94-1229 Council File # ?9 4
Green Sheet # � �o2U
ORIGINAL R: SOLUTION
CITY OF S ' I T PAU ■ , MINNESOTA `7S
Presented By: li — _ d ; 91,;...
Referred To: Committee: Date
1 Whereas, eleven African — American fire fighters brou ht an action In Ramsey County District Court alleging racial
2 discrimination, and
3
4 Whereas, the plaintiffs have entered into a settleme agreement and release, and
5
6 Whereas, the settlement has been approved by the • Council, the Mayor and the City Attorney, and
7
8 Whereas, Council File 94 -785, adopted June 29, 19 4 called for a follow up resolution to amend the City budget, and
9
10 Whereas, the Mayor, pursuant to Section 10.07.1 an 10.07.04 of the City Charter, recommends the following changes to
11 the 1994 Adopted Budget for the City of Saint Paul:
12
13 CURRENT BUDGET CHANGES AMENDED BUDGET
14
15 GENERAL FUND FINANCING
16
17 FINANCING AMENDMENT:
18 Use of Undesignated Fund Balance
19 001 -00000 -9830 1,155,102 450,000 1,605,102
20 All Other Fund Financing 147,025,896 0 147,025,896
21 Total Fund Financing 148,180,998 450,000 148,630,998
22
23
24 GENERAL FUND SPENDING
25
26 TRANSFER FROM:
27 General Government Accounts 50,974
28 001- 09060 -0548 General Contingent Reserve 2,1490,90744 (40 ,000) 2, 1 500 ,974
29 001 - 09011 -0415 Fire Accounts
30
31 SPENDING AMENDMENT AND TRANSFER TO: 690,000
32 001- 09065 -0511 Judgment and Compromise, Se lements 0
33 Spending Amendment 450,000
34 Transfer To 240,000
35
36 All Other Fund Spending 145,578,948 145,578,948
37 Total Fund Spending 148,180,998 450,000 148,630,998
38
39 Total Amendment 450,000
40 Net Transfer 0
41
42 Now, therefore, be it resolved that the City Council dopts these changes to the 1994 budget.
Requested by Department of:
Yeas Nays Abse
Blakey Mayor's Office, Budget Section
Guerin
Grimm 6Za-
t
)
Harris By: 1 )p -. - 0 -75)/-.. /
Megard
,,
Kaltman
Thune C - A Recommended by Budget
r/ � . \
7 0 By: Ike. • r J ava
Adopted by Council: Date AUG `L 4
For Appro -d City Attorney:
Adoptio ertified by C• f cil
By: 6-C ,1 / L
Appro by Mayo for Sub issi to C until:
Approved by M • or h J "
I B
I
By: 9 s -' ,I., .. --- Saint Paul Budget Office ( Kline F:\ USERS\ BUDGET \123 \RESOLUTI \FIRESETL.WK1 8/1/94)
7:4)4PARiverrtornaticavtkost. DATE IFa11A1
Budget
v � 944 GREEN SNEET W. 8820
ACT PERSON & PNONE DEPARTMENT oi ®cnv comm. .
Joseph Reid 266 - 8553 . CITY ATTORNEY [J CCTV CLEW
c
ST SE ON COUNCIL AGENDA aY ( itTE) r dftecToR , T. SeltROES DMR
Jtme29 1994 ICJ MAYOR (NI ASSISTANT) ; Q
T • TAL tit OF SIGNATURE PAGES CLIP ALL. LOCATIONS FOR 88 iATUREj
TION REQUESTED
Adoption of the attar:ed Bilikent Rovisicatesointirm,wilkh pranides spinciingatithority for as appnved settleitnitt.
NIDATIONS: r
Approvs (A) or Reject (R) PEIII30.4ALZECIVICE CONTRACTS MUST ANSWER 'FOCL QUESTIONS:
(E4slain el es agars on marine ahem And attach to Quoit sheet.)
suettatlii (eve. sewn (* almation 1. Has the
prrineyrNttlwwMord tndara continettorthle
«:.
alb GOtrt nSE _ YES NO
STAB _ 2. fin nerson/lnmevsrbeenaany owiftse?
