnson@gmail.com)
RE: Johnson v. Orkin, LLC, Orkin Pest Control, Orkin Exterminating, Inc. |

United States District Court — Northern District of Llinois
Case Number: 12cv141

Dear Mr. Johnson, }
Thank you for your letter dated March 17, 2012 notifying me of the status conference
scheduled for March 22, 2012. However, please note that Orkin is not a proper party to your
lawsuit. Also, in response to your telephone message to me today asking that I voluntarily
accept service of process on behalf of Orkin and its related entities, please be advised that I am
not authorized to do so.
Thank you for your attention to these matters,

Sincerely,

IMG/kb

* Chadeston * Chailotie * Chimgo * Clerdind * Columbia © Dalhs « Denver = Deswit Metio » Greensbom
. * Las Vegas * Los Angeles « Memphis * Miami * Minneapolis * Mocistown * Nashvile * New Odes
Orange Covery » Philadelphia * Phoenix * Pittsburgh « Portland * Raleigh © St Louis * Sx Thomas # San Antonio * San Franckco * ‘Tampa * Toetance # Tucton # Washingion

EXHIBIT A



Trenn Johnson
7107 60" Ave #101
Kenosha, WI 53144
November 9, 2010

Orkin, LLC

Attn: Legal

2170 Piedmont Rd NE
Atlanta, GA 30324

Subject: Johnson V. Orkin — Conciliation Efforts

Dear Attorney:

To date, I have not received any documents that support your participation in
conciliation efforts. However, I trust that you are participating in good faith.

The Chicago EEOC has determined that there is reasonable cause to believe that Title VII
of the Civil Rights Act has been violated. In addition, I have enclosed copies of additional facts
and supporting evidence, that has been forwarded to the Illinois Department of Human Rights,
which support a violation of the Illinois Human Rights Act, specifically 775 ILCS 5/2-103(a)
and 775 ILCS 5/2-101. I have also enclosed a copy of my press release that has a release date of
November 30, 2010.

it is my hope that any final agreements address my direct or indirect concerns of lost
wages, back pay, future pay, and compensatory damages. More importantly the final
agreement should be significant enough to deter future violations or allegations and dissuade
other companies from engaging in said practice.

If you have any questions, you may reach me at the above address.



EXHIBIT 11



contest the merits of the dispute with the practical requirements of judicial administration and the
desire not to prejudice a blameless party that has acted diligently Chrysler Credit Corp. v. Macino. 710
F.2d 363, 367 (7th Cir. 1983). Precedent teaches that a party's failure to show good cause for entry of a
default alone is sufficient to warrant denial of a motion to vacate. See Zuelzke Tool, 925 F.2d at
230 (collecting Seventh Circuit cases and holding that failure to show good cause for default was
sufficient basis to refuse to vacate an entry of default, even if the defendant had a meritorious defense);
accord, e.g., Travelodge Hotels, Inc. v. Taurus Hotels Corp., 179 F.R.D. 569, 571 (C.D. IN). 1998)
(citing Jones _v. Phipps, 39 F.3d 158, 165 (7th Cir. 1994), and Pretzel _& Stouffer, 28 F.3d at 46)

(defendant must meet all three requirements necessary to justify relief)). Binding case law has
elaborated upon Rule 55(c) by requiring vacatur if the defendant shows (1) good cause for his default;
(2) quick action to correct it; and (3) a meritorious defense to the complaint. Pretzel & Stouffer v.

