eeoc v. ups 071515

1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK

_______________________________________ EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

v.

UNITED PARCEL SERVICE, INC.,

Defendant. ______________________________________

x::::::::: ::x

CIVIL ACTION NO. 15-4141

JURY TRIAL DEMANDED

NATURE OF THE ACTION

This is an action under Title VII of the Civil Rights Act of 1964 and Title I of the Civil

Rights Act of 1991 to correct unlawful employment practices on the basis of religion, and to

provide appropriate relief to Bilal Abdullah, Muhammad Farhan and a class of similarly

aggrieved applicants and employees of Defendant who have been adversely affected by such

practices. As alleged with greater particularity in paragraphs 14-21 below, Defendant United

Parcel Service, Inc. (UPS) has discriminated nationwide against applicants and employees

whose religion conflicts with the companys Uniform & Appearance Policy (appearance

policy), in violation of Title VII. This discrimination includes the unlawful failure to provide

religious accommodations to UPSs appearance policy, failure to hire, failure to promote, and the

segregation of those individuals whose religious beliefs conflict with the appearance policy into

a particular subset of positions.

Case 1:15-cv-04141 Document 1 Filed 07/15/15 Page 1 of 14 PageID #: 1

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JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 451, 1331, 1337, 1343

and 1345. This action is authorized and instituted pursuant to Sections 706(f)(1) and (3) of Title

VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e-5(f)(1) and (3) (Title

VII) and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. 1981a.

2. The employment practices alleged to be unlawful were committed in numerous

locations, including within the jurisdiction of the United States District Court for the Eastern

District of New York.

PARTIES

3. Plaintiff, the Equal Employment Opportunity Commission (the Commission), is the

agency of the United States of America charged with the administration, interpretation and

enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1)

and (3) of Title VII, 42 U.S.C. 2000e-5(f)(1) and (3).

4. At all relevant times, Defendant United Parcel Service, Inc., a Delaware corporation,

has continuously been doing business in the State of New York and has continuously had at least

15 employees. Defendant operates throughout the United States.

5. At all relevant times, Defendant has continuously been an employer engaged in an

industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42

U.S.C. 2000e(b), (g) and (h).

STATEMENT OF CLAIMS

6. More than thirty days prior to the institution of this lawsuit, Bilal Abdullah and

Muhammad Farhan filed charges with the Commission alleging violations of Title VII by

Defendant. In addition, more than thirty days prior to the institution of this lawsuit, a charge was


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filed with the Commission by Stuart J. Ishimaru, a member thereof, alleging violations of Title

VII by Defendant UPS.

7. On June 27, 2012, the Commission issued to Defendant a Letter of Determination on

all three charges finding reasonable cause to believe that Title VII was violated, and inviting

Defendant to join with the Commission in informal methods of conciliation to endeavor to

eliminate the discriminatory practices and provide appropriate relief.

8. The Commission engaged in communications with Defendant to provide Defendant

the opportunity to remedy the discriminatory practices described in the Letter of Determination.

9. The Commission was unable to secure from Defendant a conciliation agreement

acceptable to the Commission, and on August 25, 2014 issued to Defendant a Notice of Failure

of Conciliation.

10. All conditions precedent to the initiation of this lawsuit have been fulfilled.

11. Bilal Abdullah and Muhammad Farhan both observe the Muslim faith and, as part

of their religious observance, wear a beard .

12. Defendant is the nations largest package delivery company, operating in every state

in the country. It employs over 300,000 people nationwide, including drivers, driver helpers and

package handlers.

13. Defendant maintains a Uniform & Appearance Policy that is applicable to all

employees in positions that require customer contact (including driver and driver helper) and to

all employees with supervisory responsibility. The appearance policy prohibits covered male

employees from wearing facial hair below the lip (e.g., beards) or from growing their hair below

collar length. The appearance policy does not apply to back of the facility positions which do

not involve customer contact.


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14. Since at least 2004, Defendant has engaged in unlawful employment practices at its

facilities across the United States, in violation of Sections 701(j) and 703 of Title VII, 42 U.S.C.

2000e(j) and e(2). Specifically, Defendant has refused to accommodate qualified individuals

whose religion conflicts with Defendants appearance policy where the requested

accommodation would not pose an undue hardship to Defendant.

