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Page 1 1:06-cv-01318-MMM-JAG
#1
Page 1 of 10
E-FILED
Tuesday, 19 December, 2006 08:30:24 AM
Clerk, U.S. District Court, ILCD
DEC 1 8 2006
:..,,\
i ; ; j ';;A2&>. -,&, 2 ,:.I,. t (.iJ\JRiCENTRAL DISTRICT OF f l ,li,lNOIS
[ ?!,
. % . b ' , . 3
JOHN M. WATERS, Clerk
U.S. DISTRICT COURT
CENTRAL DISTRICT OF ILLINOISPage 2 1:06-cv-01318-MMM-JAG
#1
Page 2 of 10
OF ILLINOIS
---*"-.","---.--.--.---
C i t y , Oklahoma
-.-Dk%ahnma
.--i Docket or
cast
.....-.
...-
-.---
.,,-----
"',"-
---
--
-
number o f y w charge: 2 5 0 2CJ6
- 0 0 18.--2
4. Disposition (what was hfinial result of your clrarge):--
*w
-
O t h.....e".*'- r , I s s.......................
u e d a t Charging Party's
e w. q u e s t .
'.'.-."'....A.
---'""
.'C Attxn copies of all documents you possess relating to
ESPECIALLY YOUR mHT-'TO-SLE
the EEOC
LE'1"TER.Page 3 1:06-cv-01318-MMM-JAG
#1
Page 3 of 10
If your answkr is YES. describe each legal proceeding:
1. Parties to the previous legal proceeding:
PlaintiffCs)or ptitioncr(s)
2. Name of coud or agency:
3. Docket or casenmber:
4. Name of the judge or hearing officer:
5. Dis~ositionIfor cmm~le;Was the case dismissed?
Who v c k ? W& there an hppeal? Is thc appeal pending
or final?
6 . Date of beginning previous proceeding:
---
7. D m a f disposition of pmeeeditlg-
-Page 4 1:06-cv-01318-MMM-JAG
#1
Page 4 of 10
Have yx~
atinched sepmtc sheets regarding previous state. lo~aior federal lcgal
proce,eding (other than EEOC)?
C
111.
PAKI'IES TO YOUR PRO SE C'OMPLAMT OF EMPLOYMI3X D$SCRIMINA'I'lON
A.
Plaintiff(s)
-
1 . Your fufln,me Dr. S h i p h r a h Wi 1 l i ams-Evans
.-
2. Youraddress 1021 S . Quincy, G r e e n B a y
Wisconsin, 5 4 3 0 1
3. Names ilnd addresses of otlm plainlifYs, if any
(You shauid narm a&er plaintiffs only if they were
petitioners with you in a previous EEOC proceeding; or
else if EEOU began a previous proceeding on behalf nf
you and them): none
-.
(List: a separate sheet if necessary; label it clearly if so)
B,
Have you attached a separate sheet naming other piaintiffs?
(
S
YES
C. Defendant is) (You should nine here the frrsq-named respondent, or else its
successor. in the previous EEOC proweding brought by you or on your beklrlf):
1. Fufl name (individual or firm): The M e t h o d i s t Med i z l
C e n t e r of IllinoisPage 5 1:06-cv-01318-MMM-JAG
#1
Page 5 of 10
Page 5
2. Businessaddress: 4 1 5 S t . Mark Court, Peoria, IL
61603
3, Jab p s i tion (if individual)
4. Sraius as an entir)' (if defendant is a business firm):
Fx) Corporation
( ) Partnership
( ) Sole Proprietorship
( ) Other
(If you do not know ibis information, and you cannot find out by reasonable means, ask
the defendant for it. If the defendant will not tell you, leave this section blank.)
5. Names. business addresses, and job position or entity status of other
defendants, if any &ou should name additionat defendmts only if they were
named as respondents in a previous EEOC proceeding brought by you or
on your behalf): None
(Use a separate shed if necessary; label it dearly if so)
D, Have you attached a separate shect naming other
defendants?Page 6 1:06-cv-01318-MMM-JAG
#1
Page 6 of 10
Page 6
A. Were pu:
1 Kot hired?
Discharged?
( ) Suspended?
(
( j Demoted?
( ) Dcnied Promotion'?
( ) Denied Wage Increases?
( ) CMer (please specifja) ,_---
13.
