IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

U.S. EQUAL EMPLOYMENT ) 

OPPORTUNITY COMMISSION, )

)

Plaintiff, ) Case No. 1:20-cv-3683

)

v. )

)

PERSONNEL STAFFING GROUP, LLC )

d/b/a MOST VALUABLE PERSONNEL )

and MVP WORKFORCE, LLC )

)

________________________________________________)

CONSENT DECREE

1. Plaintiff Equal Employment Opportunity Commission (“EEOC” or 

“Commission”) filed Case No. 1:20-cv-3683, alleging that, since at least January, 2014 to the 

present, at their facilities in Illinois, Defendants Personnel Staffing Group, LLC d/b/a Most 

Valuable Personnel (“PSG”) and MVP Workforce, LLC (“Workforce”) (collectively, 

“Defendants”) violated Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e 

et seq. (“Title VII”), and Title I of the Civil Rights Act of 1991, 42 U.S.C. § 1981a, by:

A. Failing or refusing to refer a class of female employees/applicants, including 

Charging Parties Qiana Matthews and Keeona Person and class members Jasmine 

Cox and Michelle Gongora, for certain job assignments, either on their own 

initiative or in compliance with discriminatory client requests, because of their 

sex;

B. Subjecting a class of female employees/applicants to different terms and 

conditions of employment because of their sex, including but not limited to, fewer 

hours of work;

C. Failing or refusing to refer a class of employees/applicants, including Charging 

Party Norman Green, for certain job assignments, either on their own initiative or 

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in compliance with discriminatory client requests, because of their race (Black);

and

D. Subjecting a class of employees to different terms and conditions of employment 

because of their race (Black), including but not limited to, fewer hours of work.

2. This Consent Decree shall not be construed as an admission by any party of the 

claims or defenses of any other party. 

3. In the interest of resolving these matters, and as a result of having engaged in 

comprehensive settlement negotiations, the parties have agreed that these actions should be 

finally resolved by entry of this Consent Decree (hereafter “Decree”). 

FINDINGS

4. Having carefully examined the terms and provisions of this Decree, and based on 

the pleadings, record, and stipulations of the parties, the Court finds the following:

A. This Court has jurisdiction of the subject matter of these actions and of the 

parties.

B. The terms of this Decree are adequate, fair, reasonable, equitable, and just. The 

rights of EEOC, Defendants, the Charging Parties, the claimants, and the public 

interest are adequately protected by this Decree.

C. This Decree conforms to the Federal Rules of Civil Procedure and Title VII and is 

not in derogation of the rights or privileges of any person. The entry of this 

Decree will further the objectives of Title VII and will be in the best interests of 

the parties, the Charging Parties, the claimants, and the public.

NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT:

INJUNCTION

5. Defendants, their officers, shareholders, agents, employees, successors, assigns 

and all persons acting in concert with them are enjoined from failing or refusing to refer for 

employment, or otherwise to discriminate against, any individual because of sex or race, or from 

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classifying or referring for employment any individual on the basis of sex or race, in violation of 

Title VII.

6. Defendants, their officers, shareholders, agents, employees, successors, assigns 

and all persons acting in concert with them are enjoined from engaging in any form of retaliation 

against any person because such person has opposed any practice made unlawful under Title VII, 

filed a Charge of Discrimination under Title VII, testified or participated in any manner in any 

investigation, proceeding, or hearing under Title VII, or asserted any rights under this Decree.

MONETARY RELIEF

7. Defendant PSG shall pay the gross sum of $145,000, pursuant to the terms of the 

Settlement Agreement entered into in Cox, et al. v. Personnel Staffing Group, LLC, Case No. 16 

C 11282 (N.D. Ill.). Qiana Matthews will provide an executed release in the form attached as 

Exhibit A to the Decree.

8. Defendant PSG shall pay the gross sum of $337,500, pursuant to the terms of the 

Settlement Agreement entered into in Hunt, et al. v. Personnel Staffing Group, LLC, dba MVP, 

et al., Case No. 16 C 11086 (N.D. Ill.) Prior to receiving payment under the Settlement 

Agreement and this Decree, charging party Norman Green shall provide PSG with an executed 

release as part of the Hunt Settlement Agreement.

