CIVIL DOCKET FOR CASE #: 0:11−cv−62525−WPD - United States ...

Case 0:11-cv-62525-WPD Document 1 Entered on FLSD Docket 11/28/2011 Page 2 of 31
Code # 05:0704 05:704- Labor Litination.15;00-05 15:5(a). 15:0002: 15:2(a) fair labor
stnndard act & 05:7703 05:7703/ iob discrimination.
Plaintiœ s tompliant divided to four sedions as:
Material facts bv EEOC with exhibits page # 7. respondent's cause of action with name. date
place and description to each cause with exhibits paa-e # 9. conclusion to the case as a whole
page # 26 and the relief renuested from the court Daae # 29 .
This matter presented direct and intentional violation of Federal Laws which prohibiting
Job Discrimination. Defendant issued wrongful termination action on April 28,201 which
violated Federal 1aw for Eqllnl Employment Opportunity (EEO): as following:-
A- Tile Vl of the Civil Rights Act of 1964 which probibited emplom ent discrimination
based on race, colors religion, sex and national origin; also to secme fair Iabor standamds and
equal protection which supported by material facts ms indicate by nnme, date and incident
description with exhibits as a symbol A & B in tltis compliant.
B- The Age Discrimination in Emplom ent Act of 1967 (ADEA), which protects individuals
who are 40 years of age or older while the defendant / directed clear discriminatory statement
directly with a threat msking plaintiffto leave job fair open for public on Oct. 05, 2010 to fil up
to 400 immediate positions in this day. The new Director of insmzctional stafting / Susan
Rockleman œsked plaintiff to leave the fair ms she stated ( they are looking for fresh paduate).
'lxis intentional discriminatory actions started since 2008 by reducing plaintitrs work hotlrs and
salary after plaintiff changed her married name Ibmbim to her father nnme Arafat as a1 material
facts listed in this case indicated in a legal omcial documents / records as tangible evidences ms
symbols A attachments for A exhibits & B attachments for B exhibits. Defendant's action was
based on false evaluations which indicated respondent direct and intentional discriminatory acts.
Some evidences retlected hate crime acts and personal opinion against plaintiff without any
cause of action or violation to any rules or law. Other false evaluations was written by defendant
/ employer's employees themselves through their own E-mail which considered public record
under Fla. Stat. except as excluded by 1 19.071.1002.22(3)(d)(smdents record)
C- Fair Labor standards Act when defendant failed to meet the stlmdards of the Federal law,
? f.
2 y