Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 1 of 8

i:lfl1 IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS ,,<I hi, [<

EASTERN DIVISION

tiM 9 --rom

EQUAL EMPLOYMENT OPPORTUNITY )

COMMISSION,

)

)

Plaintiff,

)

)

v.

)

)

MAJESTY MAINTENANCE, INC.,

)

)

)

Defendant.

)

CIVIL ACTION NO.
Ole 16£41
JURY TRIAL DEMAND

M)\,GISTRATE JUDGE NOLAN"
------------------------~)

NATURE OF THE ACTION

r:=~ cO

\~~t

I

_.,,) DC:

This is an action under Title VII of the Civil Rights Act of 1964, as ameMed,~

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 sex and to

provide appropriate relief to Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and

Barbara Poltorak, employees of Majesty Maintenance, Inc. ("Majesty") and to a class of

female employees of Majesty who were adversely affected by such practices. Plaintiff,

the U.S. Equal Employment Opportunity Commission (the "Commission"), contends

Defendant, Majesty Maintenance Inc., has engaged in a pattern and practice of

discrimination against Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and

Barbara Poltorak, and class of other female employees because of their sex, by subjecting

them to a hostile and abusive work environment and by failing to take prompt remedial

1

I-I

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 2 of 8
action intended to eliminate the harassment after the Defendant became aware of such behavior, in violation of Title VII.
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 706(f)(1) and (3) and Section 707 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.c. § 2000e-5(f)(1) and (3) and -6, and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. §1981a. 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 Northern District of Illinois, Eastern Division.
PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission, is the 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 Section 706(f)(1) and (3) ofTitle VII, 42 U.S.c. § 2000e-5(f)(1) and (3). 4. At all relevant times, Defendant has continuously been and is now doing business in the State of Illinois and has continuously had at least fifteen (15) employees. 5. At all relevant times, Defendant has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) ofTitle VII, 42 U.S.C. § 2000e-(b), (g) and (h).
2

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 3 of 8
STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak filed charges with the Commission alleging violations of Title VII by Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least 1994, Defendant has engaged in a pattern and practice of unlawful employment practices in violation of Section 703(a)(1) and Section 707 of Title VII, 42 U.S.C. § 2000e-2(a)(1) and -6. These practices include, but are not limited to, engaging in intentional discrimination against Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, and a class of female employees by subjecting them to sexual and sex-based harassment and failing to take prompt remedial action intended to eliminate the harassment after the Defendant became aware of the illegal behavior, all in continuing violation of Section 703(a) and Section 707 of Title VII, 42 U.S.C. § 2000e2(a) and -6. 8. The effect of the practices complained of in paragraph seven above has been to deprive Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, and a class of female employees of equal employment opportunities and otherwise adversely affect their status as an employee because of their sex. 9. The unlawful employment practices complained of in paragraph seven above were and are intentional. 10. The unlawful employment practices complained of in paragraph seven
3

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 4 of 8
above were and are done with malice or with reckless indifference to the federally protected rights of Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak and a class of female employees.
PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, Majesty Maintenance, Inc., its officers, successors, assigns, and all persons in active concert or participation with it, from engaging in any employment practice which discriminates on the basis of sex; B. Order Defendant to institute and carry out policies, practices, and programs which provide equal employment opportunities for women, and which eradicate the effects of its past and present unlawful employment practices; C. Order Defendant to make whole Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, and a class of female employees by providing compensation for pecuniary losses resulting from the unlawful employment practices described above; D. Order Defendant to make whole Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, and a class of female employees by providing compensation for past and future non-pecuniary losses, including emotional pain, suffering, inconvenience, loss of enjoyment oflife and humiliation;
4

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 5 of 8
E. Order Defendant to pay Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, and a class offemale employees punitive damages for its malicious and/or reckless conduct described, in amounts to be determined at trial;
F. Order Defendant and its successors to provide training to its officers, managers and employees regarding sexual harassment in the workplace;
G. Grant such further relief as the Court deems necessary and proper in the public interest; and
H. Award the Commission its costs in this action. JURY TRIAL DEMAND
The Commission requests a jury trial on all questions of fact raised by its Complaint.
5

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 6 of 8

Respectfully submitted,

GWENDOLYN YOUNG REAMS Associate General Counsel

EQUAL EMPLOYMENT OPPORTUNITY

COMMISSION

1801 " . _.street; N.W.

~1I>gr'

507

Gordon Waldron Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION 500 West Madison Street, Suite 2800 Chicago, Illinois 60661 (312) 353-7525
6

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 7 of 8
:~S::!:i:':~::~:R~:~!U£-~_~~

by law, except .. provided by local lUes of court This form, approved by1he Judicial Conference ofthelJnltsd States In September 1974, Is required for the use of 1he CIeri< of Court for 1he purpose of Inlllo1lng 1he civil dooket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

LINDBERG 1.(8) PLAINTIFFS

DEFENDANTS

V•S. Equal Einployrnent Opportunity Cannission Majesty Maintenance ,InC]E,

MAGISTRATE JUDGE NO~

(b) COUNTY OF RESIOENCE OF ARST USTEO PlAINTIFF
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) A1TOfINEYS (ARM NAME, ADDRESS, AND TElEPHONE NUMBER)
Gordon Waldron (312) 353-7525 Equal Einployment Opportunity Cannission 500 W. Madison St., Suite 2800 Chicago, Illinois 60661

COUNTY OF RESIDENCE OF FIRST USTEO DEFENDANT :=:::-C:::OO:-:::-:k_ _ _ _ _ __

NOTE:

(IN U,S. PLAINTIFF CASES ONLy)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE

TRACT OF LAND INVOLVED.