Imperial Adjusters, Inc., 28 F.3d 42, 45 (7th Cir. 1994): O'Brien v. R.J. O'Brien & Assocs., 998 F.2d

1394, 1401 (7th Cir, 1993);United States v. Di Mucci, 879 F.2d 1488, 1495 (7th Cir. 1989).The first
consideration —- good cause for the defendant's default — may consist of "mistake, inadvertence,
surprise, or excusable neglect." Fed. R. Civ. P. 60(b)(1);[2] Tate v. Riverboat Servs.. Inc., 305 F. Supp.
2d 916, 919 (N.D. Ind. 2004). The second consideration — quick action to correct — looks at the time
that passed between entry of default and the defendant's motion, yet it ultimately turns on the particular
situation presented. See Jones v. Phipps, 39 F.3d 158, 165 (7th Cir. 1994). Factors that define such a
situation are the litigant's reason for delay, his ability to learn about the grounds for judgment earlier,

and the extent of prejudice suffered by the party seeking default Tate, 305 F.'Supp. 2d at 923 (relying

upon Kagan _v. Caterpillar Tractor Co.,795 F.2d 601, 610 (7th Cir. 1986)), Finally, the third
consideration — the existence of a meritorious defense —- does not necessarily require a winning
defense but instead calls for “one which at least raises a serious question regarding the propriety of a

default judgment and which is supported by a developed legal and factual basis." Jones, 39 F.3d at 165.



Chicago District Office
509 West Madison St., Suite 2000
Chicago, 11. 60661
PH: (312) 869-8000
‘TDD: (312) 869-8001
ENFORCEMENT FAX: (312) 869-8220
LEGAT. FAX: (312) 869-8124

NOTICE TO ALL EMPLOYEES

The U.S, Equal Employment Opportunity Commission (EEOC) has investigated
whether ORKIN, LLC. violated Title VII of the Civil Rights Act of 1964, as amended
(Title VII), by maintaining an arbitration policy. The EEOC found that this policy
impacted employees’ rights to engage in protected activity. Orkin disputes this claim. This
Notice is part of a Concitiation Agreement between ORKIN, LLC and the EEOC which
resolves this dispute. ORKIN, LLC, its supervisors and managers will support and comply
with Federal Law which prohibits discrimination and harassment against any employee or
applicant because of an individual’s race. ORKIN, LLC will continue to train its
management and employees regarding its obligations under Title VI. Orkin will distribute
a revised ADR policy.

Orkin will comply with federal law prohibiting retaliation against any applicant or
employee because he/she files an employment discrimination charge against the employer.
opposes employment discrimination, or cooperates with or participates in the
Government's investigation of a charge of discrimination.

Should you have any complaints or questions regarding employment discrimination, you

can contact your Human Resources Manager. Your Division Human Resources Manager can be
contacted at

IS AN OFFICIAL NOTI MUST NOT. DEFACED. This notice must remain
Posted as agreed upon by all parties and musi not be altered, defaced, or covered by any other
material. Any questions .conceming this notice or compliance with its provisions may be directed
to the EEOC at the above-address and telephone number.

EEOC is responsible for enforcing Title VII of the Civil Rights Act of 1964, as amended, which
prohibits employment discrimination based on race, color, sex. or national origin: the Age
Discrimination in Employment Act of 1967, as amended: the Equal Pay Act of 1963; the
Americans with Disabilities Act of 1990 and the Genetic Information Non-Discrimination Act of
2008.

Date John P. Rowe, District Director, Chicago District Office

Date ORKIN, LLC



#210-2006-01523
Page 5 of 5

Uhave read this Agreement and | accept and agree to its provisions.

Date . Respondent
Date ~ Charging Party

Approved and Agreed to on Behalf of the Commission:

Date John P. Rowe
District Director



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P.O. Box 105108,
Atlanta, GA 30302
1-800-845-6004

IRENN JOHNSON
625 S DILFER AVE
222

WAUKEGAN, IL 60085

Dear: IRENN JOHNSON :

Please be advised that ChoicePoint Services inc. is reporting public record information
conceming you to: ROLLINS, INC of ATLANTA, GA

The results of this search, listed below, are confidential and will not be distributed to any
organization other than the one that originally requested it. The results are not an
Indication of an acceptance or a rejection of your employment or service. A separate
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acceptane or rejection.

Ifyou have any questions, please call our consumer disclosure center at 1-800-845-6004.