9. Defendant Workforce shall pay the gross sum of $86,000, pursuant to the terms of 

the Settlement Agreement entered into in Smith, et al. v. MVP Workforce, LLC, et al., Case No. 

18 C 03718 (N.D. Ill.)

PERSONNEL STAFFING GROUP, LLC

10. PSG hereby certifies in writing to the Court and to the EEOC that: a) it does not 

have any contracts with customers which result in PSG assigning temporary employees in 

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Illinois; and b) it does not operate offices in Illinois through which temporary employees are 

assigned to customers in Illinois. 

11. PSG shall provide the EEOC with semi-annual written certifications throughout 

the duration of the Decree demonstrating that PSG has not entered into any contracts with 

customers that result in PSG assigning temporary employees in Illinois nor does it operate any 

offices in Illinois through which laborers are assigned to customers in Illinois. The first such 

certification shall be due 6 (six) months after entry of the Decree. 

12. If, during the term of this Decree, PSG enters into any contracts with customers in 

Illinois that result in PSG’s assignment of temporary employees to that customer, or operates any 

offices that assign temporary employees to customers in Illinois, PSG shall immediately report 

that to the EEOC and be bound by the provisions of this Decree contained in paragraphs 13 - 31, 

below, without further act or deed by any person and without further notice to or order from the 

Court. 

POSTING OF NOTICE

13. Within five (5) business days following entry of the Decree, Defendant 

Workforce shall post at each of its locations in Illinois a copy of the Notice (attached as Exhibit 

B to this Decree) on any and all bulletin board(s) usually used by Workforce for communicating 

with its employees and applicants. The Notice shall remain posted for two and one half (2 1⁄2) 

years from the date of entry of this Decree. Workforce shall take all reasonable steps to ensure 

that the posting is not altered, defaced or covered by any other material. Workforce shall certify 

to EEOC in writing within ten (10) business days after entry of the Decree that the Notice has 

been properly posted. During the duration of this Decree, Defendant shall permit a 

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representative of EEOC to enter Defendant Workforce’s premises for purposes of verifying 

compliance with this Paragraph at any time during normal business hours without prior notice. 

MAILING TO CLIENTS

14. Within 21 business days following entry of the Decree, Workforce shall send a 

notice (“Client Notice”) to all of its current clients that it is an equal opportunity employer and 

will not discriminate on the basis of sex, race, age, national origin, religion, or disability when 

selecting employees for job assignments. Workforce shall obtain the EEOC’s approval of the 

language of the Client Notice before it is sent out. During the term of this Decree, within five (5) 

business days of Workforce obtaining a new client, it shall send the Client Notice to the new 

client. 

RECORD KEEPING

15. For the duration of the Decree, Defendant Workforce shall maintain and make 

available for inspection and copying by the EEOC the following records for all new applicants to 

Defendant Workforce following the entry of this Decree:

A. All sign-in sheets and applications of individuals seeking employment/referral, or 

other records that are used or created in lieu of sign-in sheets.

B. All notes of interviews with an applicant and notes of other contact with an 

applicant;

C. All applicant self-identification forms;

D. Pursuant to Workforce’s obligations under the Illinois Day and Temporary Labor 

Services Act, 820 ILCS 175/12(4), all requests made by clients for specific 

qualifications or attributes of a day or temporary laborer;

E. Pursuant to Workforce’s obligations under the Illinois Day and Temporary Labor 

Services Act, 820 ILCS 175/12(1), (2) & (9), for each day or temporary laborer:

1. the name and address;

2. race and gender, as provided by the day or temporary laborer;

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3. the name, address, and telephone number of the client and specific location 

sent to work;

4. the type of work performed;

5. the number of hours worked;

6. the hourly rate of pay; and 

7. the date sent.