, ";,'

.: ~"U.!

ATIORNEYS (IF KNOWN)

Stephen Gorman Davis, Mannix and McGrath

HAAg -lOOt

125 S. Wacker Drive, Suite 1700

Chicaoo, IL 60606-4402

II. BASIS OF JURISDICTION IPLACEAN "X" IN ONE BOXONLy)

ilI:, U.S. Govemment
Plaintiff
o 2 U.S. Government Defendant

o 3 Federal Quea1ion
(U.S. Govemment Not a Party) o 4 DWersily
(Indleste Cilizanship of PartIes In Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES IPLACE AN "X" IN ONE sox FOR PLAINTIFF

(For Diversity Cases Only)

AND ONE BOX FOR DEFENDANT)

Clllzan of This State

PTF DEF

PTF DEF

[J 1 01 Incorporated or Principal Place 0 4 0 4
01 Business In This State ,"~_

CitIzen ot Another State 0 2 0 2 Citizen or Subject of a 0 3 0 3
Foreign Country

Incorporated and Principal p\8c'e 0 5 b 5

of Business In Another Stall!.
L.w,,1

." f.::J

ForeIgn Nation L!..} -,,".- 0 e (0 e

! .-.t >-:'.: 1-

IV. CAUSE OF ACTION (CITE THE U.S. CML STAT1JTE UNDm WHICH YOU ME FlUNG AND WRITE BRIEF STATEMENT OF CAUSE.
00 NOT CITE JUAISDICTIONAL STATUTES UNLESS DIVERSiTY.)

w..l

a Sex harassment in violation of Title V]] of the Civil Rights Act of 1964";.1
42 V.S.C. §2000e et. seq. ,

co
I
-':;:-,:5

q
Gel

V. NATURE OF SUIT (PLACE AN "X" IN ONE BOX ONLy)

I

'-.)

::i

CONTRACT

TORTS

FORFEITURE/PENALTY BANKRUPTCY

OTHER STATUTES

o 110 IMurance
0120 Marine
o 130 MUlef AC1 o 140 Negotiable Instrument o 150 ~=~~e~~~lnl o 151 Medicare Act
o 162 ~~:rr:'n~lauHed
(Excl. VElterans) 0153 Recovery or overpayment
01 Veteran's BenetHs
o 110 Stockholders' Suits
o 1to Other ContrACt o 185 Contract Product Liability
REAL PROPERTY
0210 Land Condemnation
o 220 Foreclosure o 230 Rent LeMe & EJectment o 240 Torts to Land o 245 Tort Product Uablllly o 2tO All Other Real Property

PERSONAL INJURY
o 310 A.lrplane o 315 Airplane ProduC1
Uabnlty
o 320 Assault, Libel & Slander
o 330 Federal Employers' Uability
o0340 Marrne
345 Marine ProduC1 Uabillty
CI 350 Motor Vehicle
o 355 Motor Vehkle Product Uability
o 340 Other Persona/InjUry

PERSONAL INJURY
o W2 Pel$onallnJury Mod. Malpracllce
o 315 ~~r:J~~tyo . . AsbestO$ f\)/'$Onal
Injury ProduC1 Uability
PERSONAl PROPERTY
o 370 Other Fraud oo 371 nutn In lending
310 Other P$l'$Onai Property Damage
o . 5 Property Damage Product Uabmty

CIVIL RIGHTS
o 441 Voting o}t1 442 Employment
443 Housing! AccommOdations
o0444 w.rrare 440 Other OMI Rights

PRISONER PETITIONS

o 510 Motions to Vacate senlence

o

sao

HIWaas COrpus: General

0535 Death Penalty
o 540 Mandamus & Othor o &SO Other

o 110 Agrlcunufe oCJ '20 Other Food & Drug
825 Drug Related Seizure of Propefty 2 t USC 881
0130 Uquor Laws
o MO R.R. &. Tfuck o 'SO Alt1lne Regs. o NO OCcupalional
satety/Heahh
o Oto Other
LABOR
o 710 Fair Labor Standards
o '01 720 Labor/Mgmt Relations
o 730 Labor/Mgmt. Reporting &. Disclosure Act
o 740 Railway Lallof Act
o 780 Other Labor Lltlgatlon o 7f1 Empl. Ret Inc.
8ecurityAct

o 422 Appeal 28 uSC 158
o 423 Withdrawal 28 USC 167
PROPERTY RIGHTS
o .20 Copyrights o0830 Patent
840 Trademark
SOCIAL SECURITY
o N1 HlI\(139511)
o h2 Black Lung (923) o N3 OIWC/D!\WI (405(g)) o '84 SSlD TItle XVI o 185 RSI (405(9))
FEDERAL TAX SUITS
o 170 Taxes (U.S. Plaintiff or Defendant)
o .71 IRS - Third Party 26 USC 7609

o 400 Slate Reapportionment o 410 AAtltrust o 430 Banks and Banking
o 450 Commeroo/lCC Rates/etc. o 410 Deporlallon
o 470 Racket&er Influencod and
o ,,0 COrrupt Organlzallons selective Service
o ISO securilies/Commodniesl Exchange
o 875 Ct2usutosmce3r4ctOnallenge o 1t1 Agrlcunural Acts o 102 Economic Stabilization Act o 'N EnVIronmental Matlers
o '84 Energy Allocation Act
o 815 Freedom 01 Information Act
o IlOO ~peal of Fee Determination nder Equal Access to JU$llce
o or 850 Constnutlonallty State Statutes
o Ito Other Statutory Actions

