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California Legal Team

 
 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

  Plaintiff-Appellant,

 v.

 R&R VENTURES, INC.,

  Defendant-Appellee.

 _________________________________________________

  Appeal from the United States District Court
 for the District of Maryland
 _________________________________________________

 REPLY BRIEF OF THE EQUAL EMPLOYMENT
 OPPORTUNITY COMMISSION
 _________________________________________________

 INTRODUCTION

  The Commission alleges in this action that R&R Ventures
 violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e
 et seq., by subjecting Shelby Scott, Brandyn Potter, and other female
 employees of defendant's Severna Park Taco Bell restaurant to a sexually
 hostile work environment, and by retaliating against Scott and Potter for
 complaining about the harassment.  The district court granted defendant's
 motion for summary judgment, holding that the charges on which the suit
 was based were untimely; the evidence did not establish actionable sexual
 harassment; and the Commission failed to establish a causal connection
 between the complaints of harassment and the adverse employment actions
 taken.
  In our opening brief, we explained why each of these rulings was
  erroneous.  We pointed out that this government enforcement action
  can be based entirely on Scott's charge which was indisputably timely
  because it was filed only 106 days after the last alleged act of
  discrimination.  EEOC Br. at 24-26.  On the merits, we detailed the
  substantial evidence in the record that supports a finding that Scott,
  Potter, and other female employees were subjected to a sexually hostile
  work environment at the Severna Park Taco Bell for which the defendant
  is liable.  EEOC Br. at 27-37.  We also argued that the judgment may
  not be affirmed on the alternative ground advanced by defendant below
  - that R&R Ventures is not liable for the conduct of its manager Edwin
  Wheeler - because the evidence does not establish that the company
  took reasonable care to prevent and correct sexual harassment or that
  the victims unreasonably failed to take advantage of any corrective
  opportunities available.  EEOC Br. at 37-45.  Finally, we argued that
  there was sufficient evidence to support a finding that the defendant
  took adverse actions against Scott and Potter because they complained
  about Wheeler's sexual harassment.  EEOC Br. at 45-49.
  In its brief as appellee, R&R Ventures does not directly respond to
  most of the Commission's arguments.  For example, it does not dispute
  that Scott's charge was filed within the time prescribed by Title VII
  and that this action may be based entirely on that charge.  Instead,
  R&R Ventures raises another, equally baseless procedural objection -
  that Scott's charge was not served on R&R Ventures within ten days.
  On the merits, R&R Ventures at no point argues that no reasonable
  fact finder could have concluded that female employees were subjected
  to a hostile work environment at the Severna Park Taco Bell.  Instead,
  defendant simply ignores most of the evidence relied on by the Commission
  and points instead to other evidence, most of which is mischaracterized
  or taken out of context, which arguably supports its version of events.
  At best, this approach merely demonstrates that there are factual
  questions that cannot be decided on summary judgment.  Similarly, R&R
  Ventures argues it has established an affirmative defense to liability
  but ignores conflicting evidence as to whether it took reasonable steps
  to prevent and correct sexual harassment and whether the targets of
  Wheeler's conduct unreasonably failed to take advantage of defendant's
  corrective measures.  Except for denying in a footnote that there was
  retaliation, defendant also fails to respond to the Commission's argument
  that the district court erred in dismissing our retaliation claim.
  We submit this reply to respond to several new arguments raised by
  the defendant and to refocus the discussion on the issues raised by
  the Commission's appeal and the evidence supporting the Commission's
  arguments.

