On December 13, 2001, one current and nine former female agents and supervisors of defendant filed a lawsuit against defendant under Title VII of the Civil Rights Act of 1964 in the U.S. District Court for the Northern District of Illinois, Chicago Branch. The plaintiffs, represented by private counsel, asked the court for monetary and injunctive relief, alleging that they had been discriminated by defendant in, inter alia, promotions, training, compensensation, hours, transfers and job assignments based on sex. The Complaint further alleged a pattern or practice of gender-based harassment at defendant as well as a hostile work environment.

The case was assigned to Judge James H. Alesia. On February 5, 2002, Judge Alesia concluded that joinder of the plaintiffs was improper under Fed. R. Civ. P. 20 and dismissed plaintiffs' complaint without prejudice.

On February 26,counsel for plaintiffs filed an Amended Complaint, naming Ms. Radmanovich as the sole class representative. In addition, plaintiffs' counsel filed nine additional cases on behalf of the other plaintiffs who were originally named in the action.

Eight of the nine additional suits were brought as individual actions, while one of them, the Palmer action (EE-IL-0284) was filed as another putative class action.

On May 1, 2003, the plaintiff filed a motion for class certification. However, on June 26, 2003, Judge Alesia denied the motion on the ground that the proposed class would be "totally unmanageable."

In November, 2003, the parties agreed to mediation in an effort to settle all of the pending cases. On March 3, 2004, the mediator proposed that all of the foregoing cases be settled for a totla payment by defendant of $8.5 million. On March 12, 2004, the parties indicated that they would accept the mediator's proposal.

On January 12, 2005, the court (Judge James Zagel) approved the parties' settlement.

Kunyi Zhang - 11/24/2010


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