State here as briefly, conciseiy and clearly as possible the essential facts of your
claim. 'fake time to organize your statement; you n a y use numbered paragraphs ifyou
find it helpful, include ptecisety how each defendant in this action is involved, Include
the names of other persons involved who are not defendants; give dates and place.
Concentrate on describing as ciearly and simp13 as possible the employment practice you
allege to be illegal, and how it discriminat4 against you. IT IS NOT W C E S S h R Y TO
MAKE LEGAL ARGU ENTS OR CITE ANY CASES OR STATUTES. ThB MOST
ClRCUMSTANCES, TIUS ONLY MAKES THE C L A M OF A L A W MORE
DIFFICULT TO LTNDERSTAND. AS MUCH AS POSSIBLE, LET THE FACTS
SPEAK FOR THEMSELVES.
See at tachmen t # 2
DO NOT FEEL COMPELLED TO USE ALL THE SPACE.
-Page 7 1:06-cv-01318-MMM-JAG
#1
Page 7 of 10
Page 7
V.
RELLEF YOU REQUEST
Check below what you want the court to do for you. You may make as many checks a:
you like.
('N
Should you prevail in this lawsuit, award you back pay.
( ) Should you prevail in this lawsuit, reinstate you in
your old position.
()(IShould you prevail in this lawsuit, award you certain
costs of suit (but not attorneys fees).
Vl.
JURY DEMAND
(xl4 YES
Signed this
15'd.l, day of
,20&
A D D R ~ % S : ~S
O. ~ ~
Quincy
G r e e n Bay, Wisconsin 54301Page 8 EEOC Form 161 (3198)
U.S.
EMPLOYMENT
1:06-cv-01318-MMM-JAG
# 1 LUIUAL
Page
of 10 OPPORTUNITY COMI....ISION
DISMISSAL
AND NOTICE
OF RIGHTS
To:
Shiphrah Williams-Evans
From:
6822 N. Parkwood Drive
Peoria, IL 61614
0
EEOC Charge No.
On behalf of person(s) aggrieved whose idenlily is
CONFIDENTIAL (29 CFR §.1601.7(a))
EEOC Represenlative
250-2006-00182
-
Oklahoma City Area Office 564
215 Dean A. McGee Avenue
Suite 524
Oklahoma Glty. OK 73102
Telephone No.
Kathy A. Nusz,
Investigator
(405) 231-5827
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
(
The facts alleged in the charge fall to state a claim under any of the statutes enforced by the EEOC.
0
Your allegations did not involve a disability as defined by the Americans With Disabilities Act.
(
The Respondent employs less than the required number of employees or is not otheMlise covered by the statutes.
0
0
)
Your charge was not timely filed with EEOC; in other words,you waited too long after the date@)of the alleged discrimination to file your
charge
Havins been given 30 days in which to respond, you failed to provide Information, failed to appear or be available for
inte~ewslconferences,or otherwise failed to cooperate to the extent that It was not posslble to resolve your charge.
While reasonable efforts were made to locate you. we were not able to do so.
You were given 30 days to accept a reasonable settlement offer that affords full relief for the harm you alleged.
0
The EEoC issues the fallowing determination: Based upon its investigation, the EEOC Is unable to mnclude that the information obtained
establishes violations of the statutes. This does not certify that the respondent is in compliance with the statutes. No finding is made as to
any other issues that might be construed as having been raised by this charge.
(
The EEOC has adopted the findings of the state or local fair employment practices agency that InvesUgated this charge.
other (bmfly state)
Issued at Charging Party's request
- NOTICE OF SUIT RIGHTS -
(See the additional information attached to thls f m . )
Tltle VII, the Americans with Disabilities Act, andlor the Age Discrirnlnatlon in Employment Act: This will be the only
notice of dismissal and of your right to sue that we will send you. You may file a lawsuit against the respondent(s) under
federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAYS of your receipt
o f this notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a state claim may
be different.)
Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 vears (3vears)
before you file suit may not be coilectible.
On behalf of the Commission
I
September 14, 2006
1
DO&
T. ~ t e v e n s Y
Donald R. Jackson
a:
METHODIST MEDICAL CENTER
415 St. Mark Court
Peoria, IL 61603
Attorney at Law
456 Fultorl Street, Suite 218
Peoria, ILL 61602
(Date Mailed)Page 9 1:06-cv-01318-MMM-JAG
#1
Page 9 of 10
Attachment #2, Page 6, paragraph IV. B.