 ARGUMENT

  1.  The district court gave as one reason for dismissing this action that
  the charges on which it is based were not timely filed.  We argued that
  this was wrong because this action may be based entirely on Scott's
  charge, and Scott's charge was filed within the 300-day time limit
  imposed by � 706(e) of Title VII.  EEOC Br. at 24-26.  R&R Ventures
  does not dispute either of these propositions.  Instead, it raises a
  different procedural objection - that Scott's charge was not served
  on R&R Ventures within ten days as required by � 706(b) of Title VII.
  See R&R  Br. at 19-20.  This argument is both factually and legally
  meritless.
  First, as we pointed out in our opening brief, the record establishes
  that the Commission served the notice of Scott's charge on February 18,
  1997, eight days after it was filed on February 10, 1997.  See EEOC
  Br. at 25 & n.7 (citing II JA 1264-65 (EEOC Charge)).  R&R Ventures does
  not dispute that the record is as the Commission represents.  Instead,
  R&R Ventures criticizes the Commission for not specifically stating in
  district court that the February 10, 1997, date-stamp appears on the
  back of Scott's charge.<1>  See R&R Br. at 19.  In our brief opposing
  R&R Ventures' motion for summary judgment, however, we stated that
  the charge was received by the Commission on February 10, 1997, and
  cited Scott's charge.  See R. 23 (EEOC Opposition to Summary Judgment
  at 6).  Nothing more was required.  R&R Ventures also suggests that the
  date-stamp on the charge should be disregarded because the Commission
  did not provide "an affidavit or other sworn statement" attesting to
  its validity.  R&R Br. at 19-20.  No affidavit authenticating Scott's
  charge is required.  See Fed. R. Evid. 803 (8) & 901 (b)(7); see also
  Gilbrook v. City of Westminster, 177 F.3d 839, 858 (9th Cir. 1999)
  (court may presume that public records are authentic and trustworthy,
  and the burden of establishing otherwise falls on the opponent of
  the evidence, who must come forward with enough negative factors to
  persuade a court that a document should not be admitted).  Thus, the
  record establishes that the Commission served the notice of Scott's
  charge within ten days from the filing date.
  Moreover, even if there were a factual basis for R&R Ventures' argument
  that the charge was not served within ten days, that would not be a
  ground for dismissing this action.  The courts have uniformly held
  that the Commission's failure to serve notice within ten days is not
  a bar to suit absent bad faith or prejudice to the employer.  See EEOC
  v. Shell Oil Co., 466 U.S. 54, 66 n.16 (1984); EEOC v. U.S. Fidelity &
  Guaranty Co., 420 F. Supp. 244, 249-50 (D. Md. 1976), aff'd 538 F.2d
  324 (4th Cir. 1976) (10-day notice requirement not mandatory); EEOC
  v. Wayside World Corp., 646 F. Supp. 86, 88 (W.D. Va. 1986) (showing of
  "substantial" prejudice required to bar suit).  See also EEOC v. Airguide
  Corp., 539 F.2d 1038, 1042 (5th Cir. 1976) (clear showing of substantial
  prejudice required before suit will be barred); EEOC v. Burlington
  Northern, Inc., 644 F.2d 717, 720-21 (8th Cir. 1981) (untimely notice
  of charge not an absolute and automatic bar to an EEOC enforcement
  action).  R&R Ventures does not argue that it was prejudiced by the
  delay it asserts occurred in the service of Scott's charge, nor could
  it conceivably establish prejudice on the basis of such a short delay.
  See, e.g., U.S. Fidelity & Guaranty Co., 420 F. Supp. at 249-250 (claim
  was not barred where notice was served ten months after charge received
  where no prejudice was shown).  Accordingly, the Commission's action
  is properly based on Scott's timely-filed charge of discrimination.
  2.  In its opening brief, the Commission set out in detail the extensive
  evidence supporting each element of the claim that R&R Ventures violated
  Title VII by subjecting female employees at its Severna Park store
  to a sexually hostile work environment.  We argued that, contrary to
  the district court's ruling, this evidence is sufficient to support
  a jury verdict in the Commission's favor.  See EEOC Br. at 27-37.
  R&R Ventures does not directly respond to the Commission's argument;
  it makes no effort to demonstrate that the summary of the record in
  the Commission's brief is inaccurate or that the Commission misstates
  the elements of a hostile environment claim.  Instead, R&R Ventures
  offers an alternative version of events based on selective, and often
  misleading, citations to the record.  Then, ignoring the fact that
