IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

DOCKETED

UNITED STATES EQUAL EMPLOYMENT

) 02C 688 4

OPPORTUNITY COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

COMPLAINT

)
MTP ENTERPRISES, LTD., d/b/a/H &]~GISTRATE J~DSGCEHENKIE ~"R~

LIMOUSINE SERVICE, INC. Defendant.

)
) JURY TRL
)

)

NATURE OF THE ACTION

This is an action under the Age Discrimination in Employment Act to correct unlawful

employment practices on the basis of age and to provide appropriate relief to Wayne Nelson

("Nelson") and a class of employees over the age of 40, including, without limitation, Richard

Kuzynowski ("Kuzynowski"). The Equal Employment Opportunity Commission ("the

Commission" or "EEOC") alleges that since at least January 2001, MTP Enterprises, Ltd., d/b/a

H & M Limousine Service, Inc. discriminated against Nelson, Kuzynowski and a class of

employees over the age of 40, in terms and conditions of employment and by discharging them

because of their age.

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,

1343 and 1345. This action is authorized and instituted pursuant to Section 7Co) of the Age

Discrimination in Employment Act of 1967,.as amended, 29 U.S.C. § 6260a) (the "ADEA"),

which incorporates by reference Sections 16(e) and 17 of the Fair Labor Standards Act of 1938

(the "FLSA"), as amended, 29 U.S.C. §§ 216(c) and 217. 2. The employment practices alleged to be unlawful were and are now being
committed within the jurisdiction of the United States District Court for the Northem District of Illinois, Eastern Division.
PARTIES 3. Plaintiff, the EEOC, is the agency of the United States of America charged with the administration, interpretation and enforcement of the ADEA and is expressly authorized to bring this action by Section 7(b) of the ADEA, 29 U.S.C. § 626C0), as amended by Section 2 of Reorganization Plan No. 1 of 1’978, 92 Star. 378I, and by Public Law 98-532 (1984), 98 Stat. 2705. 4. At all relevant times, Defendant, MTP Enterprises Ltd., d/b/a H & M Limousine Service, Inc. (the "Employer"), has continuously been doing business in the State of Illinois, and has continuously had at least 20 employees. 5. At all relevant times, Defendant Employer has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 1 l(b), (g) and 0a) of the ADEA, 29 U.S.C. §§ 630(b), (g) and
CONCILIATION 6. Prior to institution of this lawsuit, the Commission’s representatives attempted to eliminate the unlawful employment practices alleged below and to effect voluntary compliance with the ADEA through informal methods of conciliation, conference and persuasion within the meaning of Section 7(b) of the ADEA, 29 U.S.C. § 626(b).
STATEMENT OF CLAIMS 7. Since at least J~tnuary 2001, the Defendant Employer has engaged in unlawful employment practices at its place of business, in East Dundee, IL, in violation of Section’4(a)(1)

of the ADEA, 29 U.S.C. § 623(a)(1). The practices include discriminating in terms and conditions of employment and wrongfully discharging Nelson, Kuzynowski and a class of employees over the age of 40 due to their age.
8. The effect of the practices complained of in paragraph 7 above has been to deprive Nelson, Kuzynowski and a class of employees over the age of 40 of equal employment opportunities and otherwise adversely affect their status as employees, because of their age.
9. The unlawful employment practices complained of in paragraph 7 above were and are willful within the meaning of Section 7Co) of the ADEA, 29 U.S.C. § 626(b).
PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant Employer, its officers, successors, assigns and all persons in active concert or participation with it, l~om discriminating on the basis of age against individuals 40 years or older. B. Order Defendant Employer to institute and carry out policies, practices and programs which provide equal employment opportunities for individuals 40 years of age and older, and which eradicate the effects of its past and present unlawful employment practices described in paragraph seven (7) above. C. Grant a judgment requiring Defendant Employer to pay appropriate back pay in an amount to be determined at trial, an equal sum as liquidated damages, and prejudgment interest to individuals whose wages are being unlawfully withheld as a result of the acts complained of above, including Nelson, Kuzynowski and a class of employees over age 40; D. Order Defendant Employer to make whole all individuals adversely affected by the unlawful practices described above, by providing the afftrmative relief necessary to eradicate the effects of its unlawful practices, including but not limited to reinstatement and/or front pay.