15. The unlawful practices alleged in paragraph 14 above include but are not limited to

the following:

a) Defendant has failed to inform applicants and employees of its policy

through which individuals may seek a religious accommodation to the appearance

policy.

b) Defendant has denied the existence and availability of religious accommodations

to its appearance policy when such accommodations have been requested by

applicants and employees.

c) Defendant has unreasonably delayed action on employee requests for religious

accommodation, including delays of several years, forcing employees to choose

between violating their religious beliefs or violating Defendants appearance

policy with the attendant risk of discipline or dismissal.

d) For example, a driver in San Francisco sought an accommodation to the

appearance policy permitting him to wear a beard, consistent with his observance

and practice of Islam. While awaiting UPSs evaluation of his request, he often

shaved his beard, against his religious beliefs, so that he could work. When he

chose not to shave, UPS sent him home without pay. Two years after his initial


5

request, UPS granted his accommodation, but instructed him that he would be

required to reapply if, at any time, he was assigned a new supervisor.

e) Similarly, in Brooklyn, NY, a Muslim employee sought an accommodation to

permit him to wear a beard while working as a customer service representative for

Defendant. His first supervisor told him that no such accommodations existed

and that if he did not shave his beard, he would be fired. Several years later,

when Defendant finally informed the employee that he could avail himself of the

companys accommodation request process, it refused to grant the

accommodation without first receiving certification from his iman that wearing a

beard was part of the employees religious observance. It took Defendant an

additional nine months to grant the accommodation.

f) As another example, in Harrisburg, Pennsylvania an employee of Defendant

asked that he be permitted to wear a beard as part of his observance of his

Christian faith. After three years of making verbal requests, Defendant finally

provided the worker with the form to make a written request. Before his request

was acted on, the employees supervisor asked him why, in light of his religious

observance, he had even bothered to come to UPS to work.

g) Also, at Defendants location in Fort Lauderdale, Florida, a part-time load

supervisor and practicing Rastafarian requested a religious accommodation to

permit him to wear dreadlocks and refrain from cutting his hair, as his religious

practice required. His manager ignored his request, told the employee he didnt

want any employees looking like women on his management team, and

repeatedly asked the employee when he was going to cut his hair. When the


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employee contacted Defendants human resources department, he was questioned

as to why he practiced the Rastafarian religion at all since he is not Jamaican.

h) The manager of another Christian employee in Harrisburg, after receiving the

employees request for an accommodation to wear a beard in compliance with

his faith, telephoned the employees minister to inquire as to whether the worker

attended church regularly, whether his belief was sincere, and whether the Bible

mandated a particular length of beard.

i) Also, on Long Island, a Rastafarian employee requested an accommodation to

wear a beard, after being promoted to driver. Defendant rejected his request

because the employee did not identify a location or institution where the

employee worshiped. Upon information and belief, the employee eventually

provided the requested documentation from his spiritual adviser that satisfied

Defendant and his request was granted, two years after he first sought the

accommodation.

16. Since at least 2004, Defendant has engaged in unlawful employment practices at

facilities across the United States, in violation of Section 703 of Title VII, 42 U.S.C. 2000e-2.

Specifically, Defendant has refused to hire individuals whose religion conflicts with Defendants

appearance policy.

17. These unlawful practices described in paragraph 16 above include but are not

limited to the following:

a) Defendant has refused to hire qualified employees because of their religion.

b) Defendant has refused to hire qualified employees for the positions for which they

applied, and are qualified to perform, because of religion and has instead directed


7

those individuals into positions that are not subject to Defendants appearance

policy.

c) Defendant has refused to hire qualified employees whose religion conflicts with

Defendants appearance policy and has not permitted those individuals to seek an

accommodation to the appearance policy.

d) Charging Party Bilal Abdullah applied for a position as a driver helper with

Defendant in Rochester, NY in November 2005. When Defendants hiring

official told Abdullah he would have to shave to be considered for the driver

helper position, Abdullah, who is Muslim, explained that he wears a beard as part

of his religious observance. UPSs hiring official replied that God would

understand if he shaved his beard to get a job. Defendant told Abdullah that he

could apply for a package handler position, which did not require customer

contact. Defendant did not hire Abdullah for either position.

e) As another example, in 2007, an applicant for a driver helper position at the UPS

facility in Lancaster, Massachusetts informed Defendant that he wore a beard as

part of his Muslim religious observance and inquired as to whether or not the

company would grant him an exception, on that basis, to the appearance policy.

The applicant was told that Defendant granted absolutely no exceptions for

beards. When the applicant inquired about the possibility of applying for another

position, he was told to shave his beard and cut his hair if he wanted to work for

Defendant.

f) Also, in 2007, a Native American applicant for a receiving position at UPS in

Stockton, California, after explaining that he wore his hair long as part of his


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religious observance and offering to wear it under his shirt or in a hair net, was

told, No hair cut, no job.