  this case was dismissed on summary judgment, R&R Ventures argues that
  its story is the more credible.  Even if R&R Ventures' summary of the
  facts were accurate, it would merely confirm that there are material
  issues of fact and summary judgment was inappropriate.  However, as
  we demonstrate below, R&R Ventures presents a distorted and misleading
  statement of the record.
  Although R&R Ventures acknowledges in its argument headings and statement
  of the standard of review that this is an appeal from a grant of summary
  judgment, it completely loses sight of that fact in its argument.
  It is important, therefore, to reiterate the correct standard
  of review.  Summary judgment is appropriate only if "'a reasonable
  trier of fact could draw only one conclusion from the evidence.'"
  Conner v. Schrader-Bridgeport Int'l, Inc., 2000 WL 1287904, at *8 (4th
  Cir. Sept. 13, 2000) (quoting Brown v. CSX Transp., Inc., 18 F.3d 245,
  248 (4th Cir. 1994)).  In reviewing a grant of summary judgment, a court
  must accept as true the evidence proffered by the non-moving party, and
  "[i]f, giving the non-movant the benefit of every legitimate inference in
  her favor, there was evidence upon which the jury could reasonably return
  a verdict for her, [the Court] must reverse the judgment below."  Id.
  In this case, therefore, the question on appeal is whether, crediting
  the Commission's evidence and drawing all legitimate inferences in
  the Commission's favor, a reasonable jury could find that Wheeler's
  harassment of female employees was sufficiently egregious to constitute
  unlawful sex discrimination.  We argued in our opening brief that the
  answer to that question is yes.  R&R Ventures' response entirely misses
  the point.
  First, R&R Ventures argues that no Title VII violation occurred because
  working for Wheeler was "an unpleasant and unrewarding experience,
  for both male and female employees."  R&R Br. at 23.  It supports this
  argument by citation to some evidence that Wheeler was at times verbally
  abusive to male employees.  However, R&R Ventures simply ignores the
  extensive evidence summarized in the Commission's opening brief that:
  Wheeler reserved inappropriate sexual and sexist comments and innuendo
  for female employees; Wheeler closely examined and commented on young
  female employees' bodies, often in front of others; Wheeler repeatedly
  asserted that women are stupid and less capable than men.  See EEOC
  Br. at 30-31 (citing record).  When this evidence is considered along
  with the evidence selectively cited by R&R Ventures, it is clear that
  there is sufficient evidence to support a finding that female employees
  were "exposed to disadvantageous terms or conditions of employment to
  which members of the other sex are not exposed."  Harris v. Forklift
  Sys., Inc., 510 U.S. 17, 25 (1993) (Ginsburg, J., concurring).
  Second, R&R Ventures asserts that the alleged harassment was not
  sufficiently severe or pervasive because "[n]one of the claimants
  could recall more than one or two incidents of alleged harassment
  . . . and none of those few incidents could be characterized as
  particularly offensive or egregious."  R&R Br. at 15.  In support of
  this assertion, R&R Ventures mischaracterizes several statements in the
  record and ignores substantial evidence to the contrary.  For example,
  R&R Ventures' statement that "Wheeler also occasionally made jokes and
  comments of an inappropriate (and sometimes sexual) nature" is flatly
  inconsistent with the record.  R&R Br. at 23.  Scott testified that
  Wheeler "constantly, every single day" told her "about how nice of a
  butt I had and how much guys would love to just spank me or how much I
  should try it," I JA 722 (Scott Dep. at 159), and that "at least once
  a day" when she bent over, Wheeler told her she was "giving him a cheap
  thrill" and "usually it was followed by something else, but every day it
  was different." I JA 697-98 (Scott Dep. at 134-35).  When asked about
  Wheeler's sexual comments during her deposition, Scott testified that
  "[t]here were many.  Just talking about sexual experiences, positions.
  He'd talk about anything."  I JA 700 (Scott Dep. at 137).
  Defendant also incorrectly represents that Potter "could recall only
  two specific incidents" of harassment -- that Wheeler had complained how
  long it had been since he had sex and that his girlfriend was bisexual.
  R&R Br. at 28 n.16.  Defendant misunderstands Potter's testimony.
  These two comments were examples of the types of sexual comments
  to which Wheeler subjected Potter whenever they worked together.
  Potter testified that Wheeler "would talk about his personal life to
