UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

Similar documents
IN THE UNITED STATES DISTRICT COURT. FOR THE NORTHERN DISTRICT OF ILLINOIS eu,:".' IJ~:'LD~~?~:~~URT EASTERN DIVISION ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) Plaintiff, ) ) ) ) ) ) ) ) NATURE OF THE ACTION

Case 3:04-cv RLA Document 1-1 Filed 09/30/2004 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT DISTRICT OF PUERTO RICO

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

NATURE OF THE ACTION. This is an action under Title VII of the Civil Rights Act of 1964, as amended by the

IN THE UNITED STATES DISTRICT COUR~A I FOR THE NORTHERN DISTRICT OF ILLINO~ STRA~ E EASTERN DIVISION 0~U ) ) tl0v 1 0 7_604 ) ) NATURE OF THE ACTION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

IN THE UNITED STATES DISTRICT COURT ~,~,~,,.c~...,... ~~"~ ~ " FOR THE WESTERN DISTRICT OF NORTH CAROLI~ SEP -9 ;i ~ [~: 0~ CBA~OTTE OIVlSlON

Case 3:04-cv JSW Document 168 Filed 10/20/2005 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

Case 4:07-cv JLH Document 1 Filed 06/29/2007 ( Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA PENSACOLA DIVISION NATURE OF THE ACTION

)

Case 3:06-cv JAP-TJB Document 1 Filed 03/27/2006 Page 1 of 5 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Case 1:18-cv RDB Document 1 Filed 07/30/18 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND BALTIMORE DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION ) ) ) NATURE OF THE ACTION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF IOWA DAVENPORT DIVISION. Nature Of The Action

Case 4:17-cv Document 1 Filed in TXSD on 07/20/17 Page 1 of 8

Case 4:16-cv Document 1 Filed in TXSD on 09/29/16 Page 1 of 7

Case 1:11-cv LG-JCG Document 2 Filed 11/17/11 Page 1 of 7

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII CV

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

Case 2:09-cv BSJ-RLE Document 67 Filed 10/28/11 Page 1 of 6

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 3:11-cv CRW-TJS Document 1 Filed 04/06/11 Page 1 of 7

Case 2:14-cv MPK Document 1 Filed 04/22/14 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NORTH DAKOTA ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ORIGINAL COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA NATURE OF THE ACTION

-CIVIL RIGHTS EMPLOYMENT

Case: 1:10-cv Document #: 1-2 Filed: 06/03/09 Page 1 of 5 PageID #:2

)

Case 4:04-cv LLP Document 1 Filed 12/28/2004 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA.

) I ClV a S - BUN. 18 This is an action under Title VII ofthe Civil Rights Act of 1964 and Title I of the Civil

Case 2:05-cv JES-SPC Document 47 Filed 04/24/2006 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

This is an action under the Genetic Information Nondiscrimination Act of 2008

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA. Plaintiff, Defendant. AMENDED COMPLAINT AND JURY TRIAL DEMAND NATURE OF ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA DUBLIN DIVISION

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NORTH DAKOTA ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

5:06cv1684 JUDGE HICKS MAG. JUDGE HORNSBY

UNITED STATES DISTRICT COURT DISTRICT OF HA WAIl. Case No.: NATURE OF THE ACTION AND JURISDICTION

IN THE UNITED STATES DISTRICT COURT. FOR THE NORTHERN DISTRICT OF ILLIll~ STATES DISTRICT COURT WESTERN DIVISION CONSENT DECREE THE LITIGATION

ORIGINAL COMPLAINT OF THE UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION TO THE HONORABLE UNITED STATES DISTRICT COURT:

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

Case 4:05-cv CLS Document 1 Filed 05/26/2005 Page 1 of 6

Case 7:17-cv KMK Document 1 Filed 07/06/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

IN TIlE UNITED STATES DISTRICT COURT, FOR TIlE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION. Judge Gettleman CONSENT DECREE THE LITIGATION

