Joint Appendix - LawMemo

7. In June of 1998, the defendant required the
plaintiff to transfer to the position of Technical Engineer.
8. On October 31, 1998, the defendant forced the
plaintiff into early retirement.
IV.
COUNT I – Equal Pay Act
9. The plaintiff re-alleges and incorporates by reference
paragraphs 1-8 above with the same force and effect as if
fully set out in specific detail herein below.
10. As an Area Manager, the plaintiff was
similarly situated with her male co-workers and was doing
equal work in the same establishment.
11. However, the plaintiff’s male co-workers who
were doing identical work were paid at a higher rate than she.
12. The plaintiff was involuntarily transferred to
the position of Technical Engineer in June of 1998. After her
transfer, the plaintiff was again paid at a lower rate than
similarly situated male Technical Engineers doing identical
work in the same establishment.
13. The defendant willfully and maliciously
discriminated against the plaintiff in pay because of her sex.
V. Count II – Title VII Disparate Treatment
A. Discrimination in Wages
14. The plaintiff performed work equal or
substantially equal to that of the male Area Managers, but
received less pay for a substantially similar job.
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