  me and that included his sex life and inquiries into mine," went on to
  give the above comments as examples, and also stated "He'd make jokes,
  sexual jokes."  I JA 463 (Potter Dep. at 41).  When asked how often
  Wheeler made sexual comments and jokes, she replied: "Daily.  At least
  daily if not every other day."  I JA 562 (Potter Dep. at 140).  Thus, R&R
  Ventures' assertion that there is insufficient evidence that Wheeler's
  harassment of female employees was pervasive is contrary to the record.
  R&R Ventures also argues that the alleged harassment was not severe
  because there is "absolutely no evidence that Wheeler or any other R&R
  employee ever touched Scott, Potter or Wright; that he made any overt
  sexual proposition or physical threats toward them; or that any alleged
  conduct unreasonably interfered with their work performance."  R&R
  Br. at 26.  Once again, R&R Ventures simply ignores contrary evidence.
  Pedro McKee testified that Scott complained Wheeler "had touched her
  and that he used to brush up against her."  I JA 301 (McKee Dep. at 21).
  McKee also witnessed Wheeler hugging two female employees against their
  will.  I JA 299-300 (McKee Dep. at 19-20).  Scott's mother testified
  that she saw Wheeler touch a female employee's breast inappropriately.
  I JA 354 (Mooney Dep. at 39).  A jury could also view the evidence
  that Wheeler flirted with and "hit on" young female employees (I JA
  455-56, 463 (Potter Dep. at 33-34, 41); I JA 694 (Scott Dep. at 131)),
  and repeatedly asked Scott if she liked to be spanked, I JA 698, 722
  (Scott Dep. at 135, 159), as sexual propositions and physical threats.
  Furthermore, as the Commission emphasized in its opening brief,
  verbal harassment alone may constitute a hostile work environment.
  See Smith v. First Union Nat'l Bank, 202 F.3d 234, 242 (4th Cir. 2000).
  To be actionable, a harasser's conduct must alter the conditions of
  employment and make the job harder to do.  Harris, 510 U.S. at 25
  (Ginsburg, J., concurring).  There is no requirement that a victims'
  work performance suffer.  Id. (Scalia, J., concurring) (test is not
  whether work has been impaired, but whether working conditions have been
  discriminatorily altered).  Wheeler's behavior towards subordinate female
  employees half his age could certainly be assessed by a reasonable fact
  finder as "overtly sexist, grossly demeaning, or physically threatening
  in nature."  R&R Br. at 29 n.17 (comparing the instant case to Smith,
  202 F.3d at 243).
  R&R Ventures distorts the victims' testimony in an effort to show that
  they did not regard Wheeler's harassment as particularly upsetting.
  Again, the record belies this assertion.  For example, Scott never
  indicated that Wheeler's conduct "was not particularly upsetting."<2>
  R&R Br. at 4.  On the contrary, Scott testified that "I just didn't like
  it . . . I didn't like the sexual jokes . . . I didn't feel that it was
  appropriate," I JA 700 (Scott Dep. at 137), and that "the sexual jokes,
  the position jokes" and the way Wheeler talked about sex "offended me."
  I JA 702 (Scott Dep. at 139).<3>  Scott cried in response to Wheeler's
  conduct, I JA 748, 752 (Scott Dep. at 185, 189), and lost a significant
  amount weight to avoid drawing attention to her body.  I JA 788-91 (Scott
  Dep. at 225-28).  Potter testified that she was " absolutely petrified"
  and "terrified" of Wheeler, (I JA 484, 561 (Potter Dep. at 62, 139)),
  that "emotionally I was a wreck" and that she would cry every morning
  because she had to go to work and see Wheeler.  I JA 483 (Potter Dep. at
  61).  Contrary to defendant's assertion, Potter in no way "admitted that
  she never told Wheeler to stop telling jokes or making comments."  R&R
  Br. at 9.  Potter testified that she complained to Wheeler one of the
  times he commented about his bisexual girlfriend, and in response to
  her complaint, Wheeler became "really vicious overnight."  I JA 463-64
  (Potter Dep. at 41-42).  Eventually Potter no longer could tolerate
  working with him.  I JA 484-85 (Potter Dep. at 61-62).  This evidence and
  additional testimony cited in our opening brief, see EEOC Br. at 31-35,
  demonstrates that there is sufficient evidence for a jury to find that
  Wheeler's harassment altered the victims' conditions of employment.
  Defendant can argue its unique version of the facts to a jury, but its
  misleading assessment of the evidence only demonstrates why the district
  court erred in granting summary judgment.<4>
  3.  Although the district court did not address R&R Ventures' argument