Specifically, Defendant has refused to promote, or in the alternative, failed to hire or transfer to a

different position, individuals whose religion conflicts with Defendants appearance policy.

19. The unlawful practices described in paragraph 18 above include but are not limited

to the following:

a) Defendant has refused to promote qualified employees because of their religion.

b) Defendant refused to promote qualified employees whose religion conflicts with

Defendants appearance policy and has not permitted those individuals to seek an

accommodation to the appearance policy.

c) Defendant has told qualified employees whose religion conflicts with Defendants

appearance policy that they will not be promoted unless they comply with the

appearance policy.

d) Charging Party Muhammad Farhan worked for Defendant as a package handler in

Dallas, Texas. In April 2007, upon reporting to his first day of driver training in

anticipation of a promotion to the driver position, Farhan was told by Defendant

that he would not be permitted to work as a driver because of his beard. Farhan,

who is Muslim, explained that he wore his beard as a religious observance and

asked that he be provided an accommodation. Defendants agent, Farhans

supervisor, stated that no such exception to the policy would be made. Farhan

then asked at least four other UPS supervisors, including Human Resources


9

personnel, for the form so that he could request a religious accommodation, and

was repeatedly told that the supervisors were not aware of any such form. Only

after Farhan filed a charge of discrimination with EEOC, and two months after his

initial request, did UPS provide him with a form through which he could make a

written request for a religious accommodation. In the intervening time, Farhan

lost the opportunity to train for a promotion for which he was qualified and lost

wages.

e) As a further example, Defendants managers in Portland, Oregon in 2007

repeatedly told a Muslim part-time loader that he had completed all the

preparation to be promoted to a supervisory position, and that his life would be

better and easier as a manager. But they also told him that he could not apply for

the position until he shaved his beard. These managers repeatedly pressured him

to shave his beard and apply for the promotion.

f) In Harrington, Delaware, a Muslim preloader applied for a driver helper position

in 2007, and was denied. It was not until November 2009 that he was provided

with the form to request an accommodation permitting him to wear his beard.

g) In Plainsfield, Illinois, in approximately July 2004, a Muslim Information

Technology Department employee was forced to shave by Defendants

management. Seven months after his first request for accommodation and only

after three requests were made, Defendant permitted him to wear a beard limited

to inch in length. When he applied for a promotion to a management position,

Defendant required him to agree in writing that he understood that if he wanted a

future promotion within the Information Technology Department, he would have


10

to shave and that if he was to maintain facial hair, it could limit his opportunities

for positions involving customer contact or management.



Specifically, Defendant has segregated individuals on the basis of their religion, by placing

individuals whose religious beliefs conflict with the appearance policy into different job

positions in its facilities based on the appearance policy and Defendants refusal to accommodate

religious practices. It has segregated those individuals by keeping them in back-of-the-facility

positions, which involve no customer contact.

21. The unlawful practices described in paragraph 20 above include but are not limited

to the following:

a) A Rastafarian package handler in Long Island sought a driver position in 2006

but was required to request an accommodation based on his religious

practices. He was segregated into a back of the facility position during the

two years it took for UPS to grant his accommodation request.

b) A Rastafarian package sorter in Hodgkins, Illinois applied for a promotion to

a supervisor position and requested an accommodation to wear long hair

because of his religious practice. UPS refused the accommodation request

and denied him the supervisor position, instead segregating him to the back of

the facility as a sorter.

c) A Rastafarian package sorter in Tampa, Florida applied in 2004 to be a driver

and requested an accommodation so that he could wear a beard in accordance

with his religious practice. He was first told there were no exceptions to the


11

appearance policy for his beard and long hair, if he wished to be a driver.

After three years and repeated accommodation requests, UPS granted him

limited accommodations and allowed him to obtain work as a driver.

d) Charging Party Bilal Abdullah applied for a position as a driver helper and

was asked to apply instead for a package handler position in the back of the

Rochester hub because his religious requirement of wearing his beard

conflicted with Defendants appearance policy.

22. The effect of the practices complained of in paragraphs 14-21 above has been to

deprive applicants and employees whose religion conflicts with Defendants appearance policy,

including Bilal Abdullah and Muhammad Farhan, of equal employment opportunities and

otherwise adversely affect the terms and conditions of their work, including their ability to be

hired and promoted, because of their religion.