Case Date

Case # 1982CR07956012536

Source COOK, ILLINOIS

Charge CRIMINAL TRESPASS TO LAND
Charge Type MISDEMEANOR

Disposition PENDING NEXT COURT DATE
Oisposotion Date 3/31/2006

Sentence

Sincerely,

ChoicePoint

Atlanta Employment Service Center

ze

. 4199629 ATL

ChoicePoint ky Tuesday, March 15, 2005
ChoicePoint Consumer Center



Conference requesting that they advise their “client or former client” accordingly. See Exhibit 8.

13. On March 19, 2012, the Defendant’s counsel responded stating that “Orkin was not a proper
party to [my] lawsuit” and that they were “not authorized” to accept service of process. See Exhibit 9.
On said date, a summons was issued.

14, On March 21, 2012, a copy of the summons and complaint was personally served on Fuss. He
scanned the papers and sent them via e-mail to Ms. Meribetth Ehlers (“Ehlers”), Midwest Division
Human Resources Manager Fuss Decl. Para. 6, On the same day, Ehlers had the documents sent to
Jefferson Blandford (“Blandford”), Orkin/ Rollins’ in-house legal counsel. Blandford made an inquiry
as to the delivery of the documents and Ehlers replied to the inquiry Ehlers Decl. para 5. Also on said
date, a copy of the summons and complaint were served certified mail to the Defendant’s counsel and
received on March 27, 2012. See Exhibit 10.

15. On March 22, 2012, the court held a Status Conference where the counsel for the Defendant
appeared informally out of “courtesy” stating that they were not authorized to accept service of process.
16. On April 19, 2012, the court entered an Entry of Default.

17. On April 27, 2012, the Defendant moved to vacate default and to dismiss.

POINTS AND AUTHORITIES

18. Rule 55(c) of the Federal Rules of Civil Procedure provides for relief from entries of default,

whereas Rule 60(b) provides for relief from judgments by default. See Fed. R. Civ. P. 55(c) and 60(b).

Consistent with the traditional equitable powers of courts, Rule 55 provides relief from entries of
default for "good cause shown.” Fed. R. Civ. P. 55(c). With respect to default judgments, Rule 55(c)
provides that "if a judgment by default has been entered, a court may likewise set it aside with Rule
60(b)." Fed. R. Civ. P. 55(c). The "standard to set aside the entry of default under Rule 55(c) is
essentially the same as the standard for vacating a default judgment under Rule 60(b)." A motion to set

aside a default requires a court to reconcile the goal of permitting the defaulting party an opportunity to



JOHNSON acknowledges that this Agreement in no way constitutes an admission by the
COMPANY that the COMPANY has violated any federal, state, or municipal law or any
law whatsoever and instead represents a good faith settlement of contested and disputed
claims allowing the COMPANY to buy its peace. No statement in this Agreement or the
Conciliation Agreement, or consideration provided pursuant to the terms of both
agreements, constitutes, nor should it be deemed to constitute, an admission by the
COMPANY of any violation of law or any wrongdoing whatsoever. The COMPANY
expressly denies any such wrongdoing.

JOHNSON agrees and acknowledges that he will not apply for employment with the
COMPANY, and that he forever waives and relinquishes any and all claims, rights. or
interests in reinstatement or future employment that he presently has or might in the
future have with the Company.

This Agreement in its entirety shall be binding upon the parties hereto, their heirs,
successors, legal representatives, and assigns.