Om7RGTcO.$ T YES NO
to its macs Coon*. oananvar 3. Does thhopolsorVerm possess a sir. not mentally peMSesad by nrgr craaert Sty anstisyse
YES NO
TIRE PROBLEM, ISSUE, OPPORTUNITY (Who, What When, Whore, Why)
Ek vett African — American Ike fighters hired by the City betyroea 1975 aid 1984 brtsn actkm kr limey Canty *may lettittetS ICU of
racial cliseriednation ht violation of Statutes 363.03 aabd,1(2)(s) and (c). The s byttt 1p Attorney'ad }y Mayor
t
City Council. The aetti entcass for payments of tip to 11690,00Q
R E A T
AUG 9 7994
C I T Y TOR
RECD
ADVANTAGES IF APPROVED:
1Ls terms of the approveda iraenatMAbemet.
AUG 15 1994
E
- YOR'S OFFICE
@ 11DYANTAGES IF APPROVED:
• CStyspmdkgvrittrise.
Council Research Center
OilliSOYANTSGES IF NOT APPROVED:
Fakve to meet terns of an approved AUG 16
W AL AMOUNT OF TRANSACTION 8210,000 trawler and 5450,000 in additiend a s rity OOST/REVEIUB BUt {OIgci.E OP4 YES NO
_ . SOURCE cant reserve ftnel baleen:* and transfer ACTIVITY NUMBER *dew •
L. INFORMATION: (EXPLAIN)
•
q ' - f22q p
Council File # �/ ,7.5
ORIGINAL ,. _
Green Sheet # 22415
ESOLUTION r-p%/11-67)
_ TY)OF S i NT PAUL, MINNESOTA .1 z
�� 1
Presented By .� _ % ��.� !' . ...1. , ../ � �/ •
Referred T• 4
.rG,.. 't/�JG� Committee: Da ' e
1 WHEREAS, on May 6, 1992, leven African- American fire fighters brought an
2 action in Ramsey County District Co rt entitled "Robert Mems, Nathanial Davis, Byron
3 Brown, Steven Carlisle, Rodney Edw : rds, Lonnie Favors, Thurman Smith, James Fowler,
4 James Smith, Anthony Carter and D rrill Berry v. The City of St. Paul," File No. 92-
5 005227, alleging racial discriminatio
6
7 WHEREAS, the above-name. plaintiffs have entered into the attached
8 Settlement Agreement and Release;
9
10 RESOLVED, the City Counc' for the City of St. Paul hereby approves the
11 attached Settlement Agreement and • elease as settlement of plaintiffs' claims and
12 directs the proper City officials to p. to Reinhardt and Anderson, on behalf of the
13 above -named plaintiffs, the sums spe ified therein.
Z
r ,,�, / i �' / 1 .. _ .
4 -.mac -,
Yeah Nays Abs Requested by Department of:
Blakey ✓
Harris City Attorney
Grimm
Guerin _____0`
Megard � f --
Reitman /J
Th un e ✓ By: `. _"T k�, — �. ✓ i 4 -•ti ,✓
6 I
Form Approved by City Attorney
Adopted by Council: Date 1/4. ,,,,�_ .`q CkCLA
/ f ,'(../7/i".,/,' . ./
Adoption Certified by Council Secreta.y B ,,r ; .,
y:
By: c� .4-- Approved - Mayor for Su mission to
Coun
Approved by Mao Date
By: /(///// %l . i4 By By:
1/
755
DEPARTMENT/OFFICE /COUNCIL DATE INITIATED L I 1 2
City Attorney 6/21/94 GREEN SHEET N_ 22415
CONTACT PERSON 8. PHONE ^ INITIAUDATE INITIAUDATE —
I I DEPARTMENT DIRECTOR ® CITY COUNCIL
Timothy' E. Marx, 266 -8710 ASSIGN
NUMBEF FOR CITY ATTORNEY ED CITY CLERK
MUST BE ON COUNCIL AGENDA BY (DATE) ROUTIN4 a BUDGET DIRECTOR FIN. & MGT. SERVICES DIR.
ORDER l l l MAYOR (OR ASSISTANT)
ED
TOTAL # OF SIGNATURE PAGES (CLIP ALL LOCATIONS FOR SIGNATURE)
ACTION REOUESTED:
Settlement of the claims of Robert Mems, Nathanial Davis, Byron Brown, Steven Carlisle,
Rodney Edwards, Lonnie Favors, Thurman Smith, James Fowler,,• James Smith, Anthony
Carter and Darrill Berry.