Grant such further relief as the Cottrt deems necessary and proper in the public interest¯
F. Award the Commission its costs of this action. ~IURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its Complaint.
Respectfully submitted,
NICHOLAS M. INZEO Acting Deputy General Counsel GWENDOLYN YOUNG REAMS Assistant General Counsel EQUAL~ OPPORTUNITY
~ 7l°nal’Rtt°~( /~ t~
Behh A. 1(,lil~6r - Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 (312) 353-7722

Ci~l Cove~Sheet
~~~/

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h~p ://www.ilnd .uscourts.gov/PUBLlC/Fomas/au to_j s44.¢fm

:"

" ~INITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS SEP 7 OOZ

Civil Cover Sheet

This automated JS-44 conforroz generally to the manual JS-44 approved by the Judicial Conference of the United States in

September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadingj~b~ ~~[~nired by

law. This form is authorized for use o~ in the Northern District of Illinois.

. ........

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
County Of Residence:

Defendant(s):MTP ENTERPRISES, LTD., d/b/a H & M LIMOUSINE SERVICE, INC.
County of Resideno~AGISTRATE JUDGE" ,~-’HE.z~EIE]

Plaintiffs Arty: Beth Miller

Defendant’s Arty:

Equal Employment Opportunity

Commission

500 W. Madison, Suite 2800,

Chicago, IL 60661

312-353-7722

Robert J. Morrow Early, Collison, Tousey, Regart, Wlodek & Morrow 2400 Big Timber Rd., Suite
201, Elgin, IL 60123

If. Basis of~Iurisdiction:

1. U.S. Gov’t Plaintiff

Citizenship of Principal Partiea (Diversity Cases Only)
Plaintiff:- N/A Defendant:- N/A

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

This is an action under the Age Discrimination Act to correct the

unlawful employment practices on the basis of age.

VII. Requested in Complaint

Class Action:

Dollar Demand:

Jury Demand: Yes

VIII..This c~a~reviously dismissed c~e.

I

-

Date:. qJZ~~
~ ~y of~is ~afion is ine~, ple~ go b~k m ~e Ci~l Cov~ She~ ~put fo~ ~ing ~e Back burn ~ ~w bmw~ ~ e~ it.

1 of 2

9/24/02 3:50 PM

In t.he Mattvr of

UNITED STATES DISTRICT COURI NORTHERN DISTRICT OF ILLINOIS
Eastern Division

SEP 2, 7 ZOOZ

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION,

Plaintiff,

V,
MTP ENTERPRISES, LTD., d/b/a H&M LIMOUSINE ¯

SERVICE, INC.

Defendant.

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATrORNEY(~) FOR:

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

MAGISTEATE JUDGE

,.---, ... ,

Beth Miller
Equal Employment Opportunity Conm~ission
STREET AD DR F~ S
500 W. Madison, Suite 2800 mago, Cc~TA’I’I~ZIP IL 60661

IDENTIFICATION NUMBER (SEE 1TEM 4 ON REVERSE)
ARDC No. 06203264

MF..b~F-R Of TRIAL BA.R?

YES

svaEL~--~a3vaEss
500 W. Madison, Suite 2800
C~cago, ~ 60661
TELEPHONBNUMBER
(312) 886-9124
IDENTIFICATION NUMgER (SEE r’IT_.M 4 ON REVER~E)
ARDC No. 06210804

L.,~..

DESIGNATED AS LOCAL COUNSEL?

(D)

Jo~(n C. per~rickson

~qqual F_tfnp~’o?Tnent Opportunity Commission ¯ ~

,~~ A9DD0~S ~ Ma~son, S~te 2800 go, IL 60661

~ET ~D~ CI1TISTATFJZIP ¯

TELEPHONE NUMBER
(312) 353-8551
IDENTIFICATION NqJMBER (SEE ITEM 4 ON REVfiRSE)
ARDC No. 01187589
M~MBER OF TPdAL BAR?

TELEPHONE NUMBER IDENTIFICATION NUMBER (SEE ITEM 4 ON RE’VERsE}
MEMB=OF . .,

YES

TRIAL A TTOP-J~’IEY ? DESIGNATED AS LOCAL COUNSEL?

DESIGNATED AS YLOESCANLOCDOUNS

 </s> MJl'Iute Order Form (06197)
(j'f

United States District Court, Northern District of Illinois

Name of Assigned Judge or Magistrate Judge

Suzanne B. Conlon

Sitting Judge if Other than Assigned Judge

CASE NUMBER

02 C 6884

DATE

3120/2003

CASE TITLE
MOTION:

EEOC vs. MTP ENTERPRISES
[In the followmg box (a) mdlcate the party fihng the motion, e,g" plamtlff, defendant, 3rd party plaintiff, and (b) state briefly the nature of the motion being presented.]

DOCKET ENTRY:

(I) o

Filed motion of [use listing in "Motion" box above.]

(2) o

Brief in support of motion due ___.

(3) o

Answer brief to motion due_ _ _. Reply to answer brief due_ _ _.

(4) o

RulinglHearing on _ _ _ set for _ _ _ at ___.

(5) o

Status hearing[held/continued to] [set forlre-set for] on _ _ _ set for _ _ _ at _ _ _.

(6) o

Pretrial conference[held/continued to] [set forlre-set for] on _ _ _ set for _ _ _ at _ _ _.

(7) o

Trial[set for/re-set for] on _ _ _ at _ _ _.

(8) o

