This matter was instituted by
Equal Employment Opportunity Commission("Commission" or "Plaintiff or "EEOC"), an agency of the United States government, allegingthat Defendant, Professional Transit Management, Ltd. d/b/a Springs Transit (ProfessionalTransit Management), unlawfully discriminated against Andy Martinez and a class ofemployees and former employees on the basis of a hostile work environment based on color andrace (African American) and national origin (Hispanic, Asian) in violation of Title VII of theCivil Rights Act of 1964 (Title VII). Furthermore, the Commission alleges Defendant was awareof the hostile work environment and failed to take effective measures to stop it. Martinez hasintervened in this case and has made substantially the same allegations as the EEOC.Collectively, the EEOC, Defendant, and Martinez will be called "the Parties." Defendant hasdenied any liability for the claims as alleged.
The Parties, desire to settle this action by an appropriate Consent Decree ("Decree"), andagreements between Defendant and its present and former employees. The Parties agree to thejurisdiction of this Court over the Parties and the subject matter of this action, and agree to thepower of this Court to enter a Consent Decree enforceable against Defendant.
This Decree is final and binding upon the Parties as to the issues resolved, as well asupon their successors and assigns.
The Parties agree that this Consent Decree fairly resolves the issues alleged in thislawsuit, and constitutes a complete resolution of all of the Commission's claims of unlawfulemployment practices under Title VII arising from this litigation and the charges as follows:Ronnie Huery, Charge # 541-2006-01134; Harry Wallace, Charge #541-2006-01125; EliJackson, Charge#541-2006-00921; Andy Martinez Charges 541-2006-02256 and