Tf the scope of any provision contained in this Agreement is too broad to permit enforcement
of such provision to its full extent, then such provision shall be enforced to the maximum
extént permitted by law, and enforced as reformed or modified, in any proceedings brought
to enforce such provision. Subject to the provisions of the foregoing sentence, whenever
possible, each provision of this Agreement will be interpreted in such a manner as to be
effective and valid under applicable law, but if any provision of the Agreement is held to be
prohibited by or invalid under applicable law, such provision, to the extent of such
prohibition or invalidity, shall be deemed not to be a part of the Agreement, and shall not
invalidate the remainder of such provision or the remaining provisions of the Agreement. Tf
Paragraphs 3, 4, 5, 6, 7, 8, 14 and/or 16 of the AGREEMENT arc held to be prohibited by or
invalid under applicable law, JOHNSON understands and agrees he would be responsible
for returning all monies he received pursuant to Paragraph 1 of the Agreement to the
COMPANY. JOHNSON understands and agrees that the COMPANY would be irreparably
damaged in the event that the provisions of Paragraphs 3, 4, 5, 6, 7. 8, 14 and/or 16 are
violated, and agrees that the COMPANY shall be entitled (in addition to any other remedy
to which it may be entitled, purstiant to this Agreement, at law or in equity) to an injunction
or injunctions to redress breaches of this Agreement and to specifically enforce the terms
and provisions hereof.

JOHNSON agrees that he will not make or publish any communication which negatively
impugns or detrimentally impacts the business reputation of the COMPANY.

This Agreement is a contract between JOHNSON and the COMPANY and is not merely
a recital.

JOHNSON agrees that he shail maintain the terms of this Agreement in the strictest
confidence, Specifically, JOHNSON agrees that he will not reveal the terms of this
Agreement to any person, COMPANY employee, COMPANY former employee, agency,
institution, company, or other entity unless the COMPANY agrees in writing that he may
do so. The only exceptions to this covenant are that JOHNSON may make such

-4-



EXHIBIT 6



regarding being terminated or laid off during slow periods. Not only did Fuss state that he had not
terminated any employees in 5 1/2 years for these reasons, but went on to say that he had in fact
promoted 2 employees. See Exhibit 1. On said date, I completed the pre-employment requirements.

2. On March 15, 2005, Shawn Allen, notified Fuss that the results of my criminal background
check was outside company policy. See Exhibit 2. The criminal background investigation indicated
that I had been arrested for criminal trespass to land. I was never convicted of this charge.

3. On March 18, 2005, Fuss rescinded the job offer. The reason that he gave me involved hours of
availability. On said date, I hand-delivered a written request for my pre-employment records. See
Exhibit 3.

4. On April 4, 2005, I was re-offered employment contingent upon physical results. The very next
day, I was notified that medical results were completed.

5. On April 21, 2005, I started employment. On said date, Melanie Watkins and Larry Black
prohibited me from modifying the arbitration agreement with the threat of termination.

6. On April 25, 2005, { submitted a written request for my employment records. See Exhibit 4.

7. On June 8, 2005, I submitted a written complaint opposing discrimination and violation of the
Illinois Personnel Record Review Act. See Exhibit 5.

8. On August 31, 2005, I was terminated.

9. Between September 1, 2005 and January 8, 2012, all conciliation efforts have failed and
applicable administrative remedies were exhausted. See Exhibit 6.

10. On January 9, 2012, I filed a complaint alleging violations of Title VII of the Civil Rights Act
(as amended) and the Illinois Human Rights Act in the US District Court Northern District of Illinois.
11. On January 20, 2012, the Defendant received a request for waiver of summons and complaint as
evident by certified mail return receipt hereto and marked as Exhibit 7.

12. On March 17, 2012, I unofficially notified the counsel for the Defendant of the pending Status



AO 399 (01/09) Waiver of the Service of Summons
ieee

UNITED STATES DISTRICT COURT

for the
Northern District of Illinois
TREN 1- JOHNSON
Plaintiff
Vv. Civil Action No.
CRIN, LIC) oR Kinny PEST CoMeOL.
Defendant

WAIVER OF THE SERVICE OF SUMMONS

To: TeRsrmad H- SoHo)
(Name of the plaintiff's attorney or unrepresented | plaintiff)

T have received your request to waive service of a summons in this action along with a copy of the complaint, two copies
of this waiver form, and a prepaid means of returning one signed copy of the form to you.

1, or the entity 1 represent, agree to save the expense of serving a summons and complaint in this case.

1 understand that I, or the entity I represent, will keep all defenses or objections to the lawsuit, the: court’s jurisdiction, and
the venue of the action, but that I waive any objections to the absence of a summons or of service.

