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CONSENT DECREE
Civil Action No. 05-03979-HRL
Page 1
WILLIAM R. TAMAYO – #084965 (CA)
JONATHAN T. PECK -- #12303 (VA)
EVANGELINA FIERRO HERNANDEZ -- #168879 (CA)
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
San Francisco District Office
350 The Embarcadero, Suite 500
San Francisco, California 94105
Telephone:
(415) 625-5622
Facsimile:
(415) 625-5657
Attorneys for Plaintiff Equal Employment Opportunity Commission
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,
Plaintiff,
v.
BORLAND SOFTWARE CORP.,
Defendant.
_______________________________________
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Civil Action No. 05-3979 HRL
CONSENT DECREE
Plaintiff U.S. Equal employment Opportunity Commission (“Commission” or
“EEOC”) brought this lawsuit under the Equal Pay Act of 1963 (“EPA”), Title VII of the
Civil Rights Act of 1964, as amended (“Title VII”), and Section 102 of the Civil Rights Act
of 1991, to correct alleged unlawful employment practices on the basis of sex, national
origin and race and to make whole Ms. Tuyen Tran who alleges that she is aggrieved by
the unlawful practices. Plaintiff alleged that defendant Borland Software Corporation
(hereinafter “Borland”) unlawfully paid Ms. Tran less than its male employees were paid
for performing substantially equal work and otherwise discriminated against Ms. Tran
because of her sex, national origin and/or race.
Case 5:05-cv-03979-HRL Document 7 Filed 10/19/2005 Page 1 of 8
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CONSENT DECREE
Civil Action No. 05-03979-HRL
Page 2
Borland denies these allegations. Borland believes that Ms. Tran, a current
Borland employee, is and was fairly and lawfu