23. The unlawful employment practices complained of in paragraphs 14-21 above were

and are intentional.

24. The unlawful employment practices complained of in 14-21 above were done with

malice or with reckless indifference to the federally protected rights of Abdullah, Farhan and

other applicants and employees whose religion conflicted with Defendants appearance policy.

PRAYER FOR RELIEF

Wherefore, the Commission respectfully requests that this Court:

A. Grant a permanent injunction enjoining Defendant, its officers, agents, servants,

employees, attorneys, and all persons in active concert or participation with them, from engaging

in employment practices that discriminate on the basis of religion.


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B. Order Defendant to institute and carry out policies, practices, and programs which

provide equal employment opportunities regardless of religion, and which eradicate the effects of

its past and present unlawful employment practices.

C. Order Defendant to make whole Abdullah, Farhan and all applicants and employees

who have been discriminated against because their religion conflicts with Defendants

appearance policy by providing appropriate backpay with prejudgment interest, in amounts to be

determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful

employment practices, including but not limited to rightful-place hiring, reinstatement, and/or

promotion of Abdullah, Farhan and all applicants and employees who have been discriminated

against because their religion conflicts with Defendants appearance policy.

D. Order Defendant to make whole Abdullah, Farhan and all applicants and employees

who have been discriminated against because their religion conflicts with Defendants

appearance policy by providing compensation for past and future pecuniary losses resulting from

the unlawful employment practices described in paragraphs 14-21 above in amounts to be

determined at trial.

E. Order Defendant to make whole Abdullah, Farhan and all applicants and

employees who have been discriminated against because their religion conflicts with

Defendants appearance policy by providing compensation for past and future nonpecuniary

losses resulting from the unlawful practices complained of in paragraphs 14-21 above, including

but not limited to, emotional pain, suffering, humiliation, and inconvenience, in amounts to be

determined at trial.

F. Order Defendant to pay Abdullah, Farhan and all applicants and employees who

have been discriminated against because their religion conflicts with Defendants appearance


13

policy punitive damages for its malicious and reckless conduct described in paragraphs 14-21

above, in amounts to be determined at trial.

G. Grant such further relief as the Court deems necessary and proper in the public

interest.

H. Award the Commission its costs of this action.

JURY TRIAL DEMAND

The Commission requests a jury trial on all questions of fact raised by its complaint.

Dated: July 15, 2015 New York, New York Respectfully submitted, David P. Lopez General Counsel Gwendolyn Y. Reams Associate General Counsel U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 131 M Street, NE Washington, DC 20507 /s/Robert D. Rose______________________

Regional Attorney

/s/Nora Curtin___________________________ Supervisory Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION New York District Office 33 Whitehall Street, 5th Floor New York, New York 10004 (212) 336-3747


14

/s/Elizabeth Fox-Solomon____________________

Trial Attorney

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Buffalo Local Office 6 Fountain Plaza, Suite 350 Buffalo, New York 14202 (716) 551-3393


JS 44 (Rev. 1/2013) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff(For Diversity Cases Only) and One Box for Defendant)

1 U.S. Government 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6 Foreign Country

IV. NATURE OF SUIT (Place an X in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act 120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment 130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust 140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking 150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation 151 Medicare Act 330 Federal Employers Product Liability 830 Patent 470 Racketeer Influenced and 152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations

Student Loans 340 Marine Injury Product 480 Consumer Credit (Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV

153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/ of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange

160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions 190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts 195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters 196 Franchise Injury 385 Property Damage 751 Family and Medical 895 Freedom of Information

362 Personal Injury - Product Liability Leave Act Act Medical Malpractice 790 Other Labor Litigation 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure 210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff Act/Review or Appeal of 220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) Agency Decision 230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party 950 Constitutionality of 240 Torts to Land 443 Housing/ Sentence 26 USC 7609 State Statutes 245 Tort Product Liability Accommodations 530 General 290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION

Employment Other: 462 Naturalization Application 446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration

Other 550 Civil Rights Actions 448 Education 555 Prison Condition

560 Civil Detainee - Conditions of Confinement

V. ORIGIN (Place an X in One Box Only) 1 Original

Proceeding 2 Removed from

State Court 3 Remanded from

Appellate Court 4 Reinstated or

Reopened 5 Transferred from

Another District(specify)

6 MultidistrictLitigation

VI. CAUSE OF ACTIONCite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII. REQUESTED INCOMPLAINT:

CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint:JURY DEMAND: Yes No

VIII. RELATED CASE(S)IF ANY (See instructions): JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 1:15-cv-04141 Document 1-1 Filed 07/15/15 Page 1 of 2 PageID #: 15

Local Arbitration Rule 83.10 provides that with certain exceptions, actions seeking money damages only in an amount not in excess of $150,000,exclusive of interest and costs, are eligible for compulsory arbitration. The amount of damages is presumed to be below the threshold amount unless acertification to the contrary is filed.

