Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
)
RONALD ADAMS,
) Northgate Place
)
Waldorf, MD 20602
)
)
Plaintiff,
)
)
v.
)
)
Civil Action No._____________
RAND CONSTRUCTION CORPORATION
) North Royal Street
)
Alexandria Virginia 22314
)
)
Defendant.
)
)
Serve Registered Agent:
)
Corporation Service Company
) Vermont Avenue, NW
)
Washington, DC 20005
)
__________________________________________ )
COMPLAINT
(Employment discrimination)
Plaintiff Ronald Adams, for his Complaint against the Defendant, Rand Construction
Corporation, hereby states as follows:
JURISDICTION AND VENUE.
This is an action for damages and equitable relief for race discrimination by the
Defendant in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §
2000e, et seq. (hereafter “Title VII”); 42 U.S.C. §§ 1981 and 1988; and the District of
Columbia Human Rights Act, D.C. Code §§ 2-1401.01, et seq. (hereafter “D.C.H.R.A.”).
This Court has jurisdiction under section 706(f)(3) of Title VII (42 U.S.C. § 2000e-5(f)(3)), U.S.C. §§ 1331 (federal question) and 1367 (supplemental). Venue lies in this judicial
district pursuant to 28 U.S.C. §§1391(a)(1), (a)(2).Page 2 Mr. Adams filed a timely charge with the U.S. Equal Employment Opportunity
Commission (“EEOC”) on June 14, 2006, alleging race discrimination by Rand Construction
Corporation (“Rand”) in connection with the termination of his employment as a laborer
employed by Rand on a construction project at 1627 K Street, NW, Washington DC. Upon
information and belief, and pursuant to a “work-sharing agreement,” Mr. Adams believes that
the EEOC filed Mr. Adams’ charge with the District of Columbia’s Office of Human Rights,
and that the OHR agreed to defer its investigation of the charge, pending investigation by the
EEOC. Thereafter, EEOC investigated Mr. Adams’ Charge of Discrimination. On July 19,, the EEOC issued a Notice of Right to Sue to Mr. Adams.
Thereafter, pursuant to D.C. Code § 2-1403.16 (a)(2007), Mr. Adams, by counsel,
notified the Office of Human Rights that he was withdrawing his claim from further
investigation by the agency and that he would pursue his claim against the Defendant under
the D.C. Human Rights Act in this Court.
PARTIES.
The Plaintiff, Ronald Adams resides at 3876 Northgate Place, Waldorf, MD,
..
Defendant, Rand Construction Corporation (“Rand”), is a general contractor in the
construction business with offices located at 1029 North Royal Street, Alexandria, VA,. At all times relevant to this complaint, Rand did and still does business in the District
of Columbia.
FACTUAL ALLEGATIONS.
Mr. Adams is an African-American and has worked as a Laborer since 1964. He is
and has been for many years a member of Laborers’ Local Union 657 or its predecessor. He
-2-Page 3 has been a Business Agent, Secretary/Treasurer, and Shop Steward of his Local. Mr. Adams
had not been terminated for any reason, other than lack of work, by any employer, until he
was terminated by Rand..
Mr. Adams began working for Rand on approximately March 1, 2006. From
March until May, Mr. Adams worked without incident for Rand on the construction project at K Street, NW, Washington DC, under the supervision of Mr. Mark Maple, Rand’s
General Superintendent, Mr. Mike Meek, Rand’s Superintendent. Sometime in May 2006,
Rand assigned a new Manager, Mr. Ron Thorpe, to assist Mr. Meek in supervising the
project..
Mr. Thorpe was rude and abusive to African-American and Hispanic employees,
including Mr. Adams, and he treated them differently than white employees..
On May 23, 2006, Mr. Thorpe started an argument with Mr. Adams over a
continuing, daily assigned duty that Mr. Adams had been performing without incident for
three months. During this argument, Mr. Thorpe threatened Mr. Adams saying, “I can fire
your nigger ass.”.