[Bench/Jury trial] [Hearing] held/continued to _ _ _ at _ _ _.

(9) o

This case is dismissed [with/without] prejudice and without costs[by/agreementlpursuant to]
o FRCP4(m) 0 Local Rule 41.1 0 FRCP41(a)(I) 0 FRCP41(a)(2).

(10) • [Other docket entry] This action is dismissed pursuant to parties' consent decree. All pending dates are vacated. ENTER CONSENT DECREE.

•

[For further detail see order attached to the original minute order.]

No notices required, advised in open court.

No notices required,

Notices mailed by judge's staff. Notified counsel by telephone. Docketing to mail notices.

Mail AO 450 form. Copy to judge/magistrate judge.

Hi riO:) Lm' is] Cl "S" n \ ',J' ." ",

courtroom

CB

depuly's

initials

3124/2003
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mailing deputy initials

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES EQUAL EMPLOYMENT )

OPPORTUNITY COMMISSION,

)

)

Plaintiff,

)

)

~

)

)

)

MTP ENTERPRISES, LTD., d/b/a H & M

)

LIMOUSINE SERVICE, INC.

)

)

Defendant.

)

Civil Action No. 02 C 6884
Judge Conlon Magistrate Judge Schenkier

CONSENT DECREE THE LITIGATION 1. Plaintiff Equal Employment Opportunity Commission (the "EEOC") filed this action alleging that Defendant, MTP Enterprises, Ltd. (d/b/a H & M Limousine Service, Inc.) discriminated against Wayne Nelson because of his age. Defendant, MTP Enterprises, Ltd. has denied the allegations of unlawful discrimination, and entry of this Consent Decree shall not be deemed an admission of any unlawful conduct. 2. The parties hereto have jointly entered into this Consent Decree as part of the parties' agreement to resolve this litigation, and entry ofthis Decree shaH fully and finally resolve any and all issues and claims arising out of the Complaint.
FINDINGS 3. 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 ofthe subject matter of this action and of the parties.

)3

b. The terms of this Decree are adequate, fair, reasonable, equitable and just. The rights of the EEOC, Defendant, Wayne Nelson and the public interest are adequately protected by this Decree.
c. This Decree conforms with the Federal Rules of Civil Procedure and the Age Discrimination in Employment Act, 29 USC § 621, et seq. ("ADEA"), and is not in derogation of the rights or privileges of any person. The entry of this Decree will further the objectives of the ADEA and will be in the best interests of the parties, Wayne Nelson and the public.

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

NON-DISCRIMINATIONINON-RETALIATION 4. Defendant and its officers, agents, employees, successors, assigns and all persons acting in

concert with them shall not engage in any age discrimination made unlawful by the ADEA and shall

not engage in any form of unlawful retaliation against any person because such person has opposed

imy practice made unlawful under the ADEA, filed a Charge of Discrimination under the ADEA,

testified or participated in any investigation, proceeding or hearing under the ADEA, or asserted any

rights under this Decree.

POSTING OF NOTICE

5. Within ten (10) business days after entry of this Decree, Defendant shall post a copy of the

Notice attached as Exhibit B, on the bulletin board usually used for communicating with employees.

The notice shall remain posted for the term of this Decree. Defendant shall take all reasonable steps

to ensure that the posting is not altered, defaced or covered by any other material. Defendant shaIl

certifY to the EEOC in writing within fifteen (15) business days after entry of the Decree that the

Notice has been properly posted. Defendant shall permit a representative of the EEOC to enter its

premises to verify compliance with this Paragraph at any time during normal business hours.

2

RECORD KEEPING 6. For the duration of this Decree, Defendant shall maintain and make available for inspection and copying by the EEOC records (including names, social security numbers, addresses, telephone numbers, and age) of each employee who complains of age discrimination. Such reports shall indicate the date the complaint was made, who made it, what was alleged, and what actions the Defendant took to resolve the matter. Defendant shall make all such documents or records available for inspection and copying within ten (10) business days after the EEOC so requests.
