Defendant CCA is a Pennsylvania non-profit corporation employing fifteen(15) or more employees. Defendant CCA operates a kindergarten through 12
gradeclassical Christian School founded in 1997 with a principal place of business locatedat 1982 Locust Lane, Harrisburg, PA 17109.5.
This Honorable Court has jurisdiction pursuant to 28 U.S.C. §1331 as this casearises under the laws of the United States and pursuant to the ADA which providesfor original jurisdiction. This Court has jurisdiction over Plaintiff Wright’s Stateclaims pursuant to supplemental jurisdiction codified at 28 U.S.C. §1367.6.
Venue lies within the Middle District of Pennsylvania pursuant to 28 U.S.C.§1391 as the facts and occurrences, acts and/or omissions and incidents and/oractions alleged herein took place within this judicial district, and because theDefendant resides in the Middle District.7.
At all relevant times hereto, Defendant CCA acted through its agents, apparentagents, servants, apparent servants and/or employees who were authorized and actingwithin the scope of authority, course of employment and/or under the direct controlof Defendant CCA.8.
All preconditions to the filing of this action, by way of pursuit of administrative remedies have been satisfied. Plaintiff timely filed her Charge of Discrimination with the Pennsylvania Human Relations Commission, said charge
Case 3:02-at-06000 Document 640 Filed 06/21/12 Page 3 of 30
Case 1:12-cv-01190-CCC Document 1 Filed 06/21/12 Page 3 of 30