Case 1:06-cv LTB-CBS Document 1 Filed 09/29/2006 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 6:10-cv TC Document 1 Filed 09/24/10 Page 1 of 7 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

COMPLAINT (Jury Trial Demand)

Case: 1:06-cv JRA Doc #: 28 Filed: 05/08/09 1 of 9. PageID #: 220

Case 1:17-cv Document 1 Filed 09/27/17 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

IN TI-[E UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO. ..-ECHOSTAR COMMUNICATIONS CORPORATION n/k/a DISH, LTD.,

Case 9:06-cv RHC Document 1 Filed 02/28/2006 Page 1 of 7

FILED. , #, Case 5:05-cv WRF Document 29 Filed 06/06/2006Page 1 of 9 JUN COMMISSION, Plaintiff, ALICIA MANSEL, Civil Action No.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION. Plaintitl, Defendants. COMPLAINT AND JURY TRIAL DEMAND

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA FORT PIERCE DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII ) ) ) ) ) ) ) ) ) ) ) )

2:04-cv HAB-DGB # 1 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION ) ) ) ) ) ) ) ) ) )


UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII

PLAINTIFF AVA SMITH- THOMPSON S COMPLAINT AGAINST DEFENDANT SARA LEE CORPORATION

Case 1:13-cv Document 1 Filed 06/28/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Case: 1:13-cv Document #: 1 Filed: 07/25/13 Page 1 of 7 PageID #:1

Case 2:03-cv BBD-sta Document 14 Filed 08/05/2004 Page 1 of 7

Case: 5:15-cv SL Doc #: 1 Filed: 07/20/15 2 of 9. PageID #: 2

Equal Employment Opportunity Commission, Plaintiff, v. Studley Products, Inc. and Wildwood Industries, Inc., Defendants.

Case 2:16-cv RSL Document 1 Filed 08/05/16 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

Equal Employment Opportunity Commission v. Bob Watson Chevrolet

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

EEOC v. Ealge Wings Industries, Inc.

CASE NO. 5:00-CV COMPLAINT IN INTERVENTION ON BEHALF OF JACKQULINE STOKES

Case 1:16-cv Document 1 Filed 11/21/16 Page 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT STATE OF RHODE ISLAND COMPLAINT INTRODUCTION

Case 1:14-cv KMT Document 1 Filed 09/24/14 USDC Colorado Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 8:04-cv SCB-TBM Document 32 Filed 10/07/2005 Page 1 of 6

Case: 1:17-cv Document #: 1 Filed: 03/09/17 Page 1 of 6 PageID #:1

Case 1:14-cv KAM-JO Document 8 Filed 07/02/14 Page 1 of 11 PageID #: 36

Case: 1:14-cv Document #: 1 Filed: 02/18/14 Page 1 of 15 PageID #:1

Amended Complaint, Gassman v. Frischholtz et al, Docket No. 1:05-cv (Northern District of Illinois 2005)

Second Amended Complaint, Gassman v. Frischholtz et al, Docket No. 1:05-cv (Northern District of Illinois 2005)

FIRST AMENDED COMPLAINT

Case 1:16-cv Document 1 Filed 11/21/16 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT STATE OF RHODE ISLAND COMPLAINT INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

Case 3:16-cv L Document 1 Filed 11/01/16 Page 1 of 9 PageID 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Case 3:15-cv EDL Document 1 Filed 12/09/15 Page 1 of 16

EEOC v. Bice of Chicago, et al.

