Case 1:09-cv-01652-PLF Document 9-1 Filed 08/11/10 Page 1 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

THERESA PAPADEMETRIOU,
Plaintiff,

v. Civil Action No. 09-1652 (PLF)

JAMES H. BILLINGTON, )
LIBRARIAN OF CONGRESS, 1
Defendant. )

OFFER OF JUDGMENT

Pursuant to Federal Rule of Civil Procedure 68, Defendant, James H. Billington,

Librarian of Congress, offers to allow judgment to be taken against him by Plaintiff, Theresa

Papademetriou, as follows:

1. Defendant shall, subject to the terms and conditions set forth herein, pay Plaintiff the

amount of two hundred fifty thousand dollars ($250,000) in full and final satisfaction of all of

Plaintiffs claims in this lawsuit, including without limitation Plaintiffs claims for damages and

for attorney's fees, costs and other litigation expenses incurred to the date of this offer, as

indicated below, that might be recoverable against Defendant in this action, which arises under

Title VII of the Civil Rights Act of 1964,42 U.S.C. $2000e, el seq. See Marek v. Chesny, 473

U.S. 1 (1985)(defendants not liable for attorneys fees and other costs incurred by plaintiff after

defendants' pretrial offer of settlement, where plaintiff recovered judgment less than offer).

2. Defendant offers judgment solely for the purposes of compromising disputed claims

without further legal proceedings and avoiding the risks and expenses of litigation. Therefore,

this Offer of Judgment is not intended and shall not be deemed an admission by Defendant of the

merit or lack of merit of Plaintiffs claims. Without limiting the generality of the foregoing, this
 Case 1:09-cv-01652-PLF Document 9-1 Filed 08/11/10 Page 2 of 3

Offer of Judgment does not constitute, and shall not be construed as, an admission of any

contested fact alleged byplaintiff in connection with this matter.

3. This Offer of Judgment will be deemed withdrawn if not accepted within the 14-day

period of time provided by Rule 68, and will not be used as evidence or otherwise in any other

pending or future civil or administrative action against Defendant, the United States, any current

of former officer, employee, or agent of Defendant, or any other agency or instrumentality of the

United States, except in an action to enforce this Offer of Judgment.

Offer Dated: August 2,2010

Respecthlly submitted,

RONALD C. MACHEN JR., D.C. Bar # 447889

United States Attorney
for the District of Columbia

RUDOLPH CONTRERAS, D.C. Bar # 434122

Chief, Civil Division

By: Is/
JULIA K. ~ o U D S
Special Assistant United States Attorney
555 4th Street, N.W.
Washington, D.C. 20530
(202) 707-7198
jdou@loc.~ov
 Case 1:09-cv-01652-PLF Document 9-1 Filed 08/11/10 Page 3 of 3

CERTIFICATE OF SERVICE

I certify that, on this 2nddayof August, 2010, I caused the foregoing Offer of Judgment to

be served upon counsel for Plaintiff by first class mail, postage prepaid, at his address of record

in this case: -~L

\

Bruce A. Frederickson
Webster, Fredrickson, Correia & Puth, PLLC
1775 K Street, Suite 600
Washington, D.C. 20006

and by electronic mail addressed to Bfiedrickson@WFCPLaw.com and by facsimile at (202)

Special Assistant United States Attorney