2which one applies a heated adhesive wax to the pubic hair on or near
anus andgenitalia, and then
forcibly removes that wax and hair by “tearing” the adhesive from
ed to comply with this “training,” because it was humiliating, painful,
embarrassing, and discriminatory. Moreover, Finley was scheduled to begin menstruating on thesame day she was expected to have the Brazilian wax, and expected to be extremely sensitive inthe most private region of her body.4.
When Finley explained her opposition to the mandatory “Brazilian” waxing, andexplained that receiving a “Brazilian” wax would be extremely painful and humiliating because
of her menstruation, the corporate trai
ner responded that she should “put in a fresh tampon andtake and ibuprofen and you’ll be fine.”
Finley promptly approached the owner of the Wexford Spa, and explained to himthat she refused to submit to a
wax performed on her by her co-workers, and that theEmployers could not require her to do so. Finley was terminated immediately.6.
policy of requiring female Wax Specialists to submit to
“Brazilian” waxes, and the termination of Finley in response to her opposing this policy and
refusing to submit to such a procedure, give rise to claims of harassment, discrimination, andretaliation under the Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e
and the Pennsylvania Human Relations Act, 43 P.S. §951
. (“PHRA”). The same
facts give rise to a claim for wrongful termination under Pennsylvania common law.
JURISDICTION AND VENUE
This Court’s jurisdiction is invoked pursuant to 28 U.S.C. § 1331, and § 1343
Case 2:13-cv-00909-JFC Document 1 Filed 06/27/13 Page 2 of 13