EEOC v. Merrill Pine Ridge, LLC

Case 3:16-cv DRH-PMF Document 6 Filed 04/26/16 Page 1 of 21 Page ID #19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 2:16-cv GMN-VCF Document 1 Filed 04/26/16 Page 1 of 10

Case 1:13-cv LEK-KSC Document 1 Filed 12/18/13 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT DISTRICT OF HAWAII ) ) ) ) )

Case: 1:14-cv Document #: 119 Filed: 03/08/16 Page 1 of 16 PageID #:708

Case 1:15-cv KMW Document 1 Entered on FLSD Docket 10/13/2015 Page 1 of 9

Transcription:

Civil Cover Sheet UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS Page J 1'2 Civil CQyerShe~t This,.ted JS 44 confomls generally to the manual JSA4 approved by the Judicial Conference of the United States in September 1974, The data is required for the use of the Clerk ofcolllt for the purpose of initiating the civil docket sheel, The infonnation contained herein neither replaces nor supplements the filing and service ofp1cajings or otht:r papers as required by law. This form is authorized for use OIJy in the NOl'lhern District of Illinois, Plaintiff(s: U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION County of Residence: Plaintiff's Atty: Gordon G. Waldron Equal Employment Opportunily Commission 5 W. Madison St., Suite 28 Chicago, It 6661 (312 353-7525 Defcndant(s:T -MOBILE USA, INC. County of Residence: Cook Derendant's Atty: Brian McCarthy Jackson, Lewis LLP 32 W, Ohio St., Sltitc 5, Chicago, IL 661 (312 787-4949 '!\'I>M"",.w,WI",",J\I\II~I!"n'''n,!""", \'\i\'l\jlll';l:"mm='mm",w::,":,':wm:.:"'"'j""",<""",,,"",iiiii,:'"'''''''''''''''',:""ii!ii''' """J""",:,: :"::""m,:':",,, """'",,,\',":, :J!!!!W: ::.!A',,',w""'''\i'' \1,I'lil,!A''':MIm''''"''''\I""~I"IIII,I!\''m'"'\I'''''",,,,,",,~llrl':'!\"',,",' "\1W"!'::"llllli;;I:"'"'' H. Bas(s_of jurisdiction: /i.""il.s. Gov" Plaintiff f-/ lil CitLZ;"'lship9f.f'rincip;!\ f>arties (Diversity Cases Only Plaintiff: N/A Defendant:- NI A JUDGE GETJ.IJJ4., 4C 2 ~IUA"1 MAGISTRATE JUDGC" M '" AS ON LV. Origin: 1. Original Proceeding ~nrrploy[llent yr.causgof Actio]; Title VII of the Civil Rights Act of 1964, as anrrended, 42 U.s.C. 2e et seq. ("Title Vll", and Title I ofthc Civil Rights Act of J 991,42 U.S.C. J 98la, to correct unlawful employnrrent practices on the basis of sex and retaliation.,~; J' VII. RCllJ.!ested il.conlp laint Class Action: Dollar Demand: Jury Demand:Yes vul. This case IS NOT a refiling of a previously dismissed case, ('... ~.-:: (l -. f..."-, f- e' C {-:-: (',-:' ;.:j -, --: "1'1. '. :"-,"J!.,,:"" I, 1'...::: '- ":':~ ~,,> '. i-::j ",'4.-(. Signature: Date:,~~,;9!eaJJ r t-(.~1 '1 "~I!j~II"'''''!'''mW\1,W,WM''JI!.'',\:'''MMlM"'",,": ::,,W''!\'1III',1"""W"""«::,",",\' :' :I\,,,,!"',",\':::1::"""" ""\1' """1,,"',:'''''',,,' """ """'I~I~II'",I"""" "'!",W,W':ro:I\'!!!"1""M""""', "'WW:.'::IIi!I'I,:"""C"".,'"",m '''''',~IW''J''''''',,,,,WW http://www,ilnd,nscourts,govipublic/forms/autojs44.cfm 4114124