MONETARY RELIEF 7. Defendant shaJlPay $11,000.00 to Wayne Nelson as backpay, less the employee's share of all lawful withholdings.
8. Within fifteen (15) business days after receipt of a signed Release Agreement, attached as Exhibit A, from Wayne Nelson, Defendant shall issue and mail to him a check in the amount set forth above. A copy of the check shall be mailed on the same date to the EEOC.
ADOPTION AND DISTRIBUTION OF EEO POLICY 9. Defendant shall adopt a policy against unlawful employment discrimination within 30 days after the entry of this Consent Decree. Within 30 days after the entry of this Consent Decree Defendant shall also post a copy of its Equal Employment Opportunity ("EEO") policy on the bulletin board customarily used for posting notices from management to employees.
TRAINING 10. Within 60 days of the entry of this Decree, managers and owners of Defendant shall participate in an EEO training session by a trainer paid for by Defendant and approved by the EEOC. Defendant shall obtain the EEOC's approval of its proposed trainer prior to the training session. Defendant shall submit the name, address, telephone number, background and training proposal of the proposed trainer to the EEOC at least ten (10) days prior to the proposed date of the training. The
3

EEOC shall have five (5) calendar days from the date of receipt of the information described above to reject the proposed trainer. If the parties cannot through this process agree on a trainer, then they may seek the Court's assistance under Paragraph 12. II. Defendant shall certify to the EEOC in writing within ten (10) business days after the training has occurred that the training has taken place and that the required personnel have attended. Such certification shall include: (i) the date, location and duration of the training; and (ii) a copy of the registry of attendance, which shall include the name and position of each person in attendance.
DISPUTE RESOLUTION 12. If any party to"f this Decree believes that another party has failed to comply with any provision(s) ofthe Decree, the complaining party shall notifY the other party in writing of the alleged non-compliance and shall afford the alleged non-complying party fifteen (15) business days 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 non-compliance or satisfied the complaining party that it has complied within fifteen (15) business days, the complaining party may apply to the Court for appropriate relief.
DURATION OF THE DECREE AND RETENTION OF JURISDICTION 13. All provisions of this Decree shall be in effect (and the Court will retain jurisdiction to enforce this Decree) for a period of 1 year immediately following entry of the Decree, provided, however, that if, at the end of the I year period, any disputes under Paragraph 12 above remain unresolved, the term of the Decree shall be automatically extended (and the Court will retain jurisdiction of this matter to enforce the Decree) until all such disputes have been resolved.
MISCELLANEOUS PROVISIONS 14. Each party to this Decree shall bear its own expenses, costs and attorneys' fees.
4

15. The tenns of this Decree are and shall be binding upon the present and future representatives, agents, directors, officers, assigns and successors of Defendant in their capacities as representatives, agents, directors and officers of Defendant, and not in their individual capacities. 16. When this Decree requires the submission by Defendant of reports, certifications, notices or other materials to the EEOC, they shaB be mailed to Attorney Gordon Waldron, Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800, Chicago, Illinois, 60661. When this Decree requires submission by the EEOC of materials to Defendant, they shall be mailed to Wessels & Pautsch, P.C., c/o Attorney Frank A. Gumina, 330 East Kilbourn Avenue, Suite 1475, Milwaukee, W153202.
ENTERED For the Equal Employment Opportunity Commission 1801 L Street, N.W. Washington, D.C. 20507 Nicholas M. Inzeo Acting General Counsel Gwendolyn Young Reams Associate General Counsel

~~C1\-/ JjQC~A.A.JQi-(r 0/ y W

Grego . Gochanour

r

Supervisory Trial Attorney

5

/~rrvL", Wo.2J,CN'-
Gordon Waldron Senior Trial Attorney