In May, 2004, I was hired as Associate Dean of the Methodist College of Nursing. I was promoted
to ChancellorIDean of the Methodist College of Nursing and on October 2 1,2005, I was discharged
from that position. The reason given for my termination was failing to report an alleged
overpayment of $1 1,520.00 that I received for overload teaching duties. I believe that these charges
are false and in retaliation for my speaking out against discriminatory practices engaged in by The
Methodist Medical Center, Inc., (MMCI) the parent organization of the Methodist College of
Nursing. I believe that I was discharged because I complained to the College of Nursing Board
Chairperson about not being paid equally to other non-African-American executives at MMCI for
over a period of a year, and the unfair process utilized for my evaluation. I believe that I was treated
differently in the terms and conditions of my employment because of my race. I had complained to
human resources and to my superior about racist comments made to me, and about me, by nonAfiican-American staff members and harassment by senior administrative staK I believe that I was
discriminated against and terminated in retaliation for filing complaints with human resources
regarding discriminatory incidents committed by white staff officials and white students. I was
discriminated against due to my race in that white employees who were recommended to receive a
contract received written contracts with terms and conditions. The CEO ignored a vote by the
College Board, thereby exhibiting unfair business practices. When I was promoted to DeadCEO
of the College I did not receive an increase in compensation as other white employees who were
promoted within the Corporation. When I acknowledged my disability, I was ignored by HR, who
had acknowledged other white employees with disabilities to take leave and thereby have their
disabilities accommodated. I was harassed by white officials and reported it to the President and
Page 1 of 2Page 10 1:06-cv-01318-MMM-JAG
#1
Page 10 of 10
CEO and senior staff. On October 10, 2005, I requested to be placed on medical leave under the
terms and conditions of the Family Medical Leave Act and my request was ignored notwithstanding
the fact that the request was based on my personal medical needs as well as the need to care for my
son because of medical issues.
Page 2 of 2
PDF Page 1
PlainSite Cover Page
PDF Page 2
1:06-cv-01318-MMM-JAG
#1
Page 1 of 10
E-FILED
Tuesday, 19 December, 2006 08:30:24 AM
Clerk, U.S. District Court, ILCD
DEC 1 8 2006
:..,,\
i ; ; j ';;A2&>. -,&, 2 ,:.I,. t (.iJ\JRiCENTRAL DISTRICT OF f l ,li,lNOIS
[ ?!,
. % . b ' , . 3
JOHN M. WATERS, Clerk
U.S. DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
PDF Page 3
1:06-cv-01318-MMM-JAG
#1
Page 2 of 10
OF ILLINOIS
---*"-.","---.--.--.---
C i t y , Oklahoma
-.-Dk%ahnma
.--i Docket or
cast
.....-.
...-
-.---
.,,-----
"',"-
---
--
-
number o f y w charge: 2 5 0 2CJ6
- 0 0 18.--2
4. Disposition (what was hfinial result of your clrarge):--
*w
-
O t h.....e".*'- r , I s s.......................
u e d a t Charging Party's
e w. q u e s t .
'.'.-."'....A.
---'""
.'C Attxn copies of all documents you possess relating to
ESPECIALLY YOUR mHT-'TO-SLE
the EEOC
LE'1"TER.
PDF Page 4
1:06-cv-01318-MMM-JAG
#1
Page 3 of 10
If your answkr is YES. describe each legal proceeding:
1. Parties to the previous legal proceeding:
PlaintiffCs)or ptitioncr(s)
2. Name of coud or agency:
3. Docket or casenmber:
4. Name of the judge or hearing officer:
5. Dis~ositionIfor cmm~le;Was the case dismissed?
Who v c k ? W& there an hppeal? Is thc appeal pending
or final?
6 . Date of beginning previous proceeding:
---
7. D m a f disposition of pmeeeditlg-
-
PDF Page 5
1:06-cv-01318-MMM-JAG
#1
Page 4 of 10
Have yx~
atinched sepmtc sheets regarding previous state. lo~aior federal lcgal
proce,eding (other than EEOC)?
C
111.