[also understand that I, or the entity I represent, must file and serve an answer or a motion under Rule 12 within

60 days from 1-47-12 __, the date when this request was sent (or 90 days if it was sent outside the
United States). If] fail to do so, a default judgment will be entered against me or the entity { represent.

Date:

‘Signature of the attorney or unrepresented party

Printed name of party waiving service of summons Printed name

Address

E-mail address

Telephone number

Duty to Avoid Unnecessary Expenses of Serving a Summons
Rule 4 of the Federal Rules of Civil Procedure requires certain defendants to cooperate in saving unnecessary expenses of serving a summons and
complaint. A defendant who is located in the United States and who fails to return a signed waiver of service requested by a plaintiff located in the
United States will be required to pay the expenses of service, unless the defendant shows good cause for the failure.
“Good cause” does not include.e belief that the lawsuit is groundiess, or that it has been brought in an improper venue, or that the court has no
jurisdiction over this matter or over the defendant or the defendant’s property.

If the waiver is signed and returned, you can still make these and all other defenses and objections, but you cannot object to the absence of
a summons or of service.

If you waive service, then you must, within the time specified on the waiver form, serve an answer or a motion under Rule 12 on the plaintiff and file
& copy with the court, By signing and returning the waiver form, you are allowed more time to respond than if a summons had beer served.



OGLETREE, DEAKINS, NASH,

SMOAK & STEWART, P.C.
ree Cc Atorneys at Law

One Ninety One Peachtree Tower
191 Peachtree St. NE, Suite 4800
Atlunta, GA 30303

‘el 404,881,1300
04. 870.1732
wwwogletreedcakins.com

Jon M. Gumbel
jon.gumbel@ogletreedeakins.com

August 26, 2011

Irenn H, Johnson

TOV7 60th Ave., Apt. 101

Kenosha. WI 53142

VIA CERTIFIED MAIL AND EMAIL

RE: Johnson y. Rollins

Dear Mr. Johnson:

As per my earlier message to you, the EEOC and Rollins/Orkin have agreed to a conciliation
agreement which resolves your pending charges before the EEOC. One of the critical terms of that
conciliation agreement is the stipulation that you, as an individual, and Rollins/Orkin agree to a separate
waiver and release agreement. The Commission will not involve itsclf in the negotiation or execution of
this separate agreement. However, your agreement to a separate release is a necessary precondition to the
payment by Rollins/Orkin of any and all settlement monies to you.

Enclosed/attached for your consideration is Rollins’/Orkin’s proposed settlement agreement.
Please carefully review and respond only to me with any thoughts or recommendations you may have.
The EEOC has asked that | report back soon regarding the status of this agreement so the conciliation
agreement can be finalized.

Thank you for your prompt attention to this matter,

- Sincerely,

Jon M. AM fd

JMG/kb
Enclosure

10871322.1 (OGLETREE)

Atonta © Austin © Birmingham © Hlormfick Hills © Boston © Chadestan © Chadom: © Chiego © Cloveand * Gohimba = Dallas © Denver # Greensbor
Greenville © Howson * Indimaprdis * Jackson © Kansas <* Los Anges » Memphis * Mami © Minneapolis # Morristown * Nashville # New Oreans
Orange County # Phibeklphin * Phomis © Sinburgh © Por St Janis ® St. ‘Thomas © Sin Antonio * San Frincsen © "Tampa * Fomunce * Tucson * Washington



#210-2006-01523
Page 3 of 5

Respondents agree to provide written notice within fourteen ( 14) days of satisfying the
obligations specified in paragraph 6 above, to Carmella DiNicola, Investigator, 500 W.
Madison St., Suite 2000, Chicago, Illinois 60661, 312-869-8090, email:
carmella.dinicola@eeoc.gov. -

Charging Party and Respondents represent that they have negotiated and Charging Party
has executed and delivered a Private Settlement Agreement separate from this
Agreement, Charging Party and Respondents acknowledge and agree that the execution
of this Private Settlement Agreement is a necessary prerequisite to the execution of this
Conciliation Agreement. The EEOC has not participated in the negotiation of, is not a
Party to. and has no information regarding that Private Settlement Agreement other than
the representation reflected in the preceding sentence.

