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

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,

CIVIL ACTION NO.

MOTOROLA, INC. Defendant.

MAGTIs~’~~ -~.,. , .... COMPLAINT
JURY TRIAL DEMAND

NATURE OF THEACTION

SEP ~ 8 2001

This is an action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §

2000e et sech. ("Title VII"), and Title I of the Civil Rights Act of 1991, 42 U.S.C. § 1981a, to

correct unlawful employment practices on the basis of religion to provide appropriate relief to

Syed Farooq and Hadam Soliman. The Commission alleges that Defendant discriminated

against Syed Farooq and Hadam Soliman on the basis of their religion by terminating their

employment.

JURISDICTION AND VENUE

1. This action is brought by the United States Equal Employment Opportunity

Commission to enforce the provisions of Title VII of the Civil Rights Act of 1964, as amended,

42 U.S.C. § 2000e et seq.

2. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of Title

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

3. This court has jurisdiction of this action pursuant to 28 U.S.C. § 451, 28 U.S.C. §

1331, 28 U.S.C. § 1337, 28 U.S.C. § 1343, 28 IJ.S.C. § 1345, and 42 U.S.C. § 2000e-5(f)(3). 4. The unlawful acts alleged below were and are now being committed within the
jurisdiction of the United States District Court for the Northern District of Illinois. PARTIES
5. Plaintiff, Equal Employment Opportunity Commission (the "Commission" or the "EEOC"), is an agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by § 706(t)(1) and (3), 42 U.S.C. § 2000e-5(f)(1) and (3).
6. At all relevant times, Defendant Motorola, Inc. ("Motorola") has continuously been a corporation doing business in the State of Illinois, County of Cook.
7. At all relevant times, Defendant Motorola has continuously had at least fifteen (15) employees.
8. At all relevant times, Defendant Motorola has continuously been an employer engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e(b), (g) and (h).
STATEMENT OF CLAIMS 9. More than thirty (30) days prior to the institution of this lawsuit, Syed Farooq and Hadam Soliman filed charges of discrimination with the Commission alleging violations of Title VII by Defendant (Charge numbers 210A04678 and 2IOA04674). 10. Pursuant to 42 U.S.C. § 2000e-5(f)(1), EEOC’s representatives attempted to eliminate the unlawful employment practices alleged below and to effect voluntary compliance with Title VII prior to institution of this lawsuit but EEOC was unable to secure a conciliation

agreement acceptable to the Commission. 11. All conditions precedent to the institutior~ of this lawsuit have been fulfilled. 12. From at least May 2000 until the present, Defendant has engaged in unlawful
employment practices at Motorola in Schaumburg, Illinois in continuing violation of Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a). These unlawful employment practices include, but are not limited to engaging in intentional discrimination against both Farooq and Soliman by failing to accommodate their religious observance requests and terminating their employment in violation of Title VII.
13. The result of the practices complained of above has been to deprive Syed Farooq and Hadam Soliman of equal employment opportunities and otherwise adversely affect their status as employees because of their religion.
14. The unlawful employment practices complained of above were and are intentional. 15. The unlawful employment practices complained of in paragraph 12 were done with malice or with reckless indifference to the federally protected rights of Syed Farooq and Hadam Soliman.
PRAYER FOR RELIEF WHEREFORE, the Commission requests that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with them, from engaging in any employment practices which discriminate on the basis of religion; B. Order Defendant to institute and carry out policies, practices and programs which provide equal employment opportunities for its employees regardless of religion, and which

eradicate the effects of its unlawful employment practices; C. Order Defendant to make whole Syed Farooq and Hadam Soliman adversely affected
by the unlawful practices alleged above by providing appropriate back pay with pre-judgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of the unlawful employment practices;
D. Order Defendant to make whole Syed Farooq and Hadam Soliman by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 12, above, in amounts to be determined at trial;
E. Order Defendant to make whole Syed Farooq and Hadam Soliman by providing compensation for past and future non-pecuniary losses resulting from the unlawful practices complained of in paragraph 12, above, including emotional pain, humiliation, and inconvenience in amounts to be determined at trial;
E. Order Defendant to pay punitive damages for its malicious and reckless conduct described in paragraph 12 above, in amounts to be determined at trial;
Grant such further relief as this Court deems necessary and proper in the public interest; and
G. Award the Commission its costs in this action.
4

JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by the Complaint.
Respectfully submitted, Nicholas M. Inzeo Acting Deputy General Counsel Gwendolyn Young Reams Associate General Counsel Equal E~loyment Opportunit)
" ’n
¯ oelle Brennan Supervisory Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Chicago District Office 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-7303

Civii Cover Sheet

http://www.ilnd.uscourts.gov/PUBL IC/Forms/auto_js44.cf

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS
Civil Cover Sheet

SEP 2, 8 20.0

This automated JS-44 conforms 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 pleadings or other papers as required by law. This form is authorized for use ~ in the Northern Distriot of Illinois.