Soon after the argument ended, Mr. Thorpe was on an elevator with a pipe fitter,
Jason Moore, and said to Mr. Moore, “He thinks he can do whatever he wants” referring to
Mr. Adams, and “I’m going to get rid of that nigger.”. Later that day, Mr. Thorpe and Rand fired Mr. Adams.. At no time prior to his termination had Mr. Adams’ been disciplined for poor
performance while working at Rand.
-3-Page 4 12. As a consequence of the foregoing actions, Mr. Adams has suffered severe and
ongoing humiliation, embarrassment and indignity with his fellow Laborers’ union members
and officials.. As a consequence of Mr. Thorpe’s and Rand’s termination of Mr. Adams’
employment, Mr. Adams was unemployed from May 23, 2006 until July 24, 2006 and during
that period was unable to find other employment as a union laborer, despite diligent efforts to
find other employment. On July 24, 2006, Mr. Adams did find a new position as a union
Laborer with Cherry Hill Construction in Maryland, but he was earning about $3.00 less per
hour, due to the difference between union wages in Maryland and the District of Columbia.. In addition to his humiliation before his fellow union members and officers visited
on Mr. Adams by the actions of Mr. Thorpe and the Defendant, Mr. Adams also suffered
additional humiliation in the eyes of his wife, children, family and friends.. As a consequence of the foregoing, Mr. Adams has suffered financial difficulties,
mental distress and anxiety.
COUNT I
(Race discrimination in violation of Title VII). Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 15 as if set forth fully herein.. The Defendant terminated the employment of the Plaintiff because of his race,
African-American in violation of Title VII of the Civil Rights Act of 1964, as amended.. In taking the foregoing action, the Defendant acted with racial animus and
materially and adversely altered the terms, conditions, and privileges of Plaintiff’s
employment and caused Plaintiff lost wages and benefits, and damaged Plaintiff’s reputation
and standing with prospective employers, and his fellow union members and officers.
-4-Page 5 19. The action taken by the Defendant against the Plaintiff was carried out with racial
animus, knowledge that it was in violation of the law and with a malicious intent to injure the
Plaintiff.. The Defendant’s violation of Title VII caused the Plaintiff to sustain financial
damages in lost salary and future earnings, and other reasonably foreseeable consequential
damages incurred as a natural and proximate result of the Defendant’s termination of
Plaintiff’s employment.. As a consequence of the action of the Defendant, the Plaintiff has suffered severe
mental distress.
COUNT II
(Race discrimination in violation of the
District of Columbia Human Rights Act). Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 21 as if set forth fully herein.. The Defendant terminated the employment of the Plaintiff wholly or partially
because of his race, African-American, in violation of the District of Columbia Human Rights
Act.. In taking the foregoing action, Defendant acted with racial animus and materially
and adversely altered the terms, conditions, and privileges of Plaintiff’s employment and
caused Plaintiff lost wages and benefits, and damaged Plaintiff’s reputation and standing with
prospective employers, and his fellow union members and officers.. The Defendant’s violation of the DCHRA caused the Plaintiff to sustain financial
damages in lost salary and future earnings, and other reasonably foreseeable consequential
-5-Page 6 damages incurred as a natural and proximate result of the Defendant’s termination of
Plaintiff’s employment.. The Defendants’ violation of the DCHRA caused plaintiff to suffer non-pecuniary
injuries including emotional pain, embarrassment, humiliation, mental anguish, loss of
reputation, and loss of enjoyment of life.. The Defendant’s act of discharging Plaintiff was the result of racial animus,
egregious and taken in conscious disregard of or with deliberate indifference to Plaintiff’s
rights under the DCHRA, outrageously, wantonly, and oppressively; and with legal and actual
malice.