F. Any Workforce database, or other documents, containing all information 

maintained for each applicant;

G. Documents related to each complaint of sex and/or race discrimination made by 

an applicant for employment, if any. Such documents shall include the date the 

complaint was made, the name of the complainant, the allegations of the 

complaint, and what actions Workforce took, if any, to resolve the matter; and

H. Workforce shall make all documents or records referred to in this Paragraph 

available for inspection and copying, including providing a copy of any 

Workforce database containing information regarding applicants, within fifteen 

(15) business days after the EEOC so requests. Workforce shall require personnel 

within its employ whom the EEOC reasonably requests for purposes of verifying 

compliance with this Decree to cooperate with the EEOC and to be interviewed 

for the purpose of determining compliance with this Decree.

REPORTING

16. Within six months of entry of this Decree, and at six-month intervals thereafter 

for the duration of the Decree, Workforce shall provide Reports to the EEOC. Workforce’s 

Reports shall include information regarding the following:

A. A certification in writing that it is not complying and will not comply with 

discriminatory employee assignment requests from clients;

B. Any Workforce database, or other documents, containing all information 

maintained for each applicant, including, but not limited to, the information 

maintained pursuant to Paragraphs 15D, E & F; and

C. All complaints or reports, oral or written, of sex or race discrimination or 

retaliation.

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MONITORING

17. There will not be an outside monitor initially assigned to oversee compliance with 

this consent decree. However, in the event the EEOC determines that review of Workforce’s

compliance with the terms herein necessitate an outside monitor, EEOC can request the 

appointment of an outside monitor to undertake actions the EEOC deems appropriate. In the 

event the EEOC seeks to appoint an outside monitor, the parties shall meet and confer and 

attempt to resolve any dispute regarding the issue. In the event the parties are not able to resolve 

their dispute, the EEOC and Workforce will submit themselves to the jurisdiction of this 

Honorable Court for the purpose of resolving any and all issues pertaining to the appointment of 

an outside monitor. The Court will have authority to appoint an outside monitor recommended 

by the EEOC, paid for by Workforce.

ADOPTION OF NEW POLICIES AND PROCEDURES

18. Within twenty-one (21) calendar days of the date of the entry of this Decree, 

Workforce shall use, adopt, and/or implement policies and procedures designed to carry out the 

terms and conditions of this Decree, including the following:

A. Workforce shall provide clear instructions to temporary and internal employees as 

to how to make a complaint of discrimination, including identifying the person(s) 

to whom employees can make such complaints;

B. Workforce shall adopt a temporary employee search process for identifying 

qualified individuals for open assignments with the following minimum 

standards:

1. For assignments that require no specific skill set or experience, Workforce 

will offer the assignment to its temporary employees regardless of gender and 

race; and

2. If a client specifically requests a specific skill set or prior experience, 

Workforce will document the request from the client and then conduct a 

gender- and race-neutral search for temporary employees with the skills or 

experience specifically requested by the client.

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19. Within ten calendar days of the adoption of the above policy, Workforce shall 

provide a copy of the policy to the EEOC. Workforce must consider any suggestions made by 

EEOC with respect to its policy. However, the inclusion of this paragraph in the decree does not 

represent the EEOC’s or the Court’s approval of Defendant’s policies. Ten days after receipt of 

any comments from EEOC, Workforce shall deliver a hard copy of the policy to all of its 

employees. Thereafter, Workforce shall make the policy available to new hires within five (5) 

days of the date of hire.

TRAINING

20. Workforce shall provide semi-annual training on the requirements of Title VII to 

all employees in any way involved in the hiring and/or assignment process, including, but not 

limited to, employees responsible for providing applications to potential applicants, employees 

who have input into and/or decide which applicants to interview, employees who interview 

applicants, employees who have input in the hiring/assignment process, and employees who 

make hiring/assignment decisions. Such training shall be conducted by an outside trainer paid 

for by Workforce and approved by EEOC. The first semi-annual training shall take place within 

ninety (90) days of the entry of this Decree, with subsequent trainings taking place at six (6) 

month intervals thereafter.

21. Workforce shall obtain approval from the EEOC of its proposed trainer prior to 

each training session. Workforce shall submit the name, address, telephone number, resume and 

training proposal of the proposed trainer to the EEOC at least (30) calendar days prior to the 

proposed commencement date(s) of the training(s). The EEOC shall have five (5) business days 

from the date of receipt of the information described above to accept or reject the proposed 

trainer. In the event the EEOC does not approve Workforce’s designated trainer, Workforce 

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shall have ten (10) business days to identify an alternate trainer. The EEOC shall have five (5) 

business days from the date of receipt of the information described above to accept or reject the 

alternate trainer. If the parties cannot through this process agree on a trainer, then they may seek 

the Court’s assistance under Paragraph 25.