Plaintiff(s): EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Defendant(s):MOTOROLA, INC.

County of Residence:

County of Residence:

Plaintiffs Arty: Noelle C. Brennan

Defendant’s Atty:

Equal Employment Opporunity

Commission

500 W. Madison, Suite 2600

Chicago, IL 60661

312-353-7303

Anne E. Duprey Seyfarth Shaw 55 East Monroe, Suite 4200 Chicago, IL 60603-5803
312-269-8829

II. Basis of Jurisdiction: 1. U.S. Gov’t Plaintiff

III. Citizenship of Principle Parties (Diversity Cases Only)
Plaintiff:- N/A Defendant:- N/A

JUDGE MANNING
I~AGI"~TtZ&TE JUDGE ASHMAN’

IV. Origin’

1. Original Proceeding

V. Nature of Suit:

442 Employment

VI.Cause of Action:

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, to correct unlawful employment practices

on the basis of religion.

VII. Requested in Complaint

Class Action:

Dollar Demand:

Jury Demand: Yes

VIII. This case IS NOT a refiling of a previously dismissed case.

Signature:~~--~_

Date: _~

If any of this information is incorrect, please go back to the Civil Cover Sheet Input form using the Back button in your browser and

change it. O~¢e correct, print this form, slgn and date it and submit it with your t~ew civil action. Note: You may need to adjust

the font size in your browser display to make the form print properly.

Revised: 06/28/00

of 1

~ ~e Ma~er of

UNITED STATES DISTRICT COURT
ms mc LU OIS
Eastern Division

SE.P ~ 8 2001

~PE~CES ~ ~EBY F~ED BY THE ~ERSIG~D AS ATTO~Y(S) FOR: ’

Noelle C. Brennan
FIRM
Equal EmpIoyment Opportunity Commissi
STREET ADDRESS
5,00 W. Madison~ Suite 2800
mcago, IL 60661
T~LEPI.{ONE NUMRER
(312) 353-7303
ID~’NTIFmATION NUMBER (SEE l~ ~ O~ e~W~S~)
A~C No. 06228901
M~MBER OF TRIAL BAR?
TRIAL ATTORNEY?

sir)NATuRE

(c)
="

NAME FIRM

s’fREET ADDRESS CITY/STAT ,~Z]P

TELEPHONE NUMBER

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

MEMBEROFTRIALBAR? TRIAL ATfORNEY?

YES ~] YES

NO =~ NO

///I AJAoMhIE(~W./~l/&d//~Ilrickson //v; ’X/

FlRi~:.,,,ill "~

’’

E~I Employment Oppo~unit~ Commission

STR~ ADDR~S

~

.~0 W. Madis~n~ Suite 2890 , .

CITYtSTATE/Z[P
Chicago, IL 60661

TELEPHON~NUMBE~ =’
(3.12) 35,3-855i

IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE}
ARDC No. 01187589

MEMBER OF TRIAL BAR?

YES [~

TRIAL ATTORNEY?

SIGNATURE

(D)

~"

: :

FIRM ......
....
STRE~ADDR~S
CI~/STAT~ZIP
TELEPHONE NUMBER
IDENTIFICATION NUMBER (SEE ITEM 4 ON REVERSE)

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MEMBER OF TRIAL BAR?

YES

NO

DESIONATED AS LOCAL COUNSEL?