RECOMMENDATIONS: Approve (A) or Reject (R) PERT ONAL SERVICE CONTRACTS MUST ANSWER THE FOLLOWING QUESTIONS:
PLANNING COMMISSION _ CIVIL SERVICE COMMISSION 1. Fes this person /firm ever worked under a contract for this department?
CIB COMMITTEE YES NO
2. Fes this person/firm ever been a city employee?
STAFF YES NO
_ DISTRICT COURT 3. Gies this person/firm possess a skill not normally possessed by any current city employee?
SUPPORTS WHICH COUNCIL OBJECTIVE? YES NO
Expl4In all yes answers on separate sheet and attach to green sheet
INITIATING PROBLEM, ISSUE, OPPORTUNITY (Who, What, When, Where, Why):
Eleven African- American fire fighters h :red by the City between 1975 and 1984 brought an
action in Ramsey County District Court against the City alleging various acts of racial
discrimination in violation of Minn. Stat. §363.03, subd. 1(2)(b) and (c). This office
recommends settlement of this matter in accord with the terms stated in the attached
Settlement Agreement and Release.
ADVANTAGES IF APPROVED:
Settlement of a complex lawsuit.
DISADVANTAGES IF APPROVED:
None
•
DISADVANTAGES IF NOT APPROVED:
Failure to settle a complex lawsuit.
TOTAL AMOUNT OF TRANSACTION $ Up to $690,000.00 COST /REVENUE BUDGETED (CIRCLE ONE) YES NO
FUNDING SOURCE Budget Amendment to Follbw ACTIVITY NUMBER
FINANCIAL INFORMATION: (EXPLAIN)
qz-/- /2-
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
DISCRIMINATION
Robert Mems, Nathanial Davis', Byron Court File: 92- 005227
Brown, Steven Carlisle, Rodney
Edwards, Lonnie Favors, Thurman Smith,
James Fowler, James Smith, Pdnthony
Carter and Darrill Berry,
Plaintiffs, SETTLEMENT AGREEMENT
vs. AND RELEASE
The City of St. Paul, Timothy K. Fuller,
Chief of Fire and Safety Services,
Defendants,
1. On May 6, 1992, Robert Mems, Nathanial Davis, Byron Brown,
Steven Carlisle, Rodney Edwards, Lonnie Favors, Thurman Smith,
James Fowler, James Smith, Anthony Carter and Darrill Berry
(hereinafter, "Plaintiffs ") _nitiated the above - entitled action in
Ramsey County District Court against the City of St. Paul
(hereinafter, "City ") and Timothy K. Fuller, Chief of Fire and
Safety Services, alleging various acts of racial discrimination in
violation of Minn. Stat. §363.03, Subd. 1(2)(b) and (c), and
comprising a hostile working environment, disparate treatment and
disparate impact.
2. The Defendants have duly filed their Answer in the above -
entitled action, admitting and denying the various allegations and
asserting various defenses against said claims.
1
78 '
3. On June 30, 1993, tie Honorable Joanne M. Smith, Judge of
Ramsey County District Cour , pursuant to a stipulation entered
into by the above -named p.rties, entered an order dismissing
Timothy K. Fuller from this action.
4. On August 12, 1993, the Honorable Joanne M. Smith, Judge
of Ramsey County District Co rt, pursuant to a Motion for Summary
Judgment brought by defendan City of St. Paul, entered an order
dismissing paragraphs 13K an. 13R of the Complaint, and striking
sections A -2, G -4, M -6, Q -7 and EE -18 of Plaintiffs' Answers to
Interrogatories and A -2 of P aintiff Steven Carlisle's Answers to
Interrogatories as it relate, to union activities. However, the
motion was, in all other r•spects, denied. On June 2, 1994,
Plaintiffs were granted lea by the Honorable Joanne M. Smith,
Judge of Ramsey County Distri t Court, to amend their Complaint to
include a demand for punitiv. damages
5. The remaining ciai and allegations are scheduled for
trial to begin on June 20, 199 before the Honorable Joanne Smith.
