Free Notice (Other) - District Court of Delaware - Delaware

Case 1 :05-cv-00007-JJF Document 12-2 Filed 1 1/10/2005 Page 1 of 2
EXHIBIT A , g,
ENTER CHARGE NUMBER _
CHARGE OF DISCRIMINATION I A ~ »
I] FEPA r · ·-
This form is affected b the Privac Act of 1974 El EEOC V »--.. .1 A . ; _ , _
Delaware Department of Labor and EEOC _ L T v, L '.`:i Y Q, T f TEE
(State, or local Agency, if any) In E"` " `D ‘“`i"·*· · `
NAME (Indicate Mr., Mrs., Ms) HOME TELEPHONE N0. (Include Area Code)
Valerie Reeves (302) 834—0312
STREET ADDRESS CITY, STATE AND ZIP CODE COUNTY
8 Delft Cqdrt 0 llllidldlelzovm DE 19709 NCC _”~;
I NAMED IS THE EMPLOYER, LABOR ORGANIZATION, EMPLOYMENT AGENCY, APPRENTICESHIP COMMITTEE, STATE OR LOCAL
GOVERNMENT AGENCY WHO DISCRIMINATED AGAINST ME lf more than one, list below.
NAME No. or EMPLOYEES OR TELEPHONE NUMBER (incl. Area Code)
Radiology Associates MEMBERS 200+ (302) 652-3016
STREET ADDRESS , CITY, STATE AND ZIP CODE
17 01 August ine Cut —Off , Suite 100 Wilmington DE 19803
TELEP N UMBER
STREET ADDRESS ctw, STATE AND ZIP CODE
IZ RACE lj COLOR I] SEX [1 RELIGION [I NATIONAL ORIGIN lj] AGE DATE DISCRIMINATION TOOK PLACE
EARLIEST 2l18/2003
If] RETALIATION [fl DISABILITY K] OTHER (Specify) LATEST 2/ 1 8i'2003
lf] CONTINUING ACTION
THE PARTICULARS ARE (Ii additional space is needed, attached extra sheettslc
I am a black individual who began working for Respondent on November 25, 1974. Because on Februaiy 18, 2003 the City of
Wilmington declared a state of emergency, my work site was closed. Andrea Baxter (white) advised me to report to another
oftice outside of Wilmington, which I did.
Andrea gave no explanation for my one-day transfer to another office.
I believe I have been discriminated against in violation of Title VII of the Civil Rights Act of 1964, as amended, and the
Delaware Discrimination in Employment Act, as amended, because of my race (black); 1. I am one of four black x-ray
technicians working for Respondent. 2. I was the only employee to be transferred on February 18. 3. Respondent is punitively
using the transfer in retaliaiton for unscheduled, unpaid time I previously took.
I also want this charge tiled with the EEOC. I will advise the agencies SIGNATURE OF COMPLAINANT
E tt I change my address or telephone number and I will cooperate tully
with them in the processing of my charge in accordance with their
procedures. I swear or afttmi that I have read the above charge and that it is true to the best of
· m Imowled e, infomation and belief.
I declare under penalty of perjury that the foregoing is true and correct. NOTARY - (When necessary to meet State and Local Requirements)
Date Cha ln; Pa Si nature) Subscribed and swam to before me this date Day, month, and ear
EOEQESFSMQ; previous eeiricits or mis rom Arts oesoters me Must iter at usa;

Case 1:05-cv-00007-JJF Document 12-2 Filed 11/10/2005 Page 2 of 2
CONTINUATION OF AFFIDAVIT
1. COVERAGEIRESPONDENTS BUSINESS:
g Radiologists
2. RELEVANT WORK HISTORY: `
I am a black individual who began working for Respondent on November 25, 1974. Because on February 18, 2003 the
City of Wilmington declared a state of emergency, my work site was closed. Andrea Baxter (white) advised me to report
to another office outside of Wilmington, which I did.
I heIIev»=· I have been disasirniiittf ;g;.?i;C T: .Z.,I.;iZ.... ..IT§1L.. `Jii of Li.-; Cm. I'\I9lILb HUL ui mor-I, as amended, and the
Delaware Discrimination in Employment Act, as amended, because of my race (black): 1. I am one of four black x-ray
technicians working for Respondent. 2. I was the only employee to be transferred on February 18. 3. Respondent is
punitively using the transfer in retaliaiton for unscheduled, unpaid time I previously took.
3. PERSONAL HARM: I
I believe I have been discriminated against in violation of Title VII of the Civil Rights Act of 1964, as amended, and the
Delaware Discrimination in Employment Act, as amended, because of my race (black): 1. I am one of four black x-ray
technicians working for Respondent. 2. I was the only employee to be transferred on February 18. 3. Respondent is
punitively using the transfer in retaliaiton for unscheduled, unpaid time I previously took.
4. RESPONDENT'S EXPLANATION FOR THE ALLEGED HARM AND ITS POLICIES AND PRACTICES:
Andrea gave no explanation for my one—day transfer to another office.
5. DIRECT EVIDENCE:
see attached
6. WITNESSES:
na
7. COMPARATIVE DATA:
na
s. CLASS HARM;
na
9. REMEDY/RELIEF SOUGHT:
other damages
DATE AND INITIAL I
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