 </s> CM/ECF LIVE, Ver 3.0 - U.S. District Court, Northern Illinois - Docket... https://ecf.ilnd.uscourts.gov/cgi-bin/DktRpt.pl?505791597248408-L_35...
ASHMAN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-07507

EEOC v. Motorola Inc Assigned to: Hon. Blanche M. Manning Demand: $0 Cause: 42:1981 Civil Rights Plaintiff Equal Employment Opportunity Commission
V. Defendant

Date Filed: 09/28/2001 Date Terminated: 12/28/2001 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by Noelle Christine Brennan Brennan & Monte, Ltd. 20 South Clark Street Suite 1530 Chicago, IL 60603 (312) 422-0001 Email: nbrennan@brennan-monte.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ann M Henry Equal Employment Opportunity Commission 500 W. Madison Street 2800 Chicago, IL 60661 (312)353-8558 Email: ann.henry@eeoc.gov ATTORNEY TO BE NOTICED
John C. Hendrickson United States Equal Employment Opportunity Commission 500 West Madison Street Suite 2800 Chicago, IL 60661 (312) 353-8551 Fax: (312) 353-8555 Email: john.hendrickson@eeoc.gov ATTORNEY TO BE NOTICED

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Motorola, Inc.

represented by Michael A. Warner Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 346-8000 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Anne Elizabeth Duprey Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312)460-5000 Email: aduprey@seyfarth.com ATTORNEY TO BE NOTICED
Susan F. Gallagher Seyfarth Shaw LLP 131 South Dearborn Street Suite 2400 Chicago, IL 60603-4205 (312) 346-8000

Date Filed 09/28/2001 10/17/2001 10/17/2001 10/31/2001
11/07/2001 11/21/2001

#

Docket Text

1 COMPLAINT; Jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Noelle Christine Brennan as attorney(s) for plaintiff (No summons(es) issued.) (Documents: 1-1 through 1-3) (cem) (Entered: 09/28/2001)
2 ATTORNEY APPEARANCE for defendant by Michael A. Warner, Susan F. Gallagher, Anne Elizabeth Duprey; Notice (rmm) (Entered: 10/18/2001)
3 WAIVER of service of summons as to defendant Motorola Inc sent on 9/28/01 (rmm) (Entered: 10/18/2001)
4 REFERRAL ORDER of 10/31/01 The case is referred to the Hon. Martin C. Ashman from the Hon. Blanche M. Manning pursuant to Local Rule 72.1 to conduct hearings and enter appropriate orders on the following pretrial motion/matter: Discovery supervision. Settlement conference. Perform such additional duties as are not inconsistent with the Constitution and laws of the United States. Exceptions or additions: All nondispositive pretrial motions. (For further detail see order.) Mailed notice (rmm) (Entered: 11/02/2001)
SCHEDULE set on 11/7/01 by Hon. Martin C. Ashman : Status hearing set to 10:00 11/21/01 in courtroom 1386. Mailed notice (is) (Entered: 11/07/2001)
SCHEDULE set on 11/21/01 by Hon. Martin C. Ashman : Status hearing held. Written discovery closed by 3/15/02. Oral discovery ordered closed on 4/19/02.

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12/18/2001
12/28/2001 01/07/2002 01/07/2002 01/10/2002

Dispositive motions are due 5/17/02. Settlement conference set for 2:00 12/18/01 in chambers 1366. Time to response to the complaint is extended to 1/2/02. All clients and parties with full authority to settle are to be physically present. Failure to have parties with full authority to settle present may result in the imposition of severe sanctions. (For further details see standing order distributed in open court.) Mailed notice (is) (Entered: 11/21/2001)
5 MINUTE ORDER of 12/18/01 by Hon. Martin C. Ashman : The court having been notified that this case has settled, the settlement conference is stricken. All matters relating to the referral of this action having been resolved, the case is returned to the assigned judge. Terminating the case referral to Hon. Martin C. Ashman Telephoned notice (rmm) (Entered: 12/19/2001)
6 MINUTE ORDER of 12/28/01 by Hon. Blanche M. Manning : Pursuant to minute order of 12/18/01, parties have informed the court that this case has settled. This case is hereby dismissed. Parties to submit a stipulation to this court by 01/25/02. terminating case Mailed notice (jmp) (Entered: 01/02/2002)
7 ATTORNEY APPEARANCE for plaintiff by Ann M Henry (rmm) (Entered: 01/08/2002)
8 AGREED MOTION by plaintiff and defendant for entry of consent decree (Attachments); Notices (rmm) Modified on 01/14/2002 (Entered: 01/14/2002)
9 MINUTE ORDER of 1/10/02 by Hon. Blanche M. Manning : Agreed motion for entry of consent decree is granted [8-1]. (Entered consent decree in favor of plaintiff and against defendant (Attachment)). Mailed notice (rmm) (Entered: 01/14/2002)

PACER Service Center

Transaction Receipt

07/23/2007 15:03:04

PACER Login: hs0328

Client Code: clearinghouse

Description: Docket Report Search Criteria: 1:01-cv-07507

Billable Pages: 2

Cost:

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 </s> IN THE UNITED STA'fEi:fbISTRlCT COURT FOR THE NORTHERNDISTRlCT OF ILLINOIS
EASTERN DIVISION

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,

MOTOROLA, INC.,

Defendant.