VI. ORIGIN
Xl 1 Onginal
Prooeedlng

o 2 Removed from Stete Court

(PLACE AN "X" IN ONE BOX ONLy)

o 3 Remanded from o • Ralnstated or

Appellate Court

Raopaned

Transferred from o 5 another dIstrict
(spacity)

VII. REQUESTED IN COMPLAIN'r.

CHECK IF THIS IS A CLASS ACTION
o UNDER F.R.C.P. 23

DEMAND $

o • Multidislrlct
Utlgation

Appeal to District
JudQe from 0 7 Magistrate
Judgment

CHECK YES only ndemanded In complaint

JURY DEMAND: ~ YES

0 NO

VIII. RELATED CASE(S) (See Instructions):

IF ANY

JUOGE

DATE
March 8, 2001

,J w' it, I OJ

SIGNATURE OF A:.r~RNEY OF RECORD
W rcfc! r Ur-..

DOCKET NUMBER

1-;2

Case 1:01-cv-01634 Document 1 Filed 03/08/2001 Page 8 of 8

U~"ED STATES DISTRICT COUV ' NORTHERN DISTRICT OF ILLINOIS

" ";', !,

In the Matter of
U.S. Equal Employment Opportunity Commission, Plaintiff,

Ole 1684

v. Majesty Maintenance, Inc.

Case Number:

.jUD(~~.F,~.1!!!~~'i.i.j"•8'.!=;:;Pn,AQ)

Defendants.

APPEARANCES ARE HEREBY FILED BY THE UNDERSIGNED AS ATTORNEMY(ASG)IlS'1'O1RL~i TE JUDGE NOLAN

U.S. Equal Empl0y...vat Opl!vrtunity ('nmmi«inn Plaintiff

FIRM Equal Employment Opportunity Commission STREET ADDRESS 500 W. Madison St., Suite 2800

( FIRM ~ual Employment Opportunity Commission
...... o:~. u.ooo 500 W. Madison St., SIJi~2800

CITY/STATE/ZIP Chicago, IL 60661 TELEPliONENUMDER(312) 353-7525

CITY/STATE/ZIP Chicago, IL 60661 ~ :.;;:";
TELEPHONENUMDER(312) 353-7722 / t;.}~-:; :...•..~~

ARDe No.02920646 IDENTIFICATiON NUMBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR'!

YES X

NO

TRIAL ATTORNEY? It ~

YES

NO D

MEMBER OF TRIAL BAR? TRIAL ATTORNEY'! DESIGNATED AS LOCAL COUNSEL?

" :.:.;.,.L:r'-.-~ :.,.~..•;.:~;. ,." ;2::V' x
YESc;g ~O D YES D N0D

(D)

SIGNATURE

/

NAME

CITY/STATE/ZIP Chicago, IL 60661

TELEPHONE NUMBER (312) 353-8551

ARDC No.Ol187589 IDENTIFICATION NUMBER (SEE JTEM4 ON REVERSE)

MEMBER OF TRIAL BAR?

YES

NO

TRIAL ATTORNEY? DESIGNATED AS LOCAL COUNSEL'!

YES 181

NO

D

YES 0 NO D

FIRM STREET ADDRESS

CITY/STATE/ZIP TELEPHONE NUMBER

IDENTlFICAliON NUMBER (SEE ITEM 4 ON REVERSE)

MEMBER OF TRIAL BAR?

YES

TRIAL ATTORNEY'!

YES

DESIGNATED AS LOCAL COUNSEL?

YES

D NO D D NO D D NO D

 </s> Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 1 of 11

Minll"e Order Foon (06/97)
--=n-~

United States District Court, Northern District of Illinois

Name of Assigned Judge or Magistrate Judge

NanR. Nolan

Sitting Judge if Other than Assigned Judge

CASE NUMBER

01 C 1634

DATE

9123/2002

CASE TITLE
MOTION:

EEOC, et al. vs. Majesty Maintenance, Inc.
[In the following box (a) indicate the party filing the motion, e.g., plaintiff, 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[heldlcontinued to] [set forlre-set for] on ....__ set for ___ at ___.

(6) o

Pretrial conference[heldlcontinued to] [set for/re-set for] on ___ set for ___ at ___.

(7) o

Trial[set forlre-set for] on ___ at ___.

(8) o

[Bench/Jury trial] [Hearing] heldlcontinued 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 FRCP4I (a)(2).

(10) • [Other docket entry] Enter Consent Decree: This Decree fully and finally resolves any and all issues and claims arising out of the Complaint filed by the EEOC and the Complaint filed by the Intervenors in this action. Status hearing set for September 24, 2002 is stricken.

