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  • Caroline Rich, Marie Joe Farrior, Okey Sibedu V New Jersey Department of Children and Families

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    v New Jersey Department of Children and Families

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    Caroline Rich, Marie Joe Farrior, Okey Sibedu v New Jersey Department of Children and Families

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    v New Jersey Department of Children and Families

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    46 views23 pages

    Caroline Rich, Marie Joe Farrior, Okey Sibedu V New Jersey Department of Children and Families

    Uploaded by

    opracrusades
    v New Jersey Department of Children and Families

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 23
    Case 2:14-cv-02075-JAP-DEA Document 4 Filed 07/28/14 Page 1 of 23 PagelD: 48 ‘UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAROLINE RICH, AMENDED COMPLAINT -MARIE-JOE FARRIOR, SURY TRIAL REQUESTED OKEY SIBEDU, Plant -agsinst- (Civil Action No. SAP-DEA 1dvev- 02075 STATE OF NEW JERSEY, ‘NEW JERSEY DIVISION OF CHILDREN AND FAMILIES, MARY BROWNE, WAYNE SHREWING, AND ILA BHATNAGAR, AND WAYNE SHEWRING Defendant(s), Plaintiffs, Caroline Rich, Matie-Joc Farior and Okey Sibedu, by their attomey Albert ‘Van-Lare, complaining ofthe Defendants allege as follows: JURISDICITION AND VENUE |, This action is authorized and instituted inthis court pursuant to a clsimed violation of the Mth Amendnea tothe Constaton ofthe United States nda violation of €2 USC 41981, 42 USC § 1983, 42 USC § 12101, Tie VI ofthe Civil Rights Act of 1964 (42 “USC § 20006), amongst others. 2. Defends prinepal business ofces ar located in New Jescy. 3, Plein re eden ofthe State of New Jersey 4. This cout as jursition over his case pursuant (9 28 USC1331, Claims arising ‘under site story and comenon law are under ths con's supplemental jursition punt fo 28 USC 1367, Venue lies in hs dstict pursuant to 28 USC § 1392. PARTIES Case 2:14-0v-02075-JAP-DEA Document Filed 07/28/34 Page 2 of 28 PagelD: 49, 10. uL. 2, 1. Plaintitfs were all employes of the Defendants during the relevant period ofthis complain. Plein Carotne Rich (hereinafter ered to as “Richi a white femal. Plaintiff Marie-fo Fartor (rine refered os “Kari” isan Aan American female with Haitian national rin, Plant Okey Sibed (tener refered tas “Sibed) isan Affcan American male with Nigerian onal origin ‘Wayne Shrewing and Wayne Shewring are the same individuals and upon infermation and belie the appropriate way to spell his name is Wayne Showing. Defendants were Plinth employer throughout the relevant period of his complain. “The Defendants ave the powers o grant the elit planis ar seeking FACTUAL ALLEGATIONS Plants Sibedu, Rich, and Farror fled complaints with the Equal Employment Opportunity Commission *EEOC'), Sibeda and Rich reosived right to sue eters fiom the EEOC aud bth have fled tnely complaints inthis out. Farin ied a complaint with the EEOC but the complaint was not docked because the EEOC conclu thatthe complaint wailed more than three hundred days ater the sets complained of occurred. RETALIATION PLAINTIF CAROLINE RICH Paint Rich was approached in or around July 2013 by NJ. Deputy Atomey Genera Nicole Coton, who requested an interview with Plaintiff Rich because she was named filed in federal 5 potential witness for the state in an employment discrimination cas case 3:14-cv-02075-JAP-DEA Document 4 Filed 07/28/14 Page 3 of 23 PagelD: 50 16. ” 18. 20. ak. cout (US District Coat, Distt of New Jersey) by Tracy Barco, ber former supervisor. “The New Jersey Attorey General's office was representing he state and preparing & befense nthe cate wheaPlintitPRich was approacbed in July 2013, Pst Rich nly refsed to volunteer information and stated to Ms, Colon hat she would be a witness forthe pai, Tracy Baro, ‘Upon further discussions and efetons,Plainif Rich began to answer questions fom Ms. Coton. Plant Rich informed Ms. Colon that she believes Tracy Barco was a victim of race

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