  that it established the affirmative defense outlined in Burlington
  Indus. v. Ellerth, 524 U.S. 742 (1998) and Faragher v. City of Boca
  Raton, 524 U.S. 775 (1998), the Commission argued in its opening brief
  that this Court may not affirm on that basis because R&R Ventures failed
  to establish either prong of the defense.  We noted that R&R Ventures,
  as the party bearing the burden of proof on the issue, is entitled to
  summary judgment only if the evidence in the record compels a finding
  that it has met every element of the defense.  See EEOC Br. at 37-38.
  We argued that R&R Ventures failed to establish that it had an effective
  policy against sexual harassment because, as we explained at length,
  there is extensive evidence that its policy was not disseminated, was
  not the subject of employee training, and was ineffective on its face.
  EEOC Br. at 38-43 (citing to record).  In response, R&R Ventures once
  again merely gives its version of events and ignores all contrary
  evidence in the record.
  R&R Ventures argues that it took reasonable care to prevent sexual
  harassment by having and disseminating a sexual harassment policy and by
  investigating Scott's claim of sexual harassment and transferring Potter
  away from Wheeler when she complained.  See R&R Br. at 33-34.  However,
  R&R Ventures simply ignores the evidence set out in the Commission's
  opening brief detailing deficiencies in R&R Ventures' policies.  For
  example, R&R Ventures' Area Manager, who is now Director of Operations,
  testified that the company does not provide management employees with
  sexual harassment training, I JA 113 (Lee Dep. at 35), and that there
  is no procedure in place for handling sexual harassment complaints.
  I JA 97 (Lee Dep. at 19).  The policy fails to provide names or phone
  numbers of persons to contact if one is harassed; directs employees
  to report sexual harassment to their "immediate supervisor or above"
  but does not specify who "above" is; fails to instruct supervisors to
  report complaints to the appropriate company personnel; and fails to
  promise confidentiality or protection from retaliation.  See II JA 1263
  (Policy).
  Similarly, R&R Ventures asserts that, once it learned of Scott's
  complaints of harassment, it "took prompt and reasonable steps to
  investigate and deal with the situation."  R&R Br. at 35 (footnote
  omitted).  However, a jury could find that defendant's actions were
  far from adequate.  When Scott complained of Wheeler's behavior, Lee's
  wife<5> called several female employees to ask if they had experienced
  problems with Wheeler, but did not interview Scott or Wheeler, the two
  people most likely to have information relevant to Scott's allegations.
  I JA 153 (Lee Dep. at 73).  A fact finder could assess this response
  as inadequate.  See Amirmokri v. Baltimore Gas and Elec. Co., 60 F.3d
  1126, 1131-32 (4th Cir. 1995) (where employer interviewed harasser but
  failed to warn, reprimand, or counsel harasser, court determined that
  the investigation was "superficial" and fell "far short of that taken
  by other employers in harassment cases.").  Furthermore, contrary
  to the inference in R&R Ventures' brief (see R&R Br. at 35 & 42),
  it is undisputed that R&R Ventures did not fire Wheeler because of the
  allegations of sexual harassment.  Wheeler was fired because of poor job
  performance.  I JA 76 (Heller Dep. at 59).  Accordingly, his termination
  was not part of R&R Ventures' response to the sexual harassment problem.
  R&R Ventures' argument that Scott, Potter and Wright unreasonably
  failed to take advantage of opportunities to correct the problems
  caused by Wheeler is also based on selective and misleading citations
  to the record.  There is ample undisputed evidence that the victims of
  Wheeler's harassment repeatedly complained to supervisors and managers
  at R&R Ventures.  Although Wright did not formally complain, manager
  Mareia Waddy heard Wright complaining about Wheeler to other female
  employees and volunteered that that is how Wheeler is.  II JA 1235
  (Wright Dep. at 81).  Scott told every manager at the Taco Bell about
  Wheeler's inappropriate sexual behavior.  See I JA 747-48 (Scott Dep. at
  184-85); I JA 707, 801 (Scott Dep. at 144, 238); I JA 725, 733, 735-36,
  799-800 (Scott Dep. at 162, 170, 171, 172-73, 236-37); I JA 733, 734,
  800-801 (Scott Dep. at 169, 171, 237-38); I JA 732-33, 736, 799-800
  (Scott Dep. at 169-70, 173, 236-37).  Consistent with principles of
  agency, notice to a store manager empowered to act on complaints of
  harassment is imputed to the employer.  See, e.g., Breda v. Wolf Camera &