POLICY

Within thirty (30) calendar days of the execution of this Agreement, Respondents agree
to submit to the EEOC for review their revised Alternative Dispute Resolution Policy
(“ADR Policy”), addressing the following conditions that the EEOC believes limit
employee EEO rights under Title VII:

a Section I A, which fails to mention employee EEOC rights;

b. Section IV B, which restricts employees to filing a charge of
discrimination to the “applicable contractual limitation period;” and

e. Section VIB, which requires employees who serve Respondents with a
Demand for Arbitration to request administrative closure (“notice of right
to sue”) from the EEOC within ninety (90) days.

After the final policy in Section 9 has been agreed to by the EEOC and Respondents,
Respondents shall post notices of the ADR Policy revisions along with the revised ADR
Policy at Respondents* United States office locations where, subject to the terms and
conditions of the revised ADR policy, employees are subject to the ADR policy.

Within thirty (30) days after providing the revised ADR Policy, Respondents will certify
to the EEOC that it has complied with paragraph 10 above,

NING

The Respondents agree to conduct training of Orkin’s Human Resources Managers in



Respectfully,

IRENN JOHNSON

Encl.
1. Intake doc
2. Press release



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Interview Questionnaire
Name MALL Liss Date 3/4)re
Company ofk iw
Title (yer Sates Maemo

i. Tell me about the position or positions that you are Jooking to fill and what are the qualifications and
responsibilities? :
INSWE SMES) WhO CALS

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MEET gobo erty beng fo 3 pape Site prere cish oy

ou had to terminate an employee and what where the

3. Tell me about the last two situations whey

4. Tell me about the last two situations where you promoted an employee.

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CERTIFIED MAIL.. RECEIPT

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. Subeee: Towns V. Cekin (Cc MAR 17, 2012
CASE we MLev ivy j TroHe CHAeaE ne:

2006 CN 93 /
ME. Gum be/,

You are 4 last Attorney of vero br Or kin pert Gntrol,
A Complaint has been Fleof vaxtoet and a status hearing * 1a
open Cort Will be Weel m B/22z/h2z CF:45 am,

Please aduye your Client or formar chind accordingly,

Pears /

Dvrtan Doh ason
Joid 60 me Fte/
Kenosha, wt £42
LWL- 105-6630

Encl. (3)



ROLLINS, Inc. Sil CONFIDENTIAL

2170 Piedmont Road, Atlanta, Georgia 30324

Phone: (404) 888-2184 SK
Fax: (404) 888-2189

TO: BRANCH: 615/519

CC: REGION: __- Attn: Region Manager

RE: CRC RESULTS

FROM: HR / PRE-EMPLOYMENT ASSESSMENT DEPARTMENT
# OF PAGES (Including Cover Sh a’

Attached are the results of criminal background check, Please review the marked box below to determine if the
applicant Is within or outside company policy. The resuffs of the MVR have already been faxed to your region
office.

‘Sender Shawn Allen

Applicant Name: Irenn Johnson
Applicant Number:

WITHIN

Hf the results of the CRC are within company policy, please forward this information onto the appropriate branch. A
Motor Vehicle Record Check has already been completed on this applicant and the results have already been
forwarded to your office. if this applicant is hired, attach a copy of the results to the new hire paperwork and keep a
copy in the employee's personnel file.

QUTSIDE
Wf the MVR results are outside company policy Human Resources will notify the appropriate branch and fax the
required paperwork to give to the applicant. Please verify that the branch supplies the applicant with the following:

1. Copy of MVR
2. Copy of Consumer's Rights

if you do not recsive this candidate's MVR within 72hrs or if you have any questions regarding
this information, please contact Donna King at (404) 888-2164.