COUNT III
(Race Discrimination in Violation of 42 U.S.C. § 1981). Plaintiff repeats and realleges each and every allegation contained in paragraphs
1through 27 as if set forth fully herein.. The Defendant terminated the employment of the Plaintiff because of his race,
African-American, in violation of 42 U.S.C. § 1981. In taking the foregoing action, Defendant
materially and adversely violated Plaintiff’s right to make and enforce contracts in the same
manner as is enjoyed by white citizens and caused Plaintiff lost wages and benefits, and
damaged Plaintiff’s reputation and standing with prospective employers, and his fellow union
members and officers.. The Defendant’s termination of Plaintiff’s employment was carried out with racial
animus, knowledge that it was in violation of the law and with a malicious intent to injure the
Plaintiff.
-6-Page 7 31. The Defendant’s violation of 42 U.S.C. § 1981 caused the Plaintiff to sustain
financial damages in lost salary and future earnings, and other reasonably foreseeable
consequential damages incurred as a natural and proximate result of the Defendant’s
termination of Plaintiff’s employment.. As a consequence of Defendant’s termination of Plaintiff’s employment, the
Plaintiff has suffered severe mental distress.
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in his
favor and against the Defendants, declaring that the Defendants have violated his rights under
Title VII, 42 U.S.C. §§ 1981 and the D.C. Human Rights Act, and awarding him back pay,
compensatory and punitive damages, and attorneys fees and costs, and such other and further
relief as the Court may deem appropriate.
Dated: October 16, 2007
Respectfully submitted,
__/s/ DANIEL S. KOZMA___________
Daniel S. Kozma, Esq., D.C. Bar no. 940874
Suite 245 L Street, N.W.
Washington, D.C. 20037
DKOZLAW@AOL.COM-969-2223
Counsel for the Plaintiff
JURY DEMAND
Plaintiff hereby demands a trial by jury.
____/s/ DANIEL S. KOZMA________
Daniel S. Kozma
-7-Page 8 Joimev-ur 10388 From EEOC PIM JRGH PA +412 G44 2684 7-027 P 02/011
a Page 10
ceooremer only 8@ 1:07-Cv-0H 4 FaUAL eMADORMENTUPPGRTUNTHPE O17”
DISMISSAL AND NOTICE OF RIGHTS
f fue
To: Ronald L. Adams Northgete Piace
Waldorf, MD 20602
—
From: Pittsburgh Area Office Liberty Avenue
Suite 300
Pittsburgh, PA 16222
On behait of person(s) aggneved whose identity is
CONFIDENTIAL (29 CFR § 1601. 7(a})
EEOC Charge No. EEOC Representative Telephone No.
-2006-01352 Legal Unit {215) 440-2828
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
charge.
UO BOO O O00 0
Other (briefly state)
The facts alleged in the charge fail to state a claim under eny of the stetutes enforced by the EEOC.
Your aflegations did not involve a disability as defined by the Americans with Disabilities Act.
The Respondent employs less than the required number of employees or is not otherwise covered by the statutes.
You were given 30 days to accent a reasonable settiement offer that affords hall relief for the harm you alleged.
The EEOC iesues the following determination: Based upon its investigation. the EEOC is unable to conclude that the information obtained
establishes violations of the statutes. This does not certify that the reapondant is in compliance with the statutes. No finding is made as
to any other issues that might be construed as having been raised by this charge.
The EEOC has adopted the findings of the state or iocal fair employment practices agency that investigated this charge.
- NOTICE OF SUIT RIGHTS -
{See the additional information attached to this form.)
Your charge wes not timaly filed with EEOC: in other words, you waited too long after the date(s) of the allegad discrimination to file your
Having been given 30 days in which to respond, you failed to provide information, failed to appear of be availabia for
interviews/conferances. or otherwise failed to cooperate to the extent that it was not possibile to resolve your charge.
While reasonable efforts were made to locate you. we were not able to do so.
Title Vi, the Americans with Disabilities Act, and/or the Age Discrimination in Employment Act: This will be the only
notice of dismissal and of your right to sue that we will send you. You may file a lawsult against the respondent(s) under
federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAYS of your receipt
of this Notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a state claim may
be different.)
Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 years (3 years)
before you file suit may not be collectibie.
Enclosure(s)
cc: Rand Construction
On behalf of the Cornmission
Je) ype Laveen ODL 2 _
Joseph M._ Hardeman,
Area Director
Area Director
OF 18°74
FILED
OCT 17 2007
NANCY MAYER WHITTINGTON, CLERK
U.S. DISTRICT COURTPage 9 Case 1:07-cv-01874-RCL
=e
cVcer 6 OE TON
-DOGimEGiVER SHEET 10/17/2007
Page 1 of @47-/S7¥
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fenald Ams
(b) COUNTY OF RESIDENCE OF FIRST LISTED pLanmr __ 688°
(EXCEPT IN U.S. PLAINTIFF CASES)
ANTS
Hand Corstruttion, C OrPela tion
Serve | Corporation Service Com
COUNGY OF RESEOENGE OF FIRST LisTED perenne
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
TRACT OF LAND INVOLVED
O01 U.S. Government
Plaintiff
O 2 U.S, Government
Defendant
(c) ATTORNEY. NAME, ADDRESS, NUMBER)
The Law tice "of Daniel S.Ko?na — Dane 5: Koama
AAO L Street NW
ashiy lon ).C.. 20037
Hf. BASIS OF JURISDICTION
. (PLACE AN x IN ONE BOX ONLY)
O 3 Federal Question
(U.S. Government Not a Party)
(Povey
(Indicate Citizenship of Parties
in item IN)
Case: 1:07-cy-01 874
HII CITIZE
FOR PLAINTIFF AND UNB pUA run Dk aan vars use, ae .
PIF DFT PTF DFT
Citizen of this State Oo} oO} Incorporated or Principal Place O4 O4
of Business in This State
Citizen of Another State 2 Incorporated and Principal Place 0 5 os
of Business in Another State
Citizen or Subjectofa 03 03
Foreign Country Foreign Nation 06 06
Assigned To : Lamberth, Royce C.
Assign. Date : 10/17/2007
Description: Employ. Discrim.
Ss,
IV. CASE ASSIGNMENT AND NATURE OF SUIT |
(Place a X in one A-N, that best ts your cause of action and one in a corresponding Natare of Suit)
VIE. REQUESTED IN = CHECK IF THIS IS A CLASS DEMAND $ Check YES only if jw complaint
COMPLAINT o ACTION UNDER F.R.C.P. 23 JURY DEMAND? ofys ONO
f en
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IF ANY OYES ONO iff lease lete related case form.
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/ / ’ ~
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PlainSite Cover Page
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Case 1:07-cv-01874-RCL
Document 1
Filed 10/17/2007
Page 1 of 7
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
)
RONALD ADAMS,
)
3876 Northgate Place
)
Waldorf, MD 20602
)
)
Plaintiff,
)
)
v.
)
)
Civil Action No._____________
RAND CONSTRUCTION CORPORATION
)
1029 North Royal Street
)
Alexandria Virginia 22314
)
)
Defendant.
)
)
Serve Registered Agent:
)
Corporation Service Company
)
1090 Vermont Avenue, NW
)
Washington, DC 20005
)
__________________________________________ )
COMPLAINT
(Employment discrimination)
Plaintiff Ronald Adams, for his Complaint against the Defendant, Rand Construction
Corporation, hereby states as follows:
JURISDICTION AND VENUE
1.
This is an action for damages and equitable relief for race discrimination by the
Defendant in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §
2000e, et seq. (hereafter “Title VII”); 42 U.S.C. §§ 1981 and 1988; and the District of
Columbia Human Rights Act, D.C. Code §§ 2-1401.01, et seq. (hereafter “D.C.H.R.A.”).