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS ~'.. In the Matter of EASTE7JIfCH.SION., " - fted Equa 1 Emp I oyment A pportuolty Lomn1lSSlOn, APR ' v. Plaintiff, ( 6 ZOD<f. T-Mobile, Inc., 4C Defendant. Case NumtWDGE GErnFMAN ~ 'd'~j, APPEARANCES ARE HEREBY PILED BY THE UNDERSIGNED AS ATTORNEY(S par: U.S. Equal Employmcnt Opportunity Commission, Plaintiff -. If'>!.~'b. '1"'1 SI(NATURf (A (8 :.lame FlRl\1 [.j'l'r[]ct ADDnESS C1TYiST,I,Ti',rI.Il" TE,LF,~H(lNE NIJMHER Gordon G. Waldron Equal Employment Opportunity Commission 5 W. Madison St., Suite 28 Chicago, Illinois 6661 FAX Nl,lMHI-:R (312 353-7525 (312 353-8555, MAIL ADDRnSS Gordon. W aldron@eeoc.gov NAMe ~ Gregory M. Gochanour :';'I'}{ci:.'l' ADDP..I3SS (,JTYi~TAn:r/lI' Equal Employment Opportunity COimnission 5 W. Madison St., Suite 28 Chicago, Illinois 666 J '_MA"""DRC" Gregory.Gochanour(~eeoc.gov IDCNTlf.ICATl.Ol'l NUMI'lF,1! (~F,I'. ITEM 4 ON ItI::VIJJ{SC ARl.le No_ 292646 MEMBER (IF TR IAI. I1AIU YES [!l NO o ILJI!NTIJ']C'ATION NUMBIiR(SEE ITf,M 4 ON NF.VEIISE ARDC No. 62184 MEMBE~ OF TRIAL. liar'/ yns [!l NO I'f~IAL ATTORI'uY? 7 YES NO o YES YES [!l NO o NO NAMF, ( <",_.'... : "'" Eqf.al Empl~yment Opportun ity COl11l11ission STREET AnrJllFF I 5 W. Madison St., Suite 28 c"r\.yistat lr '-"'" CI'. ucago, Til" 111lS 66'6'1 TF.I.FPHOI... E NU.\1BI::~ FAX NIIMBI::~ (312 353-R551 (312353-R555 E_MAIL Al.1uitESS lolm.hendnckson@eeoc.gov IIJENTIFICATIUN f.,'umoor (SEE ITEM..j O;o.JRF.VF.H~f: ARDe No_ Oil R7589 MEMBJ::II. Of TRIAL DAR? YJ:::S ~ N" lrll\l A'fiOR. 'U:Y? yes Ii?] NO DESIONATF,D AS 1.(I(:Al.l~UNS;f.L'? YI':!i" NO FIIIM STRiiET ADDRE.SS t:l'i'yi~'fati!izii" Tf.I.F.PH(lNE NllMBl::it E_MAIL iilll.1lt12ss IJ'F.NT1FIt':ATlON ~umocr (STIr: ITEM 4 ONREVF,R.'lF. MflMDER Of TRlAL DAR',' TRIAL 1\ TIORNTIY? nf.~l(inate1j A.'-; J.(t:AL C{uNS~L?.;-,\ I FAX:o.IllMHEit., -.:."!,., ViiS NO YI::s NO D n:.,:,,,! /9?/- I

Equal Employment Opportunity Commission, v. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Plaintiff, T-Mobile USA, Inc., formerly knowu as VoiceStream Wireless, Defendant. NATURE OF THE ACTION JUDGE GHTL[~MN COMPLAINT 'n '- JURY TRIAL DEMAND _.,:': I 'S IV,lIGI;:;lhATEJUDGE MASON This is an action under Title Vll of the Civil Rights Act of 1964, as amended, 42 U.S.c. 2e et seq. ("Title VTT", and Title I of the Civil Rights Act of 1991,42 U.S.C, 1981 a, to correct unlawful employment practices on the basis of sex and retaliation and to provide appropriate relief to Gerardine Baugh, a former employee oft-mobile USA, Inc., ("Defendant". Plaintiff, the U.S. Equal Employment Opportunity Commission (the "Commission", contends that Defendant discriminated against Baugh because of her sex by failing to remedy and prevent sexual harassment and by retaliating against her for asserting her Title VII rights, all in violation of Title VII, JURISDICTION AND VENUE I. 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 76(f(1 and (3 and Section 77(e of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.c. 2e-."'.'.. -- <;;. \,'... ~, ;~