-:>. 'iC~ =~Jle/o'!:, For MTPEIlt~. By Frank A. Gumina, Esq. Wessels & Pautsch, P.C. 330 East Kilbourn Avenue, Suite 1475 Milwaukee, WI 53202 (414) 291-0600 ~~~£J,~ Iu e on n D"re-¥O~3
6

EXHIBIT A
WAIVER AND RELEASE AGREEMENT
I, Wayne Nelson, for and in consideration of the sum of $11,000.00, mmus the employee's share of all lawful withholdings, payable to me pursuant to the terms of the Consent Decree entered by the Court in EEOC et aL v. MTP Enterprises, Ltd., d/b/a H & M Limousine Service, Inc., (N.D. IlL), on behalf of myself, my heirs, assigns, executors and agents, do hereby forever release, waive, remise, acquit, and discharge MTP Enterprises, Ltd., d/b/a H & M
,r
Limousine Service, fnc., and all of its past and present shareholders, officers, agents, employees, and representatives, as well as all successors and assignees, from any and all claims and causes of action of any kind which I now have or ever have had under the Age Discrimination in Employment Act, 29 U.S.C. § 621, et seq., or for age discrimination under the Illinois Human Rights Act, as a result of or arising from the subject matter and claims which were or which could have been asserted in the above case. Nelson represents and certifies that he has carefully read and fully understands all of the provisions and effects of this Agreement, that Nelson is voluntarily entering into this Agreement, and that neither MTP Enterprises, Ltd. nor its attorneys made any representations concerning the terms or effects of this Agreement other than those contained herein. Nelson further acknowledges, represents and certifies as follows:
a. that this Agreement is written in a manner calculated to be understood by Nelson, and that in fact Nelson fully understands all the terms and effects of this Agreement;
b. this Agreement specifically refers to a waiver of rights and claims under the Age Discrimination in Employmcnt Act of 1967, as amended, 29 U.S.c. § 621 et seq.;
Page 1 of2

c. by executing this Agreement Nelson is not waiving rights or claims that may arise

after the date he signs this Agreement;

d. under this Agreement Nelson is waiving rights and/or claims for consideration in

addition to anything of value to which he already is entitled;

e. Nelson is advised to consult with an attorney of his choice, and at his own

expense, prior to executing this Agreement; and

f.

Nelson has been given a reasonable period of time within which to consider the

terms and effects of this Agreement.

Dated:---------------------

Wayne E. Nelson, individually

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PROTO, SCHENKIER, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:02-cv-06884

EEOC v. MTP Ent Ltd Assigned to: Hon. Suzanne B. Conlon Demand: $0 Cause: 28:451 Employment Discrimination Plaintiff Equal Employment Opportunity Commission
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Date Filed: 09/26/2002 Date Terminated: 03/20/2003 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Beth A. Miller Pontikes & Garcia 111 West Washington Street Suite 1221 Chicago, IL 60610 (312) 464-1440 TERMINATED: 12/18/2002 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gordon G. Waldron United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7525 Fax: (312)35 -8555 Email: gordon.waldron@eeoc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory M. Gochanour United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 886-9124 Email: gregory.gochanour@eeoc.gov ATTORNEY TO BE NOTICED
John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street
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V. Defendant MTP Enterprises, Ltd.

Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED
represented by Charles W. Pautsch Wessels & Pautsch, P.C. 330 East Kilbourn Avenue Suite 1475 Milwaukee, WI 53202 (414) 291-0600 Email: chpautsch@milw.w-p.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Bruce Frank Mills Wessels & Pautsch 330 East Kilbourn Avenue Suite 1475 Milwaukee, WI 53202 (414) 291-0600 Email: brmills@indy.w-p.com ATTORNEY TO BE NOTICED
Frank Anthony Gumina Whyte Hirschboeck Dudek S.C. 555 E. Wells Street Suite 1900 Milwaukee, WI 53202 (414) 978-5387 Email: fgumina@whdlaw.com ATTORNEY TO BE NOTICED

Date Filed 09/26/2002
10/04/2002