This Court has jurisdiction under section 706(f)(3) of Title VII (42 U.S.C. § 2000e-5(f)(3)),
28 U.S.C. §§ 1331 (federal question) and 1367 (supplemental). Venue lies in this judicial
district pursuant to 28 U.S.C. §§1391(a)(1), (a)(2).
PDF Page 3
Case 1:07-cv-01874-RCL
2.
Document 1
Filed 10/17/2007
Page 2 of 7
Mr. Adams filed a timely charge with the U.S. Equal Employment Opportunity
Commission (“EEOC”) on June 14, 2006, alleging race discrimination by Rand Construction
Corporation (“Rand”) in connection with the termination of his employment as a laborer
employed by Rand on a construction project at 1627 K Street, NW, Washington DC. Upon
information and belief, and pursuant to a “work-sharing agreement,” Mr. Adams believes that
the EEOC filed Mr. Adams’ charge with the District of Columbia’s Office of Human Rights,
and that the OHR agreed to defer its investigation of the charge, pending investigation by the
EEOC. Thereafter, EEOC investigated Mr. Adams’ Charge of Discrimination. On July 19,
2007, the EEOC issued a Notice of Right to Sue to Mr. Adams.
Thereafter, pursuant to D.C. Code § 2-1403.16 (a)(2007), Mr. Adams, by counsel,
notified the Office of Human Rights that he was withdrawing his claim from further
investigation by the agency and that he would pursue his claim against the Defendant under
the D.C. Human Rights Act in this Court.
PARTIES
3.
The Plaintiff, Ronald Adams resides at 3876 Northgate Place, Waldorf, MD,
20602.
4.
Defendant, Rand Construction Corporation (“Rand”), is a general contractor in the
construction business with offices located at 1029 North Royal Street, Alexandria, VA,
22314. At all times relevant to this complaint, Rand did and still does business in the District
of Columbia.
FACTUAL ALLEGATIONS
5.
Mr. Adams is an African-American and has worked as a Laborer since 1964. He is
and has been for many years a member of Laborers’ Local Union 657 or its predecessor. He
-2-
PDF Page 4
Case 1:07-cv-01874-RCL
Document 1
Filed 10/17/2007
Page 3 of 7
has been a Business Agent, Secretary/Treasurer, and Shop Steward of his Local. Mr. Adams
had not been terminated for any reason, other than lack of work, by any employer, until he
was terminated by Rand.
6.
Mr. Adams began working for Rand on approximately March 1, 2006. From
March until May, Mr. Adams worked without incident for Rand on the construction project at
1627 K Street, NW, Washington DC, under the supervision of Mr. Mark Maple, Rand’s
General Superintendent, Mr. Mike Meek, Rand’s Superintendent. Sometime in May 2006,
Rand assigned a new Manager, Mr. Ron Thorpe, to assist Mr. Meek in supervising the
project.
7.
Mr. Thorpe was rude and abusive to African-American and Hispanic employees,
including Mr. Adams, and he treated them differently than white employees.
8.
On May 23, 2006, Mr. Thorpe started an argument with Mr. Adams over a
continuing, daily assigned duty that Mr. Adams had been performing without incident for
three months. During this argument, Mr. Thorpe threatened Mr. Adams saying, “I can fire
your nigger ass.”
9.
Soon after the argument ended, Mr. Thorpe was on an elevator with a pipe fitter,
Jason Moore, and said to Mr. Moore, “He thinks he can do whatever he wants” referring to
Mr. Adams, and “I’m going to get rid of that nigger.”
10. Later that day, Mr. Thorpe and Rand fired Mr. Adams.
11. At no time prior to his termination had Mr. Adams’ been disciplined for poor
performance while working at Rand.
-3-
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Document 1
Filed 10/17/2007
Page 4 of 7
12. As a consequence of the foregoing actions, Mr. Adams has suffered severe and
ongoing humiliation, embarrassment and indignity with his fellow Laborers’ union members
and officials.