  Video, 222 F.3d 886, 889 (11th Cir. 2000) (defendant in co-worker sexual
  harassment case had actual notice of harassment because supervisor
  to whom victim complained had authority to handle complaints); Adler
  v. Wal-Mart Stores, Inc., 144 F.3d 664, 674 (10th Cir. 1998) (employer
  had actual notice of co-worker harassment where plaintiff complained
  to her maintenance manager and to her first-line supervisor).  Because
  Scott notified her immediate supervisor as defendant's policy instructs
  (II JA 1263), defendant cannot complain that it did not receive notice.
  See Breda, 222 F.3d at 890 ("employees of such companies [that instruct
  victims to notify store managers] need not be concerned with whether
  they pursued their complaints far enough up the company ladder").
  In any event, Scott's mother repeatedly left detailed messages with
  Mike Lee that female employees were being sexually harassed by Wheeler;
  these calls were not returned.  I JA 345, 368, 370-78 (Mooney Dep. at
  30, 53, 55-63).
  Notwithstanding Potter's uncontradicted testimony that it took her two
  weeks to obtain Mike Lee's phone number because no manager would give
  it to her (I JA 481-83, 521 (Potter Dep. at 59-61, 99)), R&R Ventures
  criticizes her for not complaining sooner and erroneously states
  that Potter never characterized Wheeler's behavior as sexually based.
  R&R Br. at 36.  Potter testified that when she met with Mike Lee and
  Dennis Heller, "I sat down and told them everything that I just told
  you.  That he, you know, sexually - made the sexual comments and jokes
  initially, that he was verbally assaulting me at this point, that he
  was making sexual jokes and comments to the other girls there, both in
  my presence and not in my presence because I felt . . . they needed to
  know that as well because I had been advised of Shelby Scott's filing a
  complaint and I felt that they needed to know that it was still going
  on."  I JA 479-80 (Potter Dep. at 57-58).  R&R Ventures also ignores
  evidence that Potter had previously complained to managers Tammy Hartley
  (see I JA 485-86, 489 (Potter Dep. at 63-64, 67)), and Mike McCarthy
  about Wheeler's sexually offensive behavior towards her and other
  female employees.  I JA 452 (Potter Dep. at 30).
  Accordingly, after the evidence is assessed in the light most favorable
  to the Commission, it is clear that the district court could not have
  resolved the affirmative defense in favor of defendant on summary
  judgment.
  4.  In our opening brief, we argued that the district court erred in
  dismissing our retaliation claim because there is sufficient evidence
  to support a finding that adverse actions against Scott and Potter,
  including Scott's suspension and the reduction of Potter's hours,
  were caused by their complaints that they were being sexually harassed.
  EEOC Br. at 45-49.  Defendant's only mention of this claim is a cryptic
  statement in a footnote that "[f]or the same reasons that the first
  prong of the affirmative defense [to liability for Wheeler's sexual
  harassment] is satisfied, the Commission's argument regarding the
  claimants' 'retaliation' claims must be rejected -- neither Wheeler
  nor R&R Ventures took any retaliatory employment action against Scott,
  Potter or Wright."  See R&R Br. at 33 n.19.  This conclusory statement
  without any citation to the record or to case law is a manifestly
  inadequate response to the Commission's arguments.  Accordingly, this
  Court should reverse the district court's grant of summary judgment on
  the retaliation claim.
  5.  R&R Ventures includes in its brief an argument that the Commission
  is not entitled to back pay, compensatory damages or punitive damages
  even if R&R Ventures violated Title VII.  These arguments concerning
  the specific forms of relief available should the Commission prevail
  are not properly before the Court.  The district court made no rulings
  on the relief issues briefed by R&R Ventures, so there are no district
  court rulings to review.  R&R Ventures' arguments do not provide an
  alternative basis for affirming the judgment since R&R Ventures does not
  argue that the Commission would be entitled to no relief if it prevails.
  For example, R&R Ventures makes no argument that the Commission could
  not obtain injunctive relief if it proves that the company tolerated
  severe and pervasive harassment of female employees despite numerous
  complaints, as the Commission alleges in this action.  The relief issues
  raised by R&R Ventures should be left for the district court to address
  on remand or for a jury to address at trial.