22. Workforce shall certify to the EEOC, in writing, within five (5) business days 

after each training session has occurred that the training has taken place and that the required 

personnel have attended. Such certification shall include the date, location, and duration of the 

training, and a copy of the registry of attendance, which shall include the name and position of 

each person in attendance. Workforce shall also provide EEOC with a list of the names of all 

current employees who are in any way involved in the hiring and/or assignment process.

23. Within five (5) business days after each training session has occurred, Workforce 

shall provide to the EEOC copies of any and all pamphlets, brochures, outlines, or other written 

materials provided to the participants of the training session.

24. Any new hire for Workforce who will be responsible for providing applications to 

potential applicants, has input into and/or decides which applicants to interview, interviews 

applicants, has input in the hiring/assignment process, or makes hiring/assignment decisions 

shall be provided a copy of all pamphlets, brochures, outlines, or other written materials 

provided to the participants of the training session within five (5) business days of his/her start 

date. 

DISPUTE RESOLUTION

25. In the event that either party believes that any other party has failed to comply 

with any provision of this Decree, the complaining party shall notify the other parties of the 

alleged non-compliance and shall afford the alleged non-complying party ten (10) business days 

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to remedy the non-compliance or to satisfy the complaining party that the alleged non-complying 

party has complied. If the alleged non-complying party has not remedied the alleged noncompliance or satisfied the complaining party that it has complied within ten (10) business days, 

the complaining party may apply to the Court for appropriate relief.

26. In resolving any dispute with regard to a party’s compliance with any provision of the 

Decree, the Court shall have available to it all equitable remedies which come within the Court’s inherent 

authority, including, but not limited to, extension of any or all terms of the Decree and/or imposing a 

monetary fine for non-compliance.

DURATION OF DECREE AND RETENTION OF JURISDICTION

27. All provisions of this Decree shall be in effect (and the Court will retain 

jurisdiction of this matter to enforce this Decree) for a period of two and one-half (2 1⁄2) years

immediately following entry of this Decree. If, however, at the end of the two and one-half-year 

period, any disputes remain unresolved, the term of this Decree shall be automatically extended 

for the sole purpose of resolution of the issues raised in such disputes (and the Court will retain 

jurisdiction of this matter to enforce this Decree) until such time as all such disputes have been 

resolved.

MISCELLANEOUS PROVISIONS

28. Each party to this Decree shall bear its own attorney fees, expenses, and costs. 

29. If any provision of this Decree is found to be unlawful, only such 

provision(s)shall be severed and the remainder of this Decree shall remain in full force and 

effect.

30. This Consent Decree and the terms thereof apply only to the assignment of 

laborers in Illinois. The injunctive relief, record keeping, training, adoption of new policies and 

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procedures requirement, reporting requirements, and all other terms and conditions set forth in 

this Consent Decree are only applicable to the assignment of laborers in Illinois. 

31. When this Decree requires submission by Defendants of reports, certifications, 

notices, or other materials to the EEOC, they shall be mailed to: PSG/MVP Workforce 

Settlement, 230 S. Dearborn St., Suite 2920, Chicago, IL, 60604. When this Decree requires 

submission by the EEOC to Workforce, they shall be mailed to Laurence Gould, MVP 

Workforce, LLC, 1751 Lake Cook Road, Suite 600, Deerfield, Illinois 60015 with a copy to 

Elliot Richardson and Carter Korey, Korey Richardson LLP, 20 S. Clark Street, Suite 500, 

Chicago, Illinois 60603. The parties can agree to provide submissions via email. 