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of Beth A. Miller, Gregory M. Gochanour, John C. Hendrickson as attorney(s) for plaintiff (No summons(es) issued.) (Documents: 1-1 through 1-3) (hp) (Entered: 09/27/2002)
SCHEDULE set on 10/4/02 by Hon. Suzanne B. Conlon : Status hearing set on 10/22/02 at 9:00 AM. At the status hearing, the parties are to report on the following: 1. Possibility of settlement in the case; 2. If no possibility of

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10/22/2002 10/22/2002 10/22/2002
11/20/2002 11/20/2002 12/12/2002 12/18/2002
12/18/2002 02/06/2003 02/12/2003 02/19/2003
03/20/2003

settlement exists, the nature and length of discovery necessary to get the case ready for trial. Plaintiff is directed to advise all other parties of the court's action herein and to forward a copy of the court's procedure guidelines to defendant(s). Mailed notice (cgb) (Entered: 10/04/2002)
2 ATTORNEY APPEARANCE for defendant by Charles W. Pautsch, Frank Anthony Gumina, Bruce Frank Mills (Attachment) (eav) (Entered: 10/23/2002)
3 WAIVER of service of summons as to defendant MTP Ent Ltd sent on 10/21/02 (eav) (Entered: 10/23/2002)
4 MINUTE ORDER of 10/22/02 by Hon. Suzanne B. Conlon : Status hearing held. Parties to comply with FRCP 26(a)(1) by 11/26/02. Plaintiff's compliance with FRCP 26(a)(2) by 2/21/03. Defendant's compliance with FRCP 26(a)(2) by 3/21/03. Discovery cut-off and filing of dispositive motions with supporting memoranda set on 4/22/03. Joint final pretrial order with agreed pattern jury instructions submission set on 5/13/03 at 9:00 a.m. ; plaintiff's draft to be submitted to defendant by 5/6/03. Case is placed on the May 2003 trial calendar. Firm dates. Mailed notice by judge's staff (eav) (Entered: 10/23/2002)
5 NOTIFICATION by defendant MTP Ent Ltd of affiliates disclosure statement (eav) (Entered: 11/21/2002)
6 ANSWER by defendant MTP Ent Ltd and defenses to complaint [1-1] (eav) (Entered: 11/21/2002)
7 MOTION by plaintiff EEOC for substitution of counsel of Gordon G. Waldron for Beth Miller ; Notice of motion (eav) (Entered: 12/18/2002)
8 MINUTE ORDER of 12/18/02 by Hon. Suzanne B. Conlon : Plaintiff's motion for substitution of counsel is granted. [7-1] Counsel Gordon Waldron is granted leave to substitute for Beth Miller as counsel for plaintiff. Mailed notice (eav) (Entered: 12/18/2002)
9 ATTORNEY APPEARANCE for plaintiff EEOC by Gordon G. Waldron (eav) (Entered: 12/18/2002)
10 STIPULATION; Notice of filing (eav) (Entered: 02/07/2003)
11 MOTION by plaintiff for entry of attached protective order (Attachment); Notice of motion (eav) (Entered: 02/19/2003)
12 MINUTE ORDER of 2/19/03 by Hon. Suzanne B. Conlon : Plaintiff's motion for entry of attached protective order is granted. [11-1] Entered Agreed Protective Order and Stipulation Governing Confidentiality of Tax Returns Mailed notice by judge's staff (eav) (Entered: 02/19/2003)
13 MINUTE ORDER of 3/20/03 by Hon. Suzanne B. Conlon : This action is dismissed pursuant to parties' consent decree. All pending dates are vacated. (Entered Consent Decree) terminating case Mailed notice by judge's staff (eav) (Entered: 03/25/2003)

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[CONTENT] The Chicago District Office | EEOC | the U.S. District Court | the Northern District | Illinois | MTP Enterprises, Ltd. ||| September 2002 | the Age Discrimination | Defendant ||| March 2003 ||| 1 year | Defendant | 11,000 | EEOC [SUMMARY] The Chicago District Office of the EEOC brought this action in the U.S. District Court for the Northern District of Illinois, against MTP Enterprises, Ltd. d/b/a H & M Limousine Service.  The complaint, filed in September 2002, alleged age discrimination in violation of the Age Discrimination in Employment Act; specifically that the Defendant had discriminated against the charging parties in the terms and conditions of their employment and by discharging them based on their age. 

A consent decree was entered in March 2003.  The decree, valid for 1 year, required the Defendant to pay of the charging parties $11,000, to post a notice of non-discrimination on its premises, to provide its managers and owners with EEO training, and to maintain and make available for EEOC inspection, records of each employee who complains of age discrimination.

