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Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND NORTHERN DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, COMPLAINT AND JURY TRIAL DEMAND v. VERIZON MARYLAND, INC., Civil Action No. 1 East Pratt Street Baltimore, Maryland and VERIZON DELAWARE LLC, VERIZON NEW ENGLAND INC., VERIZON NEW JERSEY INC., VERIZON NEW YORK INC., VERIZON PENNSYLVANIA INC., VERIZON VIRGINIA INC., VERIZON WASHINGTON, DC INC., VERIZON FLORIDA LLC, VERIZON SOUTH INC., VERIZON CALIFORNIA INC., VERIZON AVENUE CORP. D/B/A VERIZON ENHANCED COMMUNITIES, VERIZON SERVICES CORP., VERIZON CORPORATE SERVICES CORP., VERIZON CONNECTED SOLUTIONS INC., VERIZON CORPORATE SERVICES GROUP INC., VERIZON GLOBAL NETWORKS, INC., VERIZON ENTERPRISE DELIVERY LLC, VERIZON NORTH RETAIN CO., VERIZON SELECT SERVICES INC., VERIZON TELEPRODUCTS CORP., EMPIRE CITY SUBWAY COMPANY (LIMITED), GTE SOUTHWEST D/B/A VERIZON SOUTHWEST, AND TELESECTOR RESOURCES GROUP, INC. D/B/A VERIZON SERVICES GROUP, 140 West St. New York, NY 10007 Defendants. 1 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 2 of 11 NATURE OF THE ACTION This is an action under Title I of the Americans with Disabilities Act ("the ADA") of 1990, as amended through the ADA Amendments of2008, and Title I ofthe Civil Rights Act of 1991 to correct unlawful employment practices because of disability and to provide appropriate relief to Charging Parties and a class of aggrieved persons with disabilities who were advers~ly affected by such practices. As alleged with greater particularity in paragraph 31 below, the U.S. Equal Employment Opportunity Commission ("the Commission" or "EEOC") alleges that Defendants Verizon Maryland Inc., Verizon Delaware LLC, Verizon New England Inc., Verizon New Jersey Inc., Verizon New York Inc., Verizon Pennsylvania Inc., Verizon Virginia Inc., Verizon Washington, DC Inc., Verizon Florida LLC, Verizon South Inc., Verizon California Inc., Verizon Avenue Corp. d/b/a Verizon Enhanced Communities, Verizon Services Corp., Verizon Corporate Services Corp., Verizon Connected Solutions Inc., Verizon Corporate Services Group Inc., Verizon Global Networks, Inc., Verizon Enterprise Delivery LLC, Verizon North Retain Co., Verizon Select Services Inc., Verizon TeleProducts Corp., Empire City Subway Company (Limited), GTE Southwest Inc., d/b/a Verizon Southwest, and Telesector Resources Group., Inc. d/b/a Verizon Services Group (hereinafter collectively referred to as "Verizon" or "Defendants") have discriminated against the Charging Parties and a class of disabled individuals by not making exceptions to their "no fault" attendance plans, even when legally required to do so in order to provide reasonable accommodation, a practice which has subjected employees covered under the ADA to denial of effective reasonable accommodations, discipline, denials oftransfers, and discharge. 2 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 3 of 11 JURISDICTION AND VENUE 1. Jurisdiction ofthis Court is invoked pursuant to 28 U.S.C. §§ 451,1331,1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 107(a) ofthe Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.c. § 12117(a), which incorporates by reference Sections 706(f)(1) & (3) and 707 ofTitle VII ofthe Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e-5(f)(1) & (3) and 2000e-6; and Section 102