) ) ) ) ) ) No. 01C 7507 ) ) Judge Manning ) Magistrate Judge Ashman )

CONSENT DECREE THE LITIGATION 1. PlaintiffEqual Employment Opport,unityCommission (the "EEOC") filed this action alleging that beginning in or around May 2000, Defendant, Motorola, Inc. ("Defendant" or "Motorola"), violated Title VII of the Civil Rights Act of 1964,42 U.S.C. § 2000e et. seq., ("Title VII") by discriminating against Charging Parties Syed Farooq and Hadam Soliman ("Charging Parties") on the basis of their religion. Specifically, the EEOC alleged that Defendant, at its Personal Communications Sector Call Center located at 1500 W. Dundee Rd., Suite 200, Arlington Heights, Illinois 60004 (the "Call Center"), violated Title VII by failing to accommodate Charging Parties' request to attend religious services ancrt,y terminating Charging Parties for attending religious services. Motorola denies the allegations ofthe Complaint and denies that it discriminated against Charging Parties in any way. 2. In the interest of resolving this matter, and as a result of having engaged in comprehensive settlement negotiations, the parties have agreed that this action should be finally

1

resolved by entry ofthis Consent Decree (hereafter,~~ecree"), This Decree fully and finally resolves
."'~~-<
any and all issues and claims arising out of the Complaint filed by the EEOC in this action,
FINDINGS 3, Having carefully examined the terms and provisions ofthis 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 this action and of the

b,

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

The rights of Charging Parties and the public interest are adequately protected by this Decree,

c, This Decree is not an adjudication of or a finding on the merits or an

admission of liability by Motorola,

d, This Decree conforms witbJheFederal Rules ofCivil 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.lhe..best interests of Charging Parties, Motorola,

EEOC and the public.

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

NON-DISCRIMINATION 4. Motorola, its officers, agents (including management personnel), successors, and

assigns, are required under Title VII to reasonably_accommodate employees who request to attend

religious services.

NON-RETALIATION 5. Motorola, its officers, agents, employees, successors, and assigns, shall not engage

in any form of retaliation against any person be.cause such person has opposed any practice made

2

unlawful under Title VII, filed a Charge ofDiscriInmation under Title VII, testified or participated in any manner in any investigation, proceeding,oihearing under Title VII, or asserted any rights under this Decree.
MONETARY RELIEF FOR CHARGING PARTIES
6. Charging Parties, who are represented by their own private counsel, have negotiated separate Waiver and Release Agreements ("Relefls.eAgreements") with Defendant. The EEOC has not counseled or advised Charging Parties regarding these Release Agreements. Within five (5) business days after entry of this Decree, the EEQC will cause Charging Parties' counsel, Kamran
Memon ("Memon"), to mail to Charging Parties a copy of the appropriate Release Agreement.
Charging Parties will then return their respective, signed Release Agreements to Memon, together with a completed IRS Form W-4 and IRS FormSY:-9 for each Charging Party.
7. Within five (5) business days after receipt by Memon of the signed Release Agreements and IRS Forms, Memon shall maiLihe Release Agreements and IRS Forms to Susan Gallagher, Seyfarth Shaw, 55 East Monroe Street;·Suite 4200, Chicago, IL 60603.
8. Within ten (1 0) business days aftei:r-eceipt ofthe appropriate Release Agreement and the IRS Forms, Defendant will tender to Syed Earooq a check in the amount of fifteen thousand dollars ($15,000.00) less applicable state and federal taxes and to Syed Farooq and Kamran Memon a check in the amount of fifteen thousand dollars·($15,000.00) (to be reported as taxable damages on IRS Form 1099) in settlement for damages claimed in this case. Within ten (10) business days after receipt of the appropriate Release Agreeme.nLand the IRS Forms, Defendant will tender to Hadam Soliman a check in the amount of fifteenthousand dollars ($15,000) less applicable state and federal taxes and to Hadam Soliman and Karnran Memon a check in the amount of fifteen thousand dollars ($15,000) (to be reported as taxable damages on IRS Form 1099) in settlement for
3