13. As a consequence of Mr. Thorpe’s and Rand’s termination of Mr. Adams’
employment, Mr. Adams was unemployed from May 23, 2006 until July 24, 2006 and during
that period was unable to find other employment as a union laborer, despite diligent efforts to
find other employment. On July 24, 2006, Mr. Adams did find a new position as a union
Laborer with Cherry Hill Construction in Maryland, but he was earning about $3.00 less per
hour, due to the difference between union wages in Maryland and the District of Columbia.
14. In addition to his humiliation before his fellow union members and officers visited
on Mr. Adams by the actions of Mr. Thorpe and the Defendant, Mr. Adams also suffered
additional humiliation in the eyes of his wife, children, family and friends.
15. As a consequence of the foregoing, Mr. Adams has suffered financial difficulties,
mental distress and anxiety.
COUNT I
(Race discrimination in violation of Title VII)
16. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 15 as if set forth fully herein.
17. The Defendant terminated the employment of the Plaintiff because of his race,
African-American in violation of Title VII of the Civil Rights Act of 1964, as amended.
18. In taking the foregoing action, the Defendant acted with racial animus and
materially and adversely altered the terms, conditions, and privileges of Plaintiff’s
employment and caused Plaintiff lost wages and benefits, and damaged Plaintiff’s reputation
and standing with prospective employers, and his fellow union members and officers.
-4-
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Document 1
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Page 5 of 7
19. The action taken by the Defendant against the Plaintiff was carried out with racial
animus, knowledge that it was in violation of the law and with a malicious intent to injure the
Plaintiff.
20. The Defendant’s violation of Title VII caused the Plaintiff to sustain financial
damages in lost salary and future earnings, and other reasonably foreseeable consequential
damages incurred as a natural and proximate result of the Defendant’s termination of
Plaintiff’s employment.
21. As a consequence of the action of the Defendant, the Plaintiff has suffered severe
mental distress.
COUNT II
(Race discrimination in violation of the
District of Columbia Human Rights Act)
22. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 21 as if set forth fully herein.
23. The Defendant terminated the employment of the Plaintiff wholly or partially
because of his race, African-American, in violation of the District of Columbia Human Rights
Act.
24. In taking the foregoing action, Defendant acted with racial animus and materially
and adversely altered the terms, conditions, and privileges of Plaintiff’s employment and
caused Plaintiff lost wages and benefits, and damaged Plaintiff’s reputation and standing with
prospective employers, and his fellow union members and officers.
25. The Defendant’s violation of the DCHRA caused the Plaintiff to sustain financial
damages in lost salary and future earnings, and other reasonably foreseeable consequential
-5-
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Case 1:07-cv-01874-RCL
Document 1
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Page 6 of 7
damages incurred as a natural and proximate result of the Defendant’s termination of
Plaintiff’s employment.
26. The Defendants’ violation of the DCHRA caused plaintiff to suffer non-pecuniary
injuries including emotional pain, embarrassment, humiliation, mental anguish, loss of
reputation, and loss of enjoyment of life.
27. The Defendant’s act of discharging Plaintiff was the result of racial animus,
egregious and taken in conscious disregard of or with deliberate indifference to Plaintiff’s
rights under the DCHRA, outrageously, wantonly, and oppressively; and with legal and actual
malice.
COUNT III
(Race Discrimination in Violation of 42 U.S.C. § 1981)
28. Plaintiff repeats and realleges each and every allegation contained in paragraphs
1through 27 as if set forth fully herein.
29. The Defendant terminated the employment of the Plaintiff because of his race,
African-American, in violation of 42 U.S.C. § 1981. In taking the foregoing action, Defendant
materially and adversely violated Plaintiff’s right to make and enforce contracts in the same
manner as is enjoyed by white citizens and caused Plaintiff lost wages and benefits, and
damaged Plaintiff’s reputation and standing with prospective employers, and his fellow union
members and officers.
30. The Defendant’s termination of Plaintiff’s employment was carried out with racial
animus, knowledge that it was in violation of the law and with a malicious intent to injure the
Plaintiff.