 CONCLUSION

  For the foregoing reasons, the judgment of the district court should
  be reversed and the case remanded for further proceedings.

 Respectfully submitted,

       C. GREGORY STEWART
       General Counsel

       PHILIP B. SKLOVER
       Associate General Counsel

       VINCENT J. BLACKWOOD
       Assistant General Counsel




        ___________________________________
          JULIE L. GANTZ
       Attorney
       U.S. EQUAL EMPLOYMENT
 OPPORTUNITY COMMISSION
       1801 L Street, N.W.
       Washington, D.C. 20507
                               (202) 663-4718

 October 6, 2000

 CERTIFICATE OF COMPLIANCE

  Pursuant to FRAP 32(a)(7)(C), I certify that this brief has been
  prepared in monospaced (nonproportionally spaced) typeface using Corel
  Word Perfect 8, Courier New 12-point font, and the textual portion
  contains 4849 words.  I understand that a material misrepresentation
  in completing this certificate can result in the Court's striking the
  brief and imposing sanctions.  If the Court so directs, I will provide
  an electronic version of the brief and/or a copy of the word or line
  print-out.



 _________________________
 Julie L. GantzCERTIFICATE OF SERVICE

  I hereby certify that two copies of the foregoing brief have been mailed
  first class, postage prepaid, to:
 Paul J. Weber
 HYATT & PETERS
 1919 West Street
 Box 1852
 Annapolis, MD 21404-1852




 ____________________________
 Julie L. Gantz, Esq.

 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
 1801 L Street, N.W.
 Washington, D.C. 20507


 October 6, 2000


 1  Defendant also argues that the Commission received Scott's charge
 on January 27, 1997, not on February 10th, citing a computer-generated
 EEOC intake report.  R&R  Br. at 20.  This document is an intake record
 indicating the date Scott came to the Commission's office to pick up a
 charge form and meet with an intake officer.  II JA 1344.  Scott did not
 sign her charge until February 2, 1997, see II JA 1264, and the Commission
 received the signed charge on February 10, 1997.  II JA 1265.

 2  R&R Ventures uses ellipses to misleadingly alter Scott's testimony.
 R&R Ventures quotes Scott as testifying that Wheeler's conduct was "not
 . . . bad."  See R&R Br. at 4 n.3.  Scott, in fact, stated that Wheeler's
 comments about sex were "not as bad in June." I JA 701 (Scott Dep. at
 138).


 3  While Scott characterized Wheeler's comments at one point in her
 deposition as "little stuff," more often she made clear that his behavior
 was upsetting.  See I JA 694 (Scott Dep. at 131) ("it's just something I
 was not used to and something that I did not appreciate"); I JA 695-96
 (Scott Dep. at 132-33) (as example of comments she did not like, she
 stated "he was constantly, constantly making comments about my butt");
 I JA 696 (Scott Dep. at 133 ("Nobody else talked about my butt.  And if
 they would have, I would have just - especially if it would have been
 a younger guy, I probably would have smacked him.").

 4 Defendant argues that the Commission relies "heavily" on the testimony
 of Lia Green Mack, Misti Sevier, Pedro McKee, and LaDonna Mooney and
 argues that such evidence "has no bearing on whether Scott, Potter
 and/or Wright, themselves, were subjected to an actionable hostile work
 environment while working under Wheeler's supervision at the Severna
 Park store." R&R Br. at 27.  First, in our opening brief, the Commission
 briefly referred to the testimony of Mack and Sevier as evidence that the
 defendant's sexual harassment policy is ineffective.  See EEOC Br. at
 42-44.  Second, both McKee and Mooney are valid witnesses to the work
 environment at the Severna Park Taco Bell during the relevant time period.
 McKee was Scott's and Wright's co-worker at the Severna Park Taco Bell and
 witnessed Wheeler's sexually inappropriate behavior and sexist comments,
 I JA 299, 307-08 (McKee Dep. at 19, 27, 28) and served as a confidante
 to Scott.  I JA 301 (McKee Dep. at 21).  Mooney frequently visited
 her daughter at work, I JA 337-38, 349 (Mooney Dep. at 22-23, 34);
 witnessed Wheeler's inappropriate treatment of female employees, I JA
 351, 354 (Mooney Dep. at 36, 39); listened to her daughter's complaints
 about Wheeler's sexual comments, I JA 395-96 (Mooney Dep. at 80-81);
 and attempted to intervene on her daughter's behalf by informing R&R
 Ventures' management of the problem.  I JA 345, 368, 370-78 (Mooney
 Dep. at 30, 53, 55-63).  McKee's and Mooney's testimony corroborates
 that of the victims, and certainly bears on whether they were subjected
 to a hostile work environment.

 5  Defendant incorrectly states that Mike Lee testified that he
 interviewed employees with his wife as part of this "investigation."
 R&R Br. at 35 n. 20.  Only Mike Lee's wife conducted these interviews,
 and they were by phone and not in person.  See I JA 149-52 (Lee Dep. at
 71-74).

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