•

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

No notices requircd, advised in open court.

No notices required .

./ Notices mailed by judge's staff.

Notified counsel by tclcphone.

Docketing to mail notices.

Mail AO 450 form.

Copy to judge/magistrate judge.

courtroom deputy's initials

4
SEP 25
KM, mailing deputy initials

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 2 of 11

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

./'.

EQUAL EMPLOYMENT OPPORTUNITY

)

COMMISSION,

)

Plaintiff

)

and

)

)

HALINA KATARZYNA, EDYTA KURDZIEL, )

MARIA NAPIORKOWSKI, AND BARBARA

)

POLTORAK,

)

)

Intervening Plaintiffs

)

)

v.

)

)

MAJESTY MAINTENANCE, INC.,

)

)

Defendant.

)

OOCKHED
SEP i 520(]2
CIVIL ACTION NO. 01 C 1634
Magistrate Judge Nolan

CONSENT DECREE
THE LITIGATION
1. Plaintiff Equal Employment Opportunity Commission (the "EEOC") filed this action alleging that Defendant, Majesty Maintenance Inc., ("Majesty") violated Section 703(a) of Title VII of the Civil Rights Act of 1964, as amended ("Title VII"), 42 U.S.C. § 2000e-2(a), by fostering or tolerating a working environment that was hostile to female employees. Majesty denies these allegations. The EEOC seeks relieffor Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski, and Barbara Poltorak, all ofwhom have filed Charges of Discrimination with EEOC against Majesty. They have intervened in this action, filed an intervening complaint and are represented by private counsel. (They are referred to hereafter as "Charging Parties" or "Intervenors.") The EEOC also seeks relief for Edyta Firosz.
2. In the interest of resolving this matter, and as a result of having cngaged in comprehensive settlement negotiations, the parties have agreed that this action should be

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 3 of 11
finally resolved by entry ofthis Consent Decree (hereafter "Decree"). This Decree fully and finally resolves any and all issues and claims arising out ofthe Complaint filed by the EEOC and the Complaint filed by the Intervenors in this action. Nothing in this Decree should be construed as an admission by any party regarding either liability or non-liability.
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 ofthis action and ofthe parties.
b. The terms of this Decree are adequate, fair, reasonable, equitable, and just. The rights ofEEOC, Majesty, the Interevenors, Edyta Firosz, and the public interest are adequately protected by this Decree.
c. This Decree conforms with 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 claimants, and the public.
NOW, THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED THAT: Injunction against Sexual Harassment
4. Majesty and its officers, agents, management (including supervisory employees), successors and assigns, and all those in active concert or participation with them, or any of them, are hereby enjoined from: (i) discriminating against women on the basis of sex; (ii) engaging in or being a party to any action, policy or practice that is intended to or is known to have the effect ofharassing or intimidating any female employee on the basis ofher gender; and/or (iii) creating, facilitating or permitting the existence of a work environment that is hostile to female employees.
2

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 4 of 11
NON-RETALIATION 5. Majesty, its officers, agents, employees, successors, assigns and all persons acting in concert with it shall not engage in any form ofretaliation 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 6) Majesty shall pay a total of$70,000 in full settlement of this case. Of that amount, $2,000 shall be paid to Edyta Firosz (upon receipt ofthe release in the format of Exhibit A.) The balance of $68,000 will be divided between the four charging parties and their counsel. The four charging parties and their counsel shall agree upon the division and advise the EEOC and Majesty. None of the payments to the five claimants shall be considered compensation for lost wages, so no withholdings shall be made from the payments. 7) (a) Majesty shall i,ssue a separate check representing attorneys' fees to the law firm representing the Intervenors: Katz, Friedman, Eagle, Eisenstein and Johnson, 77 W. Washington Street, 20th Floor, Chicago, Illinois 60602-2801, by September 1,2002. (b) Within five (5) business days after receipt by Majesty ofa Release Agreement, but in any event no later than September 18,2002, Majesty or its agent shall issue a check to each claimant in the amount agreed upon. The check to Edyta Firosz will be sent to her home address, which the EEOC has provided to Majesty. The checks to the four Charging Parties, who have intervened as plaintiffs in this case, shall be sent to their counsel, Laurie Burgess at the law firm listed in subparagraph (a). A copy of each check issued to each of the five claimants shall be sent to the EEOC.
POSTING OF NOTICE 8. Within ten (10) business days after entry of this Decree, Majesty shall post copies of the Notice attached as Exhibit B to this Decree on the bulletin boards usually used by Majesty for communicating with employees at its Wood Dale facility. Copies translated into Spanish and Polish shall also be posted. The Notice shall remain posted for three (3)
3