-6-
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Document 1
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Page 7 of 7
31. The Defendant’s violation of 42 U.S.C. § 1981 caused the Plaintiff to sustain
financial damages in lost salary and future earnings, and other reasonably foreseeable
consequential damages incurred as a natural and proximate result of the Defendant’s
termination of Plaintiff’s employment.
32. As a consequence of Defendant’s termination of Plaintiff’s employment, the
Plaintiff has suffered severe mental distress.
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in his
favor and against the Defendants, declaring that the Defendants have violated his rights under
Title VII, 42 U.S.C. §§ 1981 and the D.C. Human Rights Act, and awarding him back pay,
compensatory and punitive damages, and attorneys fees and costs, and such other and further
relief as the Court may deem appropriate.
Dated: October 16, 2007
Respectfully submitted,
__/s/ DANIEL S. KOZMA___________
Daniel S. Kozma, Esq., D.C. Bar no. 940874
Suite 245
2120 L Street, N.W.
Washington, D.C. 20037
DKOZLAW@AOL.COM
202-969-2223
Counsel for the Plaintiff
JURY DEMAND
Plaintiff hereby demands a trial by jury.
____/s/ DANIEL S. KOZMA________
Daniel S. Kozma
-7-
PDF Page 9
Joimev-ur 10388 From EEOC PIM JRGH PA +412 G44 2684 7-027 P 02/011
a Page 10
ceooremer only 8@ 1:07-Cv-0H 4 FaUAL eMADORMENTUPPGRTUNTHPE O17”
DISMISSAL AND NOTICE OF RIGHTS
f fue
To: Ronald L. Adams
3876 Northgete Piace
Waldorf, MD 20602
—
From: Pittsburgh Area Office
1001 Liberty Avenue
Suite 300
Pittsburgh, PA 16222
On behait of person(s) aggneved whose identity is
CONFIDENTIAL (29 CFR § 1601. 7(a})
EEOC Charge No. EEOC Representative Telephone No.
570-2006-01352 Legal Unit {215) 440-2828
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
charge.
UO BOO O O00 0
Other (briefly state)
The facts alleged in the charge fail to state a claim under eny of the stetutes enforced by the EEOC.
Your aflegations did not involve a disability as defined by the Americans with Disabilities Act.
The Respondent employs less than the required number of employees or is not otherwise covered by the statutes.
You were given 30 days to accent a reasonable settiement offer that affords hall relief for the harm you alleged.
The EEOC iesues the following determination: Based upon its investigation. the EEOC is unable to conclude that the information obtained
establishes violations of the statutes. This does not certify that the reapondant is in compliance with the statutes. No finding is made as
to any other issues that might be construed as having been raised by this charge.
The EEOC has adopted the findings of the state or iocal fair employment practices agency that investigated this charge.
- NOTICE OF SUIT RIGHTS -
{See the additional information attached to this form.)
Your charge wes not timaly filed with EEOC: in other words, you waited too long after the date(s) of the allegad discrimination to file your
Having been given 30 days in which to respond, you failed to provide information, failed to appear of be availabia for
interviews/conferances. or otherwise failed to cooperate to the extent that it was not possibile to resolve your charge.
While reasonable efforts were made to locate you. we were not able to do so.
Title Vi, the Americans with Disabilities Act, and/or the Age Discrimination in Employment Act: This will be the only
notice of dismissal and of your right to sue that we will send you. You may file a lawsult against the respondent(s) under
federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAYS of your receipt
of this Notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a state claim may
be different.)
Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 years (3 years)
before you file suit may not be collectibie.
Enclosure(s)
cc: Rand Construction
On behalf of the Cornmission
Je) ype Laveen ODL 2 _
Joseph M._ Hardeman,
Area Director
Area Director
OF 18°74
FILED
OCT 17 2007
NANCY MAYER WHITTINGTON, CLERK
U.S. DISTRICT COURT
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