6. The Plaintiffs and t e City wish to settle and resolve all
outstanding disputes and ciai s between them which were or could be
asserted between them, to avo d the uncertainties of trial and the
costs associated therewith.
7. The City, for and on its behalf, together with all of its
present and former officers, agents and employees, agrees to pay
and does pay to the plaintiff- the sum of $440,000.00, said amount
to be paid to their attorney,'__ 4 - -_ , no later than
ninety (90) days after final .•proval of this Settlement Agreement
2
and Release, which sum is tlo be distributed by him to plaintiffs
according to the proportions upon which they agree.
8. Subject to verification by the City, the City further
gan14,1wd>t ; Avv usan
agrees to pay to plaintiffs' attorney, _ • • __ _: -, up o,
and no more than, $200,000,00 attorney's fees and up to, and no
more than, $50,000.00 for costs and disbursements associated with
the prosecution of this action. Such fees, costs and disbursements
shall be paid to Attorney Af,derson no later than ninety (90) days
after he provides the verification required by the City.
9. Upon receipt from plaintiffs of information as to her
location, the City will, within thirty days, contact Ms. Jane
Elliott and arrange a mutual =y agreeable time for her to present to
its Fire and Safety Services Department diversity work force
management /cultural awareness training facilitated by her.
Contingent upon Ms. Elliott's availability, said training will be
completed by the end of the 1995 calendar year. Concomitant with
this training, the diversity training being done by Bob Oliver may
continue according to the tLmetables already established between
him and the City.
10. No later than January 1, 1995, the Chief of the St. Paul
Fire and Safety Services Department will name an Assistant Chief
who will be responsible primarily for the area of human relations.
This position shall be filled in the following manner: Within
thirty (30) days after the firial approval this Settlement Agreement
and Release, the Black Fire, Fighters United organization shall
submit to the Chief the names of three candidates for the Assistant
3
Chief position. From this, list the Fire Chief must select one
individual to fill said position. The salary for said candidate
will be commensurate with the starting salaries of the other
current assistant chiefs. [n the event that a vacancy occurs in
this Assistant Chief position prior to January 1, 1998, said
position shall be filled, aZd the salary shall be determined, in
the same manner as set forty.'; in this paragraph.
11. During the current term of Mayor Norm Coleman, all tests
for the position of Captain in the St. Paul Fire and Safety
Services Department shall consist of the following four parts, the
scores on each of which shall have equal weight: written, oral,
simulator and management /supervisory. The written portion of said
examination shall be based solely on the materials presented in the
courses mentioned in Paragraph 12 of this Settlement Agreement.
These tests shall be administered pursuant to the City of St. Paul
Personnel Rules. The Assistant Chief appointed pursuant to
paragraph 10 of this Settlement Agreement and Release shall have
the responsibility to coordinate the development and implementation
of this test with the Human Resources Department to ensure that
said tests are administered is set forth in this paragraph. Any
changes in this process shall be based on the recommendation of
said Assistant Chief.
12. Following the final approval of this Settlement Agreement
and Release, and prior to the administration of the next Captain's
examination, the City will make available to all fire personnel
training consisting of a basis and an advanced course designed to
4
7 �aa y
prepare candidates for the taking of said examination. These
courses shall be optional: The City shall offer additional
tutoring to any candidate wIo so requests it.
13. Because of concern :hat employee files contain invalid or
unfair complaints and or reprimands, the Assistant Chief appointed
pursuant to paragraph 10 of this Settlement Agreement and Release
shall have the authority tD review the personnel files of all
candidates who successfully pass the test for the position of
Captain and advise the Fire' Chief as to any legitimate concerns
relating to said files. Minor matters of questionable legitimacy
may be disregarded in the consideration of whether the candidates
will be appointed.
14. The Mayor of the City of St. Paul will, prior to hiring
any fire fighters pursuant to Rule 17(c) of the City of St. Paul
Personnel Rules, consult with representatives from the Black Fire
Fighters United organization; regarding the process to be used for
such hiring.
15. The City of St. Pau_ Fire and Safety Services Department
will, no later than June 30, 1995, begin the implementation of a
mentoring program for all new employees in said department. This
program will have as its emphasis protected -class employees. The
Chief of the Fire and Safety Cervices Department will determine the
program's structure, budget ald manner of implementation, provided
that the Assistant Chief appcinted pursuant to paragraph 10 shall
have the responsibility for making recommendations to the Chief
concerning such matters.