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 5 of 11
years from the date of entry of this Decree. Majesty shall take all reasonable steps to ensure that the posting is not altered, defaced or covered by any other material. Majesty shall certify to the EEOC in writing within ten (10) business days after entry of the Decree that the Notice has been properly posted. Majesty shall permit a representative of the EEOC to enter Majesty's premises for purposes of verifYing compliance with this Paragraph at any time during normal business hours without prior notice.
RECORD KEEPING 9. For a period ofone year following entry ofthis Decree, Majesty shall maintain and make available for inspection and copying by the EEOC records of each complaint of sexual harassment. Such records shall indicate the date the complaint was made, who made it, what was alleged, and what actions Majesty took to resolve the matter, and when. 10. Majesty shall make all documents or records referred to in Paragraph 9 above, available for inspection and copying within ten (10) business days after the EEOC so requests. In addition, Majesty shall make available for interview all persons within its employ whom the EEOC reasonably requests for purposes of verifYing compliance with this Decree and shall permit a representative of the EEOC to enter Majesty's premises for such purposes on five (5) business days advance notice by the EEOC.
REPORTING 11. Majesty shall fumish to the EEOC the following written reports .The first report shall be due six (6) months after entry ofthe Decree. The final report shall be due eleven (11) months after entry of the Decree. Each such report shall contain:
a. A summary of the information recorded by Majesty within the last 6 months pursuant to Paragraph 9, including the names of each person who complained of sexual harassment, the date of the complaint, and the actions, and dates thereof, taken by Majesty, including any discipline given;
b. A certification by Majesty that the Notice required to be posted in 8, above, remained posted during the entire six (6) month period preceding the report.
4

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 6 of 11
ADOPTION AND DISTRIBUTION OF POLICY AGAINST SEXUAL HARASSMENT
12. Majesty has agreed to and shall amend its policy against sexual harassment. Majesty represents that its policy currently prohibits sexual harassment by all employees, encourages employees who have complaints ofsexual harassment to complain promptly, and provides that employees who violate the policy are subject to discipline up to and including discharge. The amended policy shall:
a) Prohibit sexual harassment by employees, supervisors, officer and owners of Majesty;
b) Prohibit sexual harassment whether it occurs on the premises of Majesty, at a Majesty client site or in travel to or from a work site or the premises of Majesty;
c) Provide that if the alleged harasser is a supervisor, the employee may complain to someone else about the harassment;
d) Provide that if the alleged harasser is an owner or officer of Majesty, complaints can be made to a designated outside representative.
e) Not set mandatory deadlines for complaining about harassment; f) Provide that supervisors who receive reports of or observe sexual harassment shall notify their supervisor of the observed or reported harassment; g) Advise employees that they may complain of sexual harassment to the Equal Employment Opportunity Commission at 500 West Madison, Chicago, Illinois. Within twenty-one (21) days after the entry of this Consent Decree Majesty shall include a copy of its amended Policy in each pay check envelope of each employee of Majesty. Should Majesty know that the primary language of an employee is Polish, it shall also include a Polish translation of the policy in the envelope. Should Majesty know that the primary language of an employee is Spanish, it shall also include a Spanish translation ofthe policy in the envelope. 13. A copy ofthe amended Policy shall be given to each new employee on the day the person is hired. Should Majesty know that the primary language of a new employee is
5

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 7 of 11
Polish, it shall also give him or her a Polish translation of the policy. Should Majesty know that the primary language of a new employee is Spanish, it shall also give him or her a Spanish translation of the policy.
Copies ofthe Policy shall also be posted on the bulletin boards customarily used for posting notices from management to employees.
TRAINING 14 Within 60 days of the entry of this Decree, Defendant shall retain and pay for a trainer approved by the EEOC, to provide training to all owners, officers and supervisors with respect to sexual harassment and with respect to the Policy implemented pursuant to Paragraph 12 above. A registry of attendance shall be maintained. 15. Majesty shall obtain the EEOC's approval of its proposed trainer prior to the training session. Majesty shall submit the name, address, telephone number and resume of the proposed trainer to the EEOC within 15 days ofthe entry ofthis Decree. The EEOC shall have five calendar days from the date of receipt ofthe information described above to accept or reject the proposed trainer. In the event the EEOC does not approve Majesty's designated trainer, Majesty shall have five calendar days to identify an alternate trainer. The EEOC shall have five calendar days from the date of receipt ofthe information described above to accept or reject the alternate trainer. In the event the EEOC does not approve Majesty's alternate trainer, the EEOC shall designate the trainer to be retained and paid for by Majesty. 16. Majesty shall certify to the EEOC in writing with five (5) 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 ofthe registry ofattendance, which shall include the name and position ofeach person in attendance.
DISPUTE RESOLUTION 17. In the event that either party to this Decrec believes that the other party has failed to comply with any provision(s) of the Decree, the complaining party shall notify the other party of the alleged non-compliance within ninety (90) days of the alleged
6

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 8 of 11

non-compliance and shaH afford the aIleged non-complying party ten (10) business days to

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

party has complied. If the aHeged non-complying party has not remedied the aIleged non-

compliance 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.

DURATION OF THE DECREE AND RETENTION OF JURISDICTION

18. AIl provisions of this Decree shaH be in effect (and the Court wiII retain

jurisdiction ofthis matter to enforce this Decree) for a period ofone year immediately foIlowing

entry of the Decree, provided, however, that if, at the end of one year, any disputes under

Paragraph 17, above, remain unresolved, the term ofthe Decree shaH be automaticaIly extended

(and the Court will retain jurisdiction of this matter to enforce the Decree) until such time as all

such disputes have been resolved.

MISCELLANEOUS PROVISIONS

19. Each party to this Decree shall bear its own expenses and costs. The EEOC and

Majesty shall bear their own attorneys' fees.

