Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1:04-cv-01450-JJF Document 30-27 Filed 10/31/2005 Page1 012

- ‘ 31/2005 Pa e 2 of2
Case 1 :04-cv-01450-JJF Document 30 27 Flléd 10/ 9
ENTER L.:-IARGEINUMBER
CHARGE OF DISCRIMINATION -
[I t=st=A O3/JI LID
rms mlm is arreneu ¤ me Priv Aa ¤r1e74 U EE¤¢ HCHLI DO|5_I
Delaware Department of Labor and EEOC
(State. or loci Agency, lf any}
NAME (Indicate Mr., Mrs,. Mn) HOME TELEPHONE N0. (Include Area Code)
Ms. Cassandra Johnson (302} 653-4192
STREET ADDRESS CITY. STATE AND ZIP CODE COUNTY
120 Locust St:. Smyrna, DE 19977 Kent
NAMED IS THE EMPLDYER, LABOR DRGAMIZATIDM, EMPLOYMENT AGENCY, APPRENTICESHIP DDMMITTEE, STATE on LOCAL
GOVERNMENT AGENCY WHO DISCRIMINATED AGAINST ME lfmon than one usr below.
luu•E No. or EIPLDYEES on ` TEl.EPt·lonE nutteen (Ind. Am Code)
S ams Club tl 6 3 3 0 nsseens 2 5+ (302} 678-4223
Smear ADDRESS c1TT,STATEAN¤ ZIP cope
1527 N. Dupont HWY. Dover, DE 19901
tm M W T *1
STREET ADDRESS CITY, STATE AND m CODE
L] nAcE [1 COLOR »¤ SEX [fl FIEIGIDM lj NATIONAL Dmcllt lj] AGE DATE mscmlnnnon TDDK PLACE
__ eannxssr 9!‘l 996
lj RETAl.lAT1otl Cl DISABILITY Elon-IEA {Smelly) mms: /Mr!/»l¤¤J Md
D CDIITIMJIHGACTIDN
THE FARHCULARS ARE llleddltlonel space is needed, attached utre shsetlslz -
l. I am a female individual who has been employed by Respondent since September 1998. I have worked as a Sales Associate
in the Tire Department at Respondents store #6330 for approximately 3 years. I am currently employed by Respondent;
howeverl am not paid the same as my male co-workers, even though I have more seniority than some of them.
ll. Respondent has given me various reasons for not paylng me equally or given me a merit raise.
lll. I believe Respondent ls in violation Title Vll ofthe Civil Rights Act of 1964, as amended. and the state of Delaware’s
Discrimination in Employment Act, as amended. because they are not paying me equally to my male co-worker s or have not
given me-a merit raise. I have been employed by Respondent ln the `llre Department for approximately 3 years, longer than
my Team Leader, Johnny Revis (male) and Tire Moumer, Memphis (last name unknown, male) but they are paid more than I
am. I have been employed by Respondent for T yeats, two years more than Tire Mounter, Nathan Gibson (male) however he
also is paid more than I am. I am expected to perform the same job duties of all the men but they are not expected to perform
my specific job duties-
"" n tl. mes a ` ` I " s e w T" 7 " 7 " T `
IB It I change my address or tsleplmne number and I ell cooperate fully
nlth them ln the procseslnpofmy charge In accordance with their
procedures. lseearoralflnn thetlhsvsreedths shove charge and tltetltle truetothebntuf
Itno · p . lrrforrnrtlon and belief.
I declare und r penalty of perjury that the loregol · ls true and correct. HGTARY -(’l’Jh¤n notazssary tomeet State and loca Requirements]
` A; . . 4.-uc] ' V
Dill SF- mn} Subscribed and sworn to before me this date (D . rnonth. md you
sspcrnnus mrvicus anmous ur mis runnnas casosrs no tusrncr esustz
nav mz
· Wal-llllart-Johnson
01271