Free Request for Oral Argument - District Court of Delaware - Delaware

_- ._ Case 1 :04-cv-01469-SLR Document 12-2 Filed 06/16/2005 Page 1 of 4
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(D¤l.Rw.I2/98}
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
s-in o limi L 'Bu gg.:

(Name ¤fPlam fforP nant; ) J__ G 4 __ 1 A B g
v. CIVIL ACTION N0.
(Nome of Defendant or Defendants)


1; This action is brought pursuant to Title VII cj me Civil Rights Act nf 1964, as amended. for
employment disorlmlnution. Jurisdiction exists by virtue of 42 U.S.CE. 520DDe-5. Equituble and other rel1e·l'uru also
sought under 42 U.S.C. €2000e-5(g).
2, P1¤i¤¤ifF r¢sid¤¤ M
(Strom Address)
mab Qlgllg gc; ge 13 *1 2 c
city) (County) ism; (zap cm)
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(Am Code) (Phone Nmnber)
3. Defendant vesicles ut, or its business is located at 5 Q Qg [ D Cl gg. Q
(Street Aucresel
g5u.\QgQ{L;; gg ng 11230
(City) (County) (State') (Zip Cade)
4. The diserinunatury conduct occupred in spnnection with pl¤intiH·"s employment at, or application to
be employed at, defendants place of bussiness
(D nd:m}'s Num l
1¤¤¤»¤»·
r etAddressl
iggggg (Pg;/ie m,c, Q5, Li'76l0
(City) (County} (Sum) (Zip Code)

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' - _ _ Case 1:04-cv-01469-SLR Document 12-2 Filed 06/16/2005 Page 2 of 4
5. The alleged discriminatory acts occurred on _L_ , ,
(Day) (Month) (Year)
6. The alleged discriminatory practice ’ is O jing; continuing.
7t Plaintifililed char es with the Department of Labor of the State of Delaware,
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(Agency) treet Address) (City)
~*¤e¤t¤t¤s
(¤ ly) (State) (Zip cena)
defenda.nt’s alleged discriminatory conduct on ___&___ , __L•L____ ,
(Day) lM¤tttlt) (Yarn')
8, Plaintiff Hled charges with the Equal Employment opportunity Commission ofthe United Status
regarding de·fenclant‘s alleged discriminatory conduct on· ___§______ , L , G 3
(Day) (Moana) (wu-i
9. The Equal Ernployrnent Opportunity Clcmmissmn issued the attached hloucg-gf-Bight-tg-§`i;e letter
which was received by plaintiff on , ___&____ , .
(Dill'} (Month) (Year)

10 The alleged discriminatory acts, in this suit, c0ncem‘
A. é Failure to employ plaintiff.
B. G Termination of plaintiff’s employment.
C. 5 Failure to promote piaiatifti
D. G Other acts (please specify below)
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at · _ _ _ Case 1 :04-cv-01469-SLR Document 12-2 Filed 06/16/2005 Page 3 of 4
11. Defcndanvs conduct ts discriminatory with respect to the following:
A. 1 Plaintlt't"s race
B. ¥· Plaintiffs color
C. O Plaintiffs sex
D. O Plaintiffs religion
E. U Plaintiffs national origin
12. A copy ofthe charges tiled with the Equal Employment Opportunity Commission is attached to this
complaint and is submitted as a brief statement of the facts of plaintiffs claim.
13. If relief is not granted. plaintiffs will be irrcparably denied rights secured by Title Vll ofthe N64
Civilkights Act, as amended.
14. Plaintiffs has no adequate remedy at law to redress the wrongs described ubova
THEREFORE, Plaintiff prays as follows: (Check appropriate Ictter(s))
A. § That all feeS. cost or security attendant to this litigation be hereby waived
B. U That the Court appoint legal counsel. [P PgC£I*N Le
C. O That the Court grantsuch relief as may be appropriate, including irtiunctive orders, alnniagcs.
· cost and attot·ney‘s fees
I declare under penalty ofperjury that tlic foregoing ls truo and correct.
Dated? I 6 H
(Signatg {F P|nintilT)
(Signature ofttddillotttil Pl:iinLi1T)

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Case 1 :04-cv-01469-SLR Document 12-2 Filed 06/16/2005 Page 4 of 4
ssoclrm isha (mms) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION at
NOTICE OF RIGHT TO SUE {ISSUED ON REQUEST!
To:Stsni'ord L. Burris From:_U. S. Equal Employment Opportunity- Commission
88 Karlyn Drive Philadelphia District 0Ecc
New Castle, DE l9720 21 South Sth Street — Suite 400
· i Philadelphia, PA 19106-2515
On behalf ofperron(.r) aggrieved whose identity is
[ l CONFIDENTIAL (29 CFR § 1601, 7(a)) `
V Charge No. EEOC Representative Telephone No.
l7€·2¤03-00419 (formerly l7C/*.300419) Legl Unit 215440-2828
· (See also the additional information mashed to rhisfor-rn.)
NOTICE TO THE PERSON AGGRIEVED:
Title VII of the Civil Rights Act of 1964 and/or the Americans with Disabilities Act (ADA): This is your Notice of Right to Sue, issued
under Title VII and/or the ADA based on the above·numbered charge. It has been issued at your request. Your lawsuit under Title VII
or the ADA must he tiled lntederal or, state court of your receipt of this Notice. Otherwise, your right to sue
based on this charge will be lost. .§The time limit for tiling suit based on a state claim may be different.)
( X ] More than 180 days have passed since the Bling of this charge.
[ ] Less than 180 days have passed since the tiling of this charge, hutI have determined that it is unlikely the EEOC
will be able to complete its administrative processing within 180 days irom the tiling of the charge.
[ X ] The EEOC is terminating its processing of this charge. _
[ ] The EEOC will continue to process this charger
Age Discrimination ln Employment Act (AJJEA): You may sue under the ADEA at any time frdm 60 days after thc charge was tiled
until 90 days mer you receive notice that we have completed action on the ·charge. In this regard, the paragraph marked below
applies to your casef
[ ] The EEOC is closing your case. Therefore, your lawsuit under the ADEA must be tiled in federal or state court
of your receipt of this Notice. Otherwise, your right tosue based on the abovemimibered charge
· — will be lost. ·
`_ [ ] The EEOC is continuing its handling of your ADEA case. However, if 60 days have passed since the ming of
your charge, you may tile suit in federal or state court under the ADBA at this time. .
Equal Pay Act (EPA): You already have the right to sue under the‘BPA (tiling an EEOC charge is not required.) EPA suits-mustbe
brought in federal or state court within 2 years (3 years for willful violations) of the alleged EPA underpayment. This means that
haokpay due for any violations that occurred more may g years (3 ygggs) before you file suit may not be collectible.
If you file suit based on this charge, please send a copy ofyour court complaint to this otiice.
· On behalf ofthe Commission
. _ £»7, 7/50*]
. - Enclosure(a) Marie M. Tomasso, District Director (Daze Mailed)
cer Richards Paving; Inc. I _ '
; · uni
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