damages claimed in this case. All checks shall be diflvered to Kamran Memon, 200 South Michigan Avenue, Suite 1240, Chicago, Illinois 60604. HOYlCever, the entry of this Consent Decree by the Court is a condition precedent to any of Motorola' s obligations set forth in the Release Agreements.
POSTING Oi?NOTICE 9. Within five (5) business days after entry of this Decree, Motorola shall post a samesized copy of the Notice attached as Exhibit A to this Decree at the Call Center, in a conspicuous location easily accessible to and commonly frequented by employees ofMotorola. The Notice shall remain posted for one (1) year from the date oLentry of this Decree. Motorola shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other material. Motorola shall certify to the EEOC in writing withinJen (10) business days after entry ofthe Decree that the Notice has been properly posted.
RECORD KEEPING 10. For a period of one (1) year following entry of this Decree, Motorola shall maintain and make available for inspection and copying ~i.the EEOC records (including name, age, social security number, address, telephone number, complaint and resolution of the complaint) of each person at the Call Center complaining of discrimination on the basis of religion. 11. Motorola shall make all document:S:.Qr records referred to in Paragraph 10, above, available for inspection and copying within twenty-one (21) business days after the EEOC so requests. 12. Nothing contained in this Decreeshiill be construed to limit any obligation Motorola
vn may otherwise have to maintain records under fEle or any other law or regulation.
4

REPORTING 13. Motorola shall furnish to the EEOC. the following written reports for a period of one (1) year following entry ofthis Decree. The firstrep-ort shall be due six (6) months after entry of the Decree. The final report shall be due twelve (12) months after entry ofthe Decree. Each such report shall contain:
a. A description ofeach complaint ofreligious discrimination and the resolution of such complaint, occurring within the six (6) month period preceding the report;
b. A certification by Motoroliifuat the Notice required to be posted in Paragraph 9, above, remained posted during the entire six (6)month period preceding the report.
TRAINING 14. Motorola shall provide training to all management personnel in the Call Center on equal employment opportnnity law (including religious accommodation) by March 1,2002. Within ten (1 0) calendar days ofthe completion ofthe traiping, Motorola shall notify the EEOC ofthe dates the training was conducted, the name and job title of the person(s) who conducted the training, and the name and job title of each person who recebi;ed the training. Motorola shall have the option either to utilize its own employees to conduct this. training or to utilize outside consultants.
DISPUTE RESOLUTION 15. In the event that either party to thisJ)ecree believes that the other party has failed to comply with any provision(s) ofthe Decree, the cQmplaining party shall notify the other party ofthe alleged non-compliance and shall afford the alleged non-complying party ten (10) business days to
C,,",._.
remedy the non-compliance or to satisfy the compl~ining party that the alleged non-complying party has complied. If the alleged non-complying party has not remedied the alleged non-compliance or
5

satisfied the complaining party that it has complieifwithin ten (10) business days, the complaining party may apply to the Court for appropriate relieL
',,:l~";;\,
DURATION OF THE DECREE AND RETENTION OF JURISDICTION 16. All provisions of this Decree shalL,'b''_'~e~'."i'n' effect (and the Court will retain jurisdiction ofthis matter to enforce this Decree) for a period o£:one (1) year immediately following entry of the Decree, provided, however, that if, at the end of the one (1) year period, any disputes under Paragraph 15, above, remain unresolved, the CotiJiwil! retain jurisdiction ofthis matter to enforce the Decree until such time as all such disputes haye_been resolved.
MISCELLANEOUS PROVISIONS 17. Each party to this Decree shall bear,its own expenses, costs and attorneys' fees. 18. The terms of this Decree are and .shall be binding upon the present and future representatives, agents, directors, officers, assigns, and successors ofMotorola, Charging Parties and the EEOC.
6

19. When this Decree requires the submission by Motorola of reports, certifications, notices, or other materials to the EEOC, they sh;;rrbe mailed to: Motorola Settlement, c/o Ann Henry, Trial Attorney, Equal Employment opportUriityCommission, 500 West Madison Street, Suite 2800, Chicago, Illinois 60661. When this Decre-e reqUires submission by the EEOC of materials to Motorola, they shall bemailedto:SusanGallagIi.e;:~·SeyfarthShaw.55EastMonroeStreet.Snite 4200, Chicago, IL 60603.