ENTERED AND APPROVED FOR:

For the EQUAL EMPLOYMENT

OPPORTUNITY COMMISSION

131 M Street, NE

Washington, DC 20507

SHARON FAST GUSTAFSON

General Counsel

JAMES LEE

Deputy General Counsel

GWENDOLYN YOUNG REAMS

Associate General Counsel

/s/ Gregory Gochanour

Gregory Gochanour

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION

Chicago District Office

230 S. Dearborn, Suite 2920

Chicago, Illinois 60604 

Telephone: (312) 872-9685

E-Mail: gregory.gochanour@eeoc.gov

/s/ Ann M. Henry

Ann M. Henry

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EQUAL EMPLOYMENT OPPORTUNITY 

COMMISSION

Chicago District Office

230 S. Dearborn, Suite 2920

Chicago, Illinois 60604 

Telephone: (312) 872-9659

E-Mail: ann.henry@eeoc.gov

For Defendants:

/s/ Elliot Richardson

Elliot Richardson

One of Defendants’ Attorneys

Korey Richardson LLP

Two First National Plaza

20 South Clark Street, Suite 500

Chicago, IL 60603

Telephone: 312-372-7045 ext. 458

Email: erichardson@koreyrichardsonlaw.com

ENTER: 6/29/20

_____________________________

John Z. Lee

United States District Judge

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EXHIBIT A

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RELEASE

In consideration for the payments to be paid to me by Defendants Personnel Staffing 

Group, LLC d/b/a Most Valuable Personnel and/or MVP Workforce, LLC, in connection with 

the resolution of EEOC v. Personnel Staffing Group, LLC d/b/a Most Valuable Personnel and 

MVP Workforce, LLC, Case No. 1:20-cv-3683 (N.D. Ill.), I waive my right to recover for any 

claims of race and sex discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 

§ 2000e et seq., and the Civil Rights Act of 1991, 42 U.S.C. §1981a, that I had against 

Defendants Personnel Staffing Group, LLC d/b/a Most Valuable Personnel and MVP Workforce, 

LLC, prior to the date of this release and that were included in the claims alleged in EEOC’s 

complaint in EEOC v. Personnel Staffing Group, LLC d/b/a Most Valuable Personnel and MVP 

Workforce, LLC, Case No. 1:20-cv-3683 (N.D. Ill.)

_____________________________ Dated:__________________

Qiana Matthews

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EXHIBIT B

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NOTICE TO ALL EMPLOYEES

This Notice is being posted pursuant to a Consent Decree entered by the federal court in 

EEOC v. Personnel Staffing Group, LLC and MVP Workforce, LLC, No. 1:20-cv-3683 (N.D. Ill.), 

resolving a lawsuit filed by the Equal Employment Opportunity Commission (“EEOC”) against 

Personnel Staffing Group, LLC d/b/a Most Valuable Personnel and MVP Workforce, LLC

(“Defendants”). 

In its litigation, EEOC alleged that Defendants violated Title VII of the Civil Rights Act 

of 1964, as amended, (“Title VII) by discriminating against classes of individuals on the bases of 

sex and race. 

To resolve the case, Defendants and EEOC have entered into a Consent Decree which 

provides, among other things, that:

1) Defendants will make a monetary payment to resolve the discrimination claims 

against them; 

2) Defendants are enjoined from discriminating against any employee on the basis of

sex or race;

3) Defendants will not retaliate against any employee who has made allegations of 

discrimination or participated in any way in a proceeding involving discrimination 

under Title VII; 

4) Defendants will provide training on Title VII to all employees in any way involved 

in the hiring and/or assignment process; and

5) Defendants will change their policies and procedures to comply with Title VII. 

The EEOC enforces the federal laws against discrimination in employment on the basis of race, 

national origin, color, religion, sex, age, or disability. The EEOC charges no fees and has 

employees who speak languages other than English. If you believe you have been discriminated 

against, you may contact the EEOC at 800-669-4000 or visit EEOC online at 

https://publicportal.eeoc.gov/Portal/Login.aspx.

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE

This Notice must remain posted for two and one-half (2 1⁄2) years from the date below 

and must not be altered, defaced or covered by any other material. Any questions about this 

Notice or compliance with its terms may be directed to EEOC, PSG/MVP Workforce

Settlement, 230 South Dearborn Street, Suite 2920, Chicago, IL 60604.

____________ _____________________________

Date The Honorable John Z. Lee

United States District Court

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