20. The terms of this Decree are and shall be binding upon the present and future

representatives, agents, directors, officers, assigns, and successors ofMajesty in their capacities

as representatives, agents, directors and officers of Majesty, and not in their individual

capacities.

2 I. When this Decree requires the submission by Majesty of reports, certifications,

notices, or other materials to the EEOC, they shall be mailed to: Gordon Waldron, Senior Trial

Attorney, Equal Employment Opportunity Commission, 500 West Madison Street, Suite 2800,

Chicago, Illinois, 60661. When this Decree requires submission by the EEOC of materials to

Majesty, they shall be mailed to: Attorney, Stephen Gorman at Davis, Mannix and McGrath,

125 S. Wacker Drive, Suite 1700, Chicago, Illinois 60606-4402.

22. Majesty represents that John Jamrozik no longer has any involvement in

personnel decisions in regard to female employees or female applicants. Neither her nor Wojtek

Chojinacki

shall have any involvement in personnel decisions in regard to female

employees or female applicants.

7

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 9 of 11

ENTER
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
Equal Employment Opportunity Commission
500 West Madison Street Suite 2""11' -~ Chic

Date: __~---,{_01_3~/_c_2.._

~Jrb [J cd6 f\Y'\
Goraon aldron Senior Trial Attorney

j,~441~ ~/l or Inte~enors~O

_________

Laurie Burgess

Katz, Friedman, Eagle, Eisenstein and

Johnson 77 W. Washington Street, 20th Floor Chicago, Illinois 60602-2801

8

Case 1:01-cv-01634 Document 15

Filed 09/23/2002 Page 10 of 11

"~,,,

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EXHIBIT A
RELEASE AGREEMENT 1,_ _ _ _ _ _ _, for and in consideration of the sum of$ ____ payable to me pursuant to the terms ofthe Consent Decree entered by the Court in EEOC et al. v. Majesty Maintenance. Inc. , No. NO. 01 C 1634 (N.D. Ill.), on behalf of myself, my heirs, assigns, executors, and agents, do hereby forever release, waive, remise, acquit, and discharge ("Majesty"), and all past and present shareholders, officers, agents, employees, and representatives of Majesty, as well as all successors and assignees of Majesty, from any and all claims and causes ofaction ofany kind which I now have or ever have had under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S ,C. § 2000e et seq., as a result of or arising from the subject matter and claims which were or which could have been asserted in EEOC et al. v, Majesty Maintenance. Inc. , No. NO. 01 C 1634 (N.D. Ill.)

Date

9

Case 1:01-cv-01634 Document 15 Filed 09/23/2002 Page 11 of 11

EXHIBITB NOTICE TO ALL MAJESTY EMPLOYEES

This Notice is being posted pursuant to a Consent Decree entered by the federal court in EEOC et al. v. Majesty Maintenance, Inc. , No. NO. 01 C 1634 (N.D. Ill.), resolving a lawsuit filed by the Equal Employment Opportunity Commission ("EEOC") against Majesty Maintenance, Inc. ("Majesty").

In its suit, the EEOC alleged that Majesty fostered or tolerated a working environment that was hostile to female employees, in violation ofTitle VII ofthe Civil Rights Act of 1964 ("Title VII"). Majesty denies these allegations.

To resolve the case, Majesty and the EEOC have entered in to a Consent Decree which provided, among other things, that:

1) Majesty will not foster or tolerate sexual harassment; 2) Majesty will not retaliate against any person because (s)he opposed any practice
made unlawful by Title VII, filed a Title VII charge of discrimination, participated in any Title VII proceeding, or asserted any rights under the Consent Decree; 3) Majesty will adopt and distribute to all employees a policy against sexual harassment and will train all its supervisors and officers regarding sexual harassment and its policy.

The EEOC enforces the federal laws against discrimination in employment on the basis of race, color, religion, national origin, sex, age or disability. If you believe you have been discriminated against, you may contact the EEOC at (312) 353-8195. 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.

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

This Notice must remain posted for one year from the date below and must not be altered, defaced or covered by any other material.

SEP 23 2002 Date

t~t2-Yb Magistrate Judge Nolan

S:\OLegalUnit\Casefolders\Majesty\Settlement\CONSENT DecreeFinal.wpd
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NOLAN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 3.0 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-01634

EEOC v. Majesty Maintenance Assigned to: Hon. Nan R. Nolan Demand: $0 Cause: 28:451 Employment Discrimination
Plaintiff Equal Employment Opportunity Commission

Date Filed: 03/08/2001 Date Terminated: 09/23/2002 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff
represented by 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
AUSA United States Attorney's Office (NDIL) 219 South Dearborn Street Suite 500 Chicago, IL 60604 (312) 353-5300 Email: USAILN.ECFAUSA@usdoj.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
Jose Jorge Behar Hughes Socol Piers Resnick & Dym Ltd. 70 West Madison Street

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V. Defendant Majesty Maintenance Inc
Intervenor Barbara Poltorak
Intervenor Halina Katarzyna

