Free Response to Order - District Court of Delaware - Delaware

Case 1 :05-cv-00915-KAJ Document 6 Filed 05/23/2006 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT May 22, 2006K jj
FOR THE DISTRICT OF DELAWARE
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0MAn Monars, ) CE
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PlaintiffQ ) rr ra
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‘ V. ) Civ. No. l:05—cv—915—KAJ
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AMAZONCOM, )
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Defendant, )
I. Omar Morris is a citizen of The State of Delaware residing at 36 Appleby Rd. New
Castle, Delaware 19720 `
2. The defendant is a company in The State of Delaware at 1 C enterpoint Blvd. New Castle,
Delaware 19720
3. From December 2004 to February 2005 the plaintiff worked for Amazoncom thru
Integrity Staffing Solutions Temporary Service.
4, The first week of January 2005 the plaintiff was promoted to become an Amazon.com
associate on February 5, 2005. This was brought to the plaintiff attention by the
Overnight Picking department manager. The plaintiff then had to go thru numerous tasks,
including a drug—screen, proof of diploma, and a background check the second week of
January. As the month of January pass the plaintiff continues to work in his department,
and also transferred to other departments to work in and learn how that area of the
facilitate function. At the end of the month, Amazoncom had a welcorne/ benefits
meeting for all new associates for the overnight shift, where Amazoncom provided
information about our benefits, position, and what they expected from us. At the meeting
it was about ten new overnight associates.
5. On Friday February 4, 2005 Amazon.c01n called the plaintiff at his residence to notify the
plaintiff not to come to work today and said to go to Integrity Staffing Solutions
Temporary Service on Monday February 7, 2005.
6. consequently on Saturday February 5, 2005 the plaintiff received a letter from
Comprehensive information Services, Inc. (CIS) a notice of adverse action based on a
consumer report or investigative consumer report required by § 61 5(a) of the fair credit
reporting act. The letter as read, "A1nazon.com has denied your application for
employment on the basis of information contained in a consumer report or investigative
consumer report (hereinafter "consumer report")". _
7. Therefore On February 7, 2005 the plaintiff first went to Integrity Staffing Solutions
Temporary Service, located in Newark, Delaware. The plaintiff was inform the consumer
report or investigative consumer report the plaintiff conducted showed the plaintiff
having several felonies, which would denied the eligibility for any human to work in the I
United States. Furthermore the plaintiff went to Delaware State Police Headquarters State
of Delaware State Bureau Of Identification located in Dover, Delaware. Where the

Case 1 :05-cv-00915-KAJ Document 6 Filed 05/23/2006 Page 2 of 2
l plaintiff requested a Personal Criminal History Background Check. At the same time the
plaintiff called Comprehensive Information Services, inc. to dispute the accuracy ofthe
information contained in the plaintiff consumer report. The plaintiff spoke to the General
Manager, Teresa Ward (Ext.4006) well as the President of the company, Robert Capwell
(Ext.4001).The plaintiff asked the Robert Capwell for a reinvestigation of the plaintiff
consumer report. Afterward the plaintiff returned to Integrity Staffing Solutions
Temporary Service to give them a copy ofthe plaintiff criminal history, the plaintiff also
went to Amazoncom to speak to Ellen Kuntzman and hand her a copy of the plaintiff
criminal history as well.
8. Nevertheless on February ll, 2005 the plaintiff mailed two certified letters, one to
Comprehensive Infomation Services, Inc. and one more to Amazoncom, containing a
letter disputing the accuracy ofthe information concerning the information contain in the
plaintiffs consumer report or investigative consumer report. In addition copies of the
plaintiffs criminal history Background check which the plaintiff obtained from the
Delaware State Police Headquarters State of Delaware State Bureau Of Identification.
9. On February 16, 2005 the plaintiff received a letter from Comprehensive Information
Services, Inc. revealing the Case #, Social Security, For Use By: Name, Company,
Reference, Position Applied For, date requested, date sent, turnaround time in work days,
number of sources verifying, information alert, Company/' Source and Type. A
reinvestigation of the plaintiff consumer report was also included. The reinvestigation
read Time Period (7 years). Results (Clear).
10. Through out the months of February and March the plaintiff would call Ellen Kuntzman
to speak to the human resource to ask the status coming back to work or the
reemployment of the plaintiff. The human resource told the plaintiff the manager that can
rehire the plaintiff was in Seattle and did not know when that can take place. l
ll. Therefore the plaintiff asked the court to award the plaintiff the amount of $l ,000,000.00.
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