5( (1 and (3 and 2c"6(e, and Section 12 of the Civil Rights Act of 1991, 42 U.S.C. 198Ia. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the United States District Court for the Northern District oft1linois, 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 cnforcement of Title VII, and is expressly authorized to bring this action by Section 76( (1 and (3 and Section 77(e oftitie VIT, 42 U.S.C. 2e-5( (l and (3 and 2e-6(e. 4. At all relevant times, Defendant has continuously been and is now doing business in the State of Illinois and the City of Chicago and has continuously had at least fiftcen (15 employees. At all relevant times Defendant has had over 5 employees. 5. At all relevant times, Dcfendant has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 71(h, (g and (b of Title Vll, 42 U.S.C. 2e-(b, (g and (h. STATEMENT OF CLAIMS 6. More than thirty days prior to the institution oftbis lawsuit, Baugh (formerly known as Gerardine Novak filed charges of discrimination with the Commission alleging violations of Title VII by Defendant, or its predecessor. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. During 21 and 22 Defendant engaged in unlawful cmployment practices at its 2

~- facility in Chicago, Tllinois in violation of Sections 73(a(l and 74(a of Title Vll, 42 U,S.C. 2e-2(a(1 and 2e-3(a. These practices include discriminating against Baugh by failing to remedy and prevent sexual harassment against her in 21 and 22, and by retaliating against Baugh for having filed charges of discrimination with the Commission by terminating her on about September 25,22, 8. The effect of the practices complained of in paragraph seven above has been to deprive Baugh of equal employment opportunities and otherwise adversely affect her status as an employee because of her scx, and because she had filed charges of discrimination with the Commission. 9. The unlawful employment practices complained of in paragraph seven above were intentional. 1, The unlawful employment practices complained of in paragraph seven above were done with malice or with reckless indifference to Baugh's rederally protected rights. PRAYER FOR RELlEF WHEREFORE, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, S~Lcccssors, 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. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with it, from retaliating against any employee for participating in protected activity; C. Order Defendant to institute and carry out policies, practices, and programs which 3

.- provide equal employment opportunities for women, and which eradicate the erfects of its past and present unlawful employment practices; D. Order Defendant to make whole Baugh by providing appropriate back pay with pre-judgment interest, in amounts to be detenllined at trial, and other affinuative relief necessary to eradicate the effects of its unlawful employment practices; E. Order Defendant to make whole Baugh by providing compensation for past and future pecuniary losses resulting from her unlawful tenuination, including, but not limited to, job search expenses; F. Order Defendant to make whole Baugh by providing compensation for past and future non "pecuniary losses, including emotional pain, suffering, inconvenience, loss of enjoyment of life and humiliation; G. Order Defendant to pay Baugh punitive damages for its malicious ancvor reckless conduct, in amounts to be determined at trial; H. Order Defendant and its successors to provide training to its officers, managers and employees regarding sexual harassment and retaliation in the workplace; 1. Grant such further relief as the Court deems necessary and proper in the public interest; and 1. 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. 4

Respectfully submitted, Eric S. Dreiband General Counsel James Lee Deputy General Counsel Gwendolyn Young Reams Associate General Counsel EQUAL EMPLOYMENT OPPORTUNITY COMMISSION I,.fter;e;;; G<.>c\--q,., \JM ( if Rlw Gregory anour Supervisory Trial Attorney 1fdr- N&.i W\ Gordon Waldron Senior Trial Attorney EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 5 West Madison Street, Suite 28 Chicago, Illinois 6661 (312 353 7525 5