5
rq
16. No later than thir=y (30) days after the approval of this
Settlement Agreement and Release, the parties hereto, through their
attorneys, shall request of the Ramsey County District Court that
it enter an Order (attached . iereto) requiring the City to keep open
the list of individuals who pass the first Captain's test for the
City of St. Paul Fire and Safety Services Department given
subsequent to the signing of this Settlement Agreement and Release,
until everyone on that list has been hired, or until five (5) years
after said list is established, whichever occurs first. In the
event that said Order is challenged, or that the Court refuses to
sign said Order, the remair'der of this Settlement Agreement and
Release shall remain valid and enforceable. In the event that said
Order is challenged, there `will be a joint defense of the Order
undertaken by Counsel for the plaintiffs and by the City.
Plaintiffs will bear the expenses for their portion of said defense
and the City will bear the expenses for its portion of said
defense. The provisions contained in this paragraph shall not
apply to any subsequent Captain's Examination.
17. Plaintiffs and Defendant are entering into this settlement
not only to end this litigat:on but also to promote improved race
relations within the Saint Paul Fire and Safety Services Department
and throughout the City. Accgordingly, Plaintiffs agree that they
will in no way encourage, copperate with, or provide information
for, the
prosecution of any additional claims related to alleged
incidents of racial harassm=_nt involving the Saint Paul Fire
Department which may have occurred prior to the date of this
6
Settlement Agreement ( "Inci►ents "). Plaintiffs will instruct their
counsel to not use any info ation which is work - product and which
is the property of plaint''fs or subject to the attorney /client
privilege owed to plaintiff. for the purpose of prosecuting claims
related to any such alleged Incidents. Plaintiffs also agree that
all public statements mad =! concerning this litigation and this
Settlement will be made in the spirit of promoting improved race
relations within the Saint 'Paul Fire Department and the City.
18. In consideration of the payment of the sums specified
above, the receipt and sufficiency of which are hereby
acknowledged, together with he above - mentioned additional good and
valuable consideration, the plaintiffs do, on behalf of themselves,
their heirs, successors an. assigns, and each and all thereof,
hereby release, discharge a d acquit the City of St. Paul, all of
the City of St. Paul's pre.ent and former officers, agents and
employees, successors and as and each and all thereof, of and
from any and all manner o action or actions, suits, claims,
damages, judgments, levies and executions, whether known or
unknown, liquidated or unliq idated, fixed, contingent, direct or
indirect, which have as their basis a claim of racial
discrimination, which the •laintiffs, their heirs, executors,
administrators, successors a d assigns, ever had, have or claim to
have against the City of St. Paul, any of the City of St. Paul's
present or former officers, agents or employees, successors or
assigns, for, upon, or .y reason of any act of racial
discrimination occurring pr to the date of this Settlement
7
9 /) -
Agreement and Release.
19. The parties to or is Settlement Agreement and Release
hereby stipulate to the dis issal of the Plaintiffs' claims in the
above - entitled action with prejudice and on the merits and will
file with the Court a Stip lation of Dismissal with Prejudice in
the form attached hereto upo the final approval of this Settlement
Agreement and Release.
20. It is specifically nderstood and agreed that the payment
and acceptance of the consi.]- ration recited above is a full, final
and complete compromise set lement and satisfaction of all claims;
that the same does not constitute, and shall not be construed as,
any admission of liability .r fault whatsoever by the City of St.
Paul or any current or forme, employee of the City of St. Paul, and
that there are no cov:nants, . promises, undertakings or
understandings outside of t is Settlement Agreement and Release
other than as herein specifi ally set forth.
21. The undersigned covenant and agree not to bring suit
against the City of St. Paul or any officer or agent thereof, for
any claims released hereby. If the undersigned hereafter brings
any suit or claim against th- City of St. Paul, or any officer or
agent thereof, in breach hereof, the undersigned shall pay to the
City of St. Paul all da .ges caused thereby together with
reasonable attorneys' fees incurred in defending or otherwise
responding to said suit or c aim.