Suite 4000 Chicago, IL 60602 (312) 580-0100 Fax: 312-580-1994 Email: jbehar@hsplegal.com ATTORNEY TO BE NOTICED
represented by Stephen Anthony Gorman Law Offices of Stephen A. Gorman 325 N. LaSalle Street Suite 450 Chicago, IL 60610 (312)822-0200 Email: sagorman@myintellispace.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Stanley Eisenstein Katz Friedman Eagle Eisenstein & Johnson 77 West Washington Street 20th Floor Chicago, IL 60602 (312) 263-6330 Email: seisenstein@kfeej.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laurie Marie Burgess Katz Friedman Eagle Eisenstein & Johnson 77 West Washington Street 20th Floor Chicago, IL 60602 (312) 263-6330 Fax: (312) 372-5555 Email: lburgess@kfeej.com ATTORNEY TO BE NOTICED
represented by Stanley Eisenstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laurie Marie Burgess (See above for address)

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Intervenor Edyta Kurdziel
Intervenor Maria Napiorkowski

ATTORNEY TO BE NOTICED
represented by Stanley Eisenstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laurie Marie Burgess (See above for address) ATTORNEY TO BE NOTICED
represented by Stanley Eisenstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Laurie Marie Burgess (See above for address) ATTORNEY TO BE NOTICED

Date Filed 03/08/2001
03/14/2001 03/19/2001 05/29/2001 05/30/2001 06/05/2001 06/07/2001 06/18/2001

#

Docket Text

1 COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Jose Jorge Behar, Gordon G. Waldron as attorney(s) for plaintiff ( no summons(es) issued.) ( Documents: 1-1 through 1-3) (eav) (Entered: 03/09/2001)
2 ATTORNEY APPEARANCE for defendant Majesty Maintenance by Stephen Anthony Gorman (eav) (Entered: 03/15/2001)
3 WAIVER of service of summons as to defendant Majesty Maintenance sent on 3/13/01 (eav) (Entered: 03/19/2001)
4 ANSWER by defendant Majesty Maintenance to complaint [1-1]; Notice of filing (eav) (Entered: 05/30/2001)
SCHEDULE set on 5/30/01 by Hon. George W. Lindberg : Status hearing set to 9:30 6/14/01 . Mailed notice (slb) (Entered: 05/30/2001)
SCHEDULE set on 6/5/01 by Hon. George W. Lindberg : Status hearing reset to June 13, 2001 at 9:30a.m. Mailed notice (slb) (Entered: 06/05/2001)
SCHEDULE set on 6/7/01 by Hon. George W. Lindberg : Status hearing reset to June 15, 2001 at 9:30a.m. Mailed notice (slb) (Entered: 06/07/2001)
5 MOTION by plaintiff-intervenors Barbara Poltorak, Halina Katarzyna, Edyta Kurdziel and Maria Napiorkowski to intervene ; Notice of motion (eav) (Entered: 06/19/2001)

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06/18/2001
06/18/2001 06/18/2001 07/11/2001 07/30/2001 08/09/2001 08/16/2001 08/20/2001 08/22/2001 09/05/2001
09/14/2001 09/20/2001 11/08/2001

6 MINUTE ORDER of 6/18/01 by Hon. George W. Lindberg : Status hearing held and continued to 8/9/2001 at 9:30 a.m. Trial set for 2/4/2002 at 10:00 a.m. Motion by Barbara Poltorak, Halina Katarzyna, Edyta Kurdziel and Maria Napiorkowski to intervene is granted without prejudice to defendants to object. [5-1] Objections to be filed by 6/20/2001. Discovery cutoff set for 10/10/2001. Motion for summary judgment due 10/19/2001. Response due 11/2/2001. Reply due 11/9/2001. Ruling set for 1/9/2002 at 9:45 a.m. Proposed final pretrial order to be delivered to chambers by 4:30 p.m. on 1/20/2002. Mailed notice (eav) (Entered: 06/19/2001)
7 INTERVENOR'S COMPLAINT by intervenors Barbara Poltorak, Halina Katarzyna, Edyta Kurdziel, Maria Napiorkowski (eav) (Entered: 06/19/2001)
8 ATTORNEY APPEARANCE for intervenors by Stanley Eisenstein, Laurie Marie Burgess (eav) (Entered: 06/19/2001)
9 ANSWER by defendant to intervenors' complaint [7-1]; Notice. (fce) (Entered: 07/13/2001)
SCHEDULE set on 7/30/01 by Hon. George W. Lindberg : Status hearing reset to 9:30 8/22/01 . Mailed notice (slb) (Entered: 07/30/2001)
10 CONSENT by defendant Majesty Maintenance to exercise of jurisdiction by a United States Magistrate Judge. (eav) (Entered: 08/22/2001)
11 CONSENT by plaintiff to exercise of jurisdiction by a United States Magistrate Judge. (eav) (Entered: 08/22/2001)
12 REASSIGNMENT ORDER of 8/20/01 Case reassigned to Hon. Magistrate Judge Nan R. Nolan from Hon Judge George W. Lindberg pursuant to Local Rule 73.1. (For further detail see order.) Mailed notice (eav) (Entered: 08/22/2001)
13 CONSENT by intervenors to exercise of jurisdiction by a United States Magistrate Judge. (eav) (Entered: 08/24/2001)
SCHEDULE set on 9/5/01 by Hon. Nan R. Nolan : Initial status hearing before Magistrate Judge Nolan set to 10:00 9/20/01 in courtroom 1858. Parties shall deliver a copy of an initial status report to chambers, room 1870, at least three business days before the initial status hearing. If the parties have recently prepared and filed an initial status report, the submission of the previously filed initial status report is sufficient. For further details see attached standing order. Mailed notice (fce) (Entered: 09/05/2001)
14 INITIAL STATUS REPORT by plaintiff, defendant, intervenor (Attachments) (eav) (Entered: 09/17/2001)
SCHEDULE set on 9/20/01 by Hon. Nan R. Nolan : Status hearing held; continued to 10:00 11/8/01. The Court adopts the parties proposed discovery cutoff. Accordingly, all discovery ordered closed on 4/15/02. Mailed notice (fce) (Entered: 09/24/2001)
SCHEDULE set on 11/8/01 by Hon. Nan R. Nolan : Status hearing held; continued to 10:00 12/18/01. In court notice (fce) (Entered: 11/09/2001)