PAKI'IES TO YOUR PRO SE C'OMPLAMT OF EMPLOYMI3X D$SCRIMINA'I'lON
A.
Plaintiff(s)
-
1 . Your fufln,me Dr. S h i p h r a h Wi 1 l i ams-Evans
.-
2. Youraddress 1021 S . Quincy, G r e e n B a y
Wisconsin, 5 4 3 0 1
3. Names ilnd addresses of otlm plainlifYs, if any
(You shauid narm a&er plaintiffs only if they were
petitioners with you in a previous EEOC proceeding; or
else if EEOU began a previous proceeding on behalf nf
you and them): none
-.
(List: a separate sheet if necessary; label it clearly if so)
B,
Have you attached a separate sheet naming other piaintiffs?
(
S
YES
C. Defendant is) (You should nine here the frrsq-named respondent, or else its
successor. in the previous EEOC proweding brought by you or on your beklrlf):
1. Fufl name (individual or firm): The M e t h o d i s t Med i z l
C e n t e r of Illinois
PDF Page 6
1:06-cv-01318-MMM-JAG
#1
Page 5 of 10
Page 5
2. Businessaddress: 4 1 5 S t . Mark Court, Peoria, IL
61603
3, Jab p s i tion (if individual)
4. Sraius as an entir)' (if defendant is a business firm):
Fx) Corporation
( ) Partnership
( ) Sole Proprietorship
( ) Other
(If you do not know ibis information, and you cannot find out by reasonable means, ask
the defendant for it. If the defendant will not tell you, leave this section blank.)
5. Names. business addresses, and job position or entity status of other
defendants, if any &ou should name additionat defendmts only if they were
named as respondents in a previous EEOC proceeding brought by you or
on your behalf): None
(Use a separate shed if necessary; label it dearly if so)
D, Have you attached a separate shect naming other
defendants?
PDF Page 7
1:06-cv-01318-MMM-JAG
#1
Page 6 of 10
Page 6
A. Were pu:
1 Kot hired?
Discharged?
( ) Suspended?
(
( j Demoted?
( ) Dcnied Promotion'?
( ) Denied Wage Increases?
( ) CMer (please specifja) ,_---
13.
State here as briefly, conciseiy and clearly as possible the essential facts of your
claim. 'fake time to organize your statement; you n a y use numbered paragraphs ifyou
find it helpful, include ptecisety how each defendant in this action is involved, Include
the names of other persons involved who are not defendants; give dates and place.
Concentrate on describing as ciearly and simp13 as possible the employment practice you
allege to be illegal, and how it discriminat4 against you. IT IS NOT W C E S S h R Y TO
MAKE LEGAL ARGU ENTS OR CITE ANY CASES OR STATUTES. ThB MOST
ClRCUMSTANCES, TIUS ONLY MAKES THE C L A M OF A L A W MORE
DIFFICULT TO LTNDERSTAND. AS MUCH AS POSSIBLE, LET THE FACTS
SPEAK FOR THEMSELVES.
See at tachmen t # 2
DO NOT FEEL COMPELLED TO USE ALL THE SPACE.
-
PDF Page 8
1:06-cv-01318-MMM-JAG
#1
Page 7 of 10
Page 7
V.
RELLEF YOU REQUEST
Check below what you want the court to do for you. You may make as many checks a:
you like.
('N
Should you prevail in this lawsuit, award you back pay.
( ) Should you prevail in this lawsuit, reinstate you in
your old position.
()(IShould you prevail in this lawsuit, award you certain
costs of suit (but not attorneys fees).
Vl.
JURY DEMAND
(xl4 YES
Signed this
15'd.l, day of
,20&
A D D R ~ % S : ~S
O. ~ ~
Quincy
G r e e n Bay, Wisconsin 54301
PDF Page 9
EEOC Form 161 (3198)
U.S.
EMPLOYMENT
1:06-cv-01318-MMM-JAG
# 1 LUIUAL
Page
8 of 10 OPPORTUNITY COMI....ISION
DISMISSAL
AND NOTICE
OF RIGHTS
To:
Shiphrah Williams-Evans
From:
6822 N. Parkwood Drive
Peoria, IL 61614
0
EEOC Charge No.