22. The undersigned, b execution hereof, state that this
Settlement Agreement and Rel -ase has been read and explained to
8
94/- /�a7
them by their respective legal counsel, that the undersigned
understand and fully agree :o each, all, and any provision hereof,
and acknowledge receipt of copy of this Settlement Agreement and
Release.
23. The Plaintiffs understand and agree that this Settlement
Agreement and Release is subject to the approval of the St. Paul
City Council.
PLAINTIFFS
Date: / 7-- 2 /f
Robert Mems
Subscribed and sworn to before me
this 17 day of AMA , >: ''^� ^^^ti- �^^^^�+^ ^,.•� ^���
�
17;3 LYNNEM KNUTSON
NOTARY PUBLIC -MI JhIESOTA
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Notar Public My Commission Expires Sept 4 )997
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Date:
Nathanial Davis
Subscribed and sworn to before me
this /7 day of Jc.M,C, , 1994
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My Commission Expires ; ; ;&ipt 4 1997
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Date: / QV ' /L//t 67, .► 1
•ames Smith -'
Subscribed and sworn to before me
this f 7Th day of JL{KL ; 1994.
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/i°= �a �.Y ���NE'vi 1(NUTSON NoPublic " �`" NOTARY PUBIC- MINNF.SOTA
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Steven Carlisle
Subscribed and sworn to before me
this /7 day of ,J/24C.0 , 1994.
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Subscrib and sworn l to before me
this �� , 1994 ,- : LYNNE M KNUTSCJ
`. ; 1 NOTARY PUBLIG•�AfNN' SCT;R
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Lo•n`ie Fa
Subscribed and sworn to before me
this / / day of 6 2U44...-4----r , 1994
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• Thurman Smith
Subscribed and sworn to before me
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this ft day of qt(4/a----- , 1994 tt A/WW.AA.,^AAAAAAAAAAAAAAANWANwo ;4
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Darrill Berry .G
Subscribed and sworn to before me
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day of • , 1994
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Byl Brown /
Subscribed and sworn to before me
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this // of _914A--C- 1994.
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7 ,J'ames Fowler Z
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Subscribed and sworn to befare me
this / 1 .f..14...-C__
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Date: Cam_ 77- • Anth Cila,47--
ny Carter
Subscribed and sworn to before me
this /7' day of 9U4t) , „Mr, •y�,ti�..�,�,•,,ti „o ..ti
1994.
LYNNE M. KNUTSON
NOTARY PUBLIC•MINH'7SOT,
4 RAMSEY COUN1
My Commission Expires Slept a 97
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ATTORNEY FOR PLAINTIFFS
i6)
Date: uw Z Ho(
Jeffrey R. Anders.
E -1000 First Nati• al Bank
332 Minnesota Street
St.�aul, MN 55101
DEFENDANT CITY OF ST. PAUL
AJJ f”
Date: .'
Norm Coleman
Mayor, City of St. Paul
Subscribed and sworn to before me
this / q day of 9e4t-C- , 1994
c,/(//////Z,6_ 771.{-4.1
NotarylPublic
ATTORNEY FOR DEFENDANT
� C
Date: /! 1 �i f� , ;` ) ///
Timothy E. Marx
City Attorney
James S. Tures
Assistant City Attorney
400 City Hall
St. Paul, MN 55102
12
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
DISCRIMINATION
Robert Mems, Nathanial Dav's, Byron Court File: 92- 005227
Brown, Steven Carlisle, Rooney
Edwards, Lonnie Favors, Th rman Smith,
James Fowler, James Smith,'•nthony
Carter and Darrill Berry,
P aintiffs, ORDER
vs.
The City of St. Paul, Timoo y K. Fuller,
Chief of Fire and Safety S= rvices,
D= fendants,
Pursuant to a Settleme t Agreement and Release entered into by
the above -named parties, an ■ attached hereto by reference, and the
request of the parties her o,
Based upon all the fil•s, records and proceedings herein, and
for the reasons set for h in the aforementioned Settlement
Agreement,
IT IS HEREBY ORDERED:
That the City of St Paul shall keep open the list of
individuals who pass the f rst test for the purpose of hiring or
promoting candidates to th. position of Captain in the St. Paul
Department of Fire and Safety Services given subsequent to the
signing of this Order for f ve (5) years or until everyone on that
list has been promoted.
Date:
Joanne Smith
Judge, Ramsey County District Court