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12/18/2001 01/18/2002 02/27/2002 04/15/2002
04/24/2002 04/29/2002 05/01/2002
06/03/2002 06/28/2002 07/22/2002 08/19/2002
09/23/2002

SCHEDULE set on 12/18/01 by Hon. Nan R. Nolan : Status hearing held; continued to 9:00 2/27/02. In court notice (fce) (Entered: 01/08/2002)
SCHEDULE set on 1/18/02 by Hon. George W. Lindberg : The date for submitting the proposed final pretrial order to Judge Lindberg is stricken. No notice (slb) (Entered: 01/18/2002)
SCHEDULE set on 2/27/02 by Hon. Nan R. Nolan : Status hearing held; continued to 9:00 4/15/02. In court notice (fce) (Entered: 02/27/2002)
SCHEDULE set on 4/15/02 by Hon. Nan R. Nolan : Status hearing held. Counsel for plaintiff and defendant appeared. Counsel for intervening plaintiffs did not appear. Status hearing continued to 9:00 4/24/02. All counsel are ordered to appear. Mailed notice (fce) (Entered: 04/15/2002)
SCHEDULE set on 4/24/02 by Hon. Nan R. Nolan : Status hearing held. Settlement conference set for 6/5/02 at 1:30 p.m. Parties are to have all position papers by 5/31/02. Mailed notice (maf) (Entered: 04/24/2002)
SCHEDULE set on 4/29/02 by Hon. Nan R. Nolan : The time for the settlement conference set for 6/5/02 is reset to 9:30 a.m. Mailed notice (fce) (Entered: 04/29/2002)
SCHEDULE set on 5/1/02 by Hon. Nan R. Nolan : Settlement conference reset to 1:30 6/3/02. Parties are reminded that Magistrate Judge Nolan requires compliance with her Standing Order Setting Settlement Conference, which has previously been mailed to the parties and is available on the court's website at www.ilnd.uscourt.gov. Mailed notice (fce) (Entered: 05/01/2002)
SCHEDULE set on 6/3/02 by Hon. Nan R. Nolan : Settlement conference held. Status hearing set to 9:00 7/1/02. Mailed notice (fce) (Entered: 06/04/2002)
SCHEDULE set on 6/28/02 by Hon. Nan R. Nolan : Status hearing reset to 9:00 7/22/02 at the parties' request. Telephoned notice (fce) (Entered: 06/28/2002)
SCHEDULE set on 7/22/02 by Hon. Nan R. Nolan : Status hearing held. Plaintiff appeared. Neither defendant nor intervening plaintiffs appeared. Settlement conference set for 10:00 8/19/02. Mailed notice (fce) (Entered: 07/22/2002)
SCHEDULE set on 8/19/02 by Hon. Nan R. Nolan : Settlement conference held. Agreement reached. Parties directed to file stipulated dismissal order. In the event stipulated dismissal order is not filed by 9/23/02, parties to appear for status hearing set to 9:00 9/24/02. Mailed notice (fce) (Entered: 08/19/2002)
15 MINUTE ORDER of 9/23/02 by Hon. Nan R. Nolan: Enter consent decree: this decree fully and finally resolves any and all issues and claims arising out of the complaint filed by the EEOC and the complaint filed by the Intervenors in this action. Status hearing set for 09/24/02 is stricken terminating case. (Entered Consent Decree.) Notices mailed by judge's staff (cdy) (Entered: 09/25/2002)

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[CONTENT] March 2001 | the Chicago District Office | EEOC | Majesty Maintenance Inc. | District Court | the Northern District | Illinois | Title VII of the Civil Rights Act | 1964 |||  ||| June 2001 ||| 2002 ||| one-year | 70,000 | five [SUMMARY] In March 2001 the Chicago District Office of the EEOC filed this lawsuit against the cleaning service Majesty Maintenance Inc. in the U.S. District Court for the Northern District of Illinois alleging discrimination on the basis of gender, female, in violation of Title VII of the Civil Rights Act of 1964.  Specifically, the defendant allegedly had a pattern or practice of creating a hostile work environment.  The complainants intervened in the lawsuit in June 2001.  Following discovery and several status conferences, the parties settled the lawsuit in 2002 through a consent decree.

The one-year decree, containing non-discrimination and retaliation provisions, required the defendant to: report on complaints and make other compliance reports, keep records, allow access to outsiders for monitoring, develop its anti-discrimination policy, post and distribute notice, provide EEO training, and pay $70,000 to be distributed among five individuals.