On behalf of person(s) aggrieved whose idenlily is
CONFIDENTIAL (29 CFR §.1601.7(a))
EEOC Represenlative
250-2006-00182
-
Oklahoma City Area Office 564
215 Dean A. McGee Avenue
Suite 524
Oklahoma Glty. OK 73102
Telephone No.
Kathy A. Nusz,
Investigator
(405) 231-5827
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
(
The facts alleged in the charge fall to state a claim under any of the statutes enforced by the EEOC.
0
Your allegations did not involve a disability as defined by the Americans With Disabilities Act.
(
The Respondent employs less than the required number of employees or is not otheMlise covered by the statutes.
0
0
)
Your charge was not timely filed with EEOC; in other words,you waited too long after the date@)of the alleged discrimination to file your
charge
Havins been given 30 days in which to respond, you failed to provide Information, failed to appear or be available for
inte~ewslconferences,or otherwise failed to cooperate to the extent that It was not posslble to resolve your charge.
While reasonable efforts were made to locate you. we were not able to do so.
You were given 30 days to accept a reasonable settlement offer that affords full relief for the harm you alleged.
0
The EEoC issues the fallowing determination: Based upon its investigation, the EEOC Is unable to mnclude that the information obtained
establishes violations of the statutes. This does not certify that the respondent is in compliance with the statutes. No finding is made as to
any other issues that might be construed as having been raised by this charge.
(
The EEOC has adopted the findings of the state or local fair employment practices agency that InvesUgated this charge.
other (bmfly state)
Issued at Charging Party's request
- NOTICE OF SUIT RIGHTS -
(See the additional information attached to thls f m . )
Tltle VII, the Americans with Disabilities Act, andlor the Age Discrirnlnatlon in Employment Act: This will be the only
notice of dismissal and of your right to sue that we will send you. You may file a lawsuit against the respondent(s) under
federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAYS of your receipt
o f this notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a state claim may
be different.)
Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 vears (3vears)
before you file suit may not be coilectible.
On behalf of the Commission
I
September 14, 2006
1
DO&
T. ~ t e v e n s Y
Donald R. Jackson
a:
METHODIST MEDICAL CENTER
415 St. Mark Court
Peoria, IL 61603
Attorney at Law
456 Fultorl Street, Suite 218
Peoria, ILL 61602
(Date Mailed)
PDF Page 10
1:06-cv-01318-MMM-JAG
#1
Page 9 of 10
Attachment #2, Page 6, paragraph IV. B.
In May, 2004, I was hired as Associate Dean of the Methodist College of Nursing. I was promoted
to ChancellorIDean of the Methodist College of Nursing and on October 2 1,2005, I was discharged
from that position. The reason given for my termination was failing to report an alleged
overpayment of $1 1,520.00 that I received for overload teaching duties. I believe that these charges
are false and in retaliation for my speaking out against discriminatory practices engaged in by The
Methodist Medical Center, Inc., (MMCI) the parent organization of the Methodist College of
Nursing. I believe that I was discharged because I complained to the College of Nursing Board
Chairperson about not being paid equally to other non-African-American executives at MMCI for
over a period of a year, and the unfair process utilized for my evaluation. I believe that I was treated
differently in the terms and conditions of my employment because of my race. I had complained to
human resources and to my superior about racist comments made to me, and about me, by nonAfiican-American staff members and harassment by senior administrative staK I believe that I was
discriminated against and terminated in retaliation for filing complaints with human resources
regarding discriminatory incidents committed by white staff officials and white students. I was
discriminated against due to my race in that white employees who were recommended to receive a
contract received written contracts with terms and conditions. The CEO ignored a vote by the
College Board, thereby exhibiting unfair business practices. When I was promoted to DeadCEO
of the College I did not receive an increase in compensation as other white employees who were
promoted within the Corporation. When I acknowledged my disability, I was ignored by HR, who
had acknowledged other white employees with disabilities to take leave and thereby have their
disabilities accommodated. I was harassed by white officials and reported it to the President and
Page 1 of 2
PDF Page 11
1:06-cv-01318-MMM-JAG
#1
Page 10 of 10
CEO and senior staff. On October 10, 2005, I requested to be placed on medical leave under the
terms and conditions of the Family Medical Leave Act and my request was ignored notwithstanding
the fact that the request was based on my personal medical needs as well as the need to care for my
son because of medical issues.
Page 2 of 2
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