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 500 West Madison Street Suite 2800~L-'_~~

MOTOROLA, INC.
..Susan GalIagher Seyfarth Shaw 55 East Monroe Street Suite 4200
inois 60603

Noelle Brennan Supervisory Trial Attorney

4e<AG a~ JI]
Ann Henry

d

Trial Attorney

/7 DATE: I JD~ I I

FNfFJ{~ '>.{.~
The Honorable Blanche Manmng United States District Court Judge

12

.-

CERTIFICATE~OF SERVICE
I, Ann Henry, an attorney, certify that on1anuary 7, 2002, I caused a copy of the foregoing
Agreed Motion for Entry of Consent Decree to be served via facsimile transmission and first class
mail, postage pre-paid to the following counsel offecord:

To: Susan Gallagher Seyfarth Shaw 55 East Monroe Street Suite 4200 Chicago, Illinois 60603

=" {L Ann Henry-,i/o

Cont rmat i on Report - Memory Send

Page

001

Datel.Jlme: Jan-07-02 12 :02

Line 1

312 886 5391

Line. 2.

MachLne I D LEGAL

Job number

277

Date

Jan-07 12:01

To

892698869

Number of pages

011

Start time

Jan-07 12:01

End time

Jan-07 12:02

Pages sent

Status

Job number

277

011
OK
*** SEND SUCCESSFUL ***

:FACSIN.lILE TRANSMXTTAL COVER. PAGE

J1'ROlY.[ THE EEOC CHICAGO DXSTRXCT OJ1'FXCE LEGAL DXVISION

Da.te:

.T&;nUa.J:y' 7 ~ 2002

Please delivor 'the folloVV'i:c.g pa.gc:(s) 'to:

Susan Gallagb.c:r,__ Phone NUl:r.lbcr (31.2.) 269-8519

F.A.X Nuxnbor:

(312)269-8869

Frcu::c.:

AnnH=y Trial Atto=ey
Phona Nu;r:nber: (312) 3$3-85S8

Ro:

EEOC; V MpIQTp\&" Ing 01.C 7507

Total Nlltt1.bcr of Pages: _-,1";1L._ (in.cludin.g transr.o.ittal. cover page)

Co:rnrnen.t.s:
IF THIS FAX. TR..ANS~SSION IS DIR.ECT:6ff.fo lv.lORE THAN ONE AD:DRESSER~ PLE.A.SE
C o p y .A:ND :r:>ISTRXBU"1."E TO .ALL A.DD;R.ES:~EES.
CONFIDEN~XTY NOTICE

This con::u::c.unlcation is j;nT:ended for t:hC:31-2l~t~e oft:he pe.rson(s) to vvho}.-o. it is addressed and :s::nay con.1;ain. inf"o:n::nation 1:ha:c is privilcs,cd. confiden.tial an.d exempt fro..-n disclosure•
. ~\t::O~'; Any d.1sse:rni:nation~ dist:ribution or copying ot:1:bis COrrttnuniCa.tiOl"\ by anyone other tban l:l"l.e inte:t:Lded recipient or me person. :resPQn,s,iple for i'ts delivery is stti.c1:ly prohibi'tec;l.
'~"''''"'
I£yQU have received t:his co:rnxn.U"Oica'tio,::r::1':':i;I::1,IIlIQ:X"Qr. please contact tb.is office inun.edia1:ely and eimer destroy 'the cOD:lXn.u:nicati01'1 or re~,it to 'the above address.


[CONTENT] September 2001 | the Chicago Office of the EEOC | Motorola Inc. | District Court | the Northern District | Illinois | Title VII of the Civil Rights Act | 1964 |||  ||| January 2002 ||| one-year | EEOC | 30,000 | two | 30,000 [SUMMARY] In September 2001, the Chicago Office of the EEOC filed this lawsuit against Motorola Inc. in the U.S. District Court for the Northern District of Illinois alleging discrimination on the basis of religion in violation of Title VII of the Civil Rights Act of 1964.  Specifically, the complaint alleged that the defendant failed to accommodate the religious observance requests of the complaining parties and terminated their employment.  Following some discovery, the parties settled the lawsuit through a consent decree in January 2002.

The one-year consent decree, containing anti-discrimination and retaliation clauses, required the defendant to: report complaints and make other compliance reports, keep records of compliance and make them available to the EEOC for inspection, post notice of employee rights, provide EEO training, and pay $30,000 to be distributed among two complaining parties and $30,000 to their attorney.