I, ______________________, counsel for __________________, do hereby certify that the above captioned civil action isineligible for compulsory arbitration for the following reason(s):

monetary damages sought are in excess of $150,000, exclusive of interest and costs,

the complaint seeks injunctive relief,

the matter is otherwise ineligible for the following reason

DISCLOSURE STATEMENT - FEDERAL RULES CIVIL PROCEDURE 7.1

Identify any parent corporation and any publicly held corporation that owns 10% or more or its stocks:

RELATED CASE STATEMENT (Section VIII on the Front of this Form)

Please list all cases that are arguably related pursuant to Division of Business Rule 50.3.1 in Section VIII on the front of this form. Rule 50.3.1 (a)provides that A civil case is related to another civil case for purposes of this guideline when, because of the similarity of facts and legal issues orbecause the cases arise from the same transactions or events, a substantial saving of judicial resources is likely to result from assigning both cases to thesame judge and magistrate judge. Rule 50.3.1 (b) provides that A civil case shall not be deemed related to another civil case merely because the civilcase: (A) involves identical legal issues, or (B) involves the same parties. Rule 50.3.1 (c) further provides that Presumptively, and subject to the powerof a judge to determine otherwise pursuant to paragraph (d), civil cases shall not be deemed to be related unless both cases are still pending before thecourt.

NY-E DIVISION OF BUSINESS RULE 50.1(d)(2)

1.) Is the civil action being filed in the Eastern District removed from a New York State Court located in Nassau or SuffolkCounty:_________________________

2.) If you answered no above:a) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in Nassau or SuffolkCounty?_________________________

b) Did the events of omissions giving rise to the claim or claims, or a substantial part thereof, occur in the EasternDistrict?_________________________

If your answer to question 2 (b) is No, does the defendant (or a majority of the defendants, if there is more than one) reside in Nassau orSuffolk County, or, in an interpleader action, does the claimant (or a majority of the claimants, if there is more than one) reside in Nassauor Suffolk County?______________________

(Note: A corporation shall be considered a resident of the County in which it has the most significant contacts).

BAR ADMISSION

I am currently admitted in the Eastern District of New York and currently a member in good standing of the bar of this court.Yes No

Are you currently the subject of any disciplinary action (s) in this or any other state or federal court?Yes (If yes, please explain) No

I certify the accuracy of all information provided above.

Signature:____________________________________________

CERTIFICATION OF ARBITRATION ELIGIBILITYCase 1:15-cv-04141 Document 1-1 Filed 07/15/15 Page 2 of 2 PageID #: 16

MarziliaTypewritten Text








Brief Description: An action to correct unlawful employment practices on the basis of religion at defendant's facilities nationwide. check1008: check1007: check 1000: 440check1005: 440Demand: check1004: Text1: Text2: Text3: check1001: 440Text4: /s/Nora E. Curtin, Supervisory Trial AttorneyText5: 17: County_2: No18: 15: 16: 13: I: Nora Curtin14: 11: 12: V: Origin: 1

counsel for: PlaintiffCounty_of_Residence_of_Fi: Kings CountyDate: July 15, 2015or Suffolk County: CauseofAction: Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991check1009: 440Plaintiff: Equal Employment Opportunity CommissionAttorneys: DOCKET_NUMBER: b_County_of_Residence_of: Nature of Suit: 442

Sig: /s/Nora E. Curtin, Supervisory Trial AttorneyCHECK_IF_THIS_IS_A_CLASS: JUDGE: FirmName: U.S. Equal Employment Opportunity Commission, New York District Office, 33 Whitehall Street, 5th Floor, New York, NY 10004, 212-336-3747.Defendant: United Parcel Service, Inc.CHECK_YES_only_if_demand1: Yes

10: County: No7: District: YesBasis of Jurisdiction: 1.U.S. Plaintiff

9: 8:

eeoc v. ups 071515

Documents

violations of title

employees of defendant

violation of title

h of title

enforcement of title

defendant ups

united states district

united states of america