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.
PARTIESCase 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 cascase 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
Terry J. Walker V County of Gloucester, Salem County Correctional Facility Warden Raymond Skradzinski, Former Salem County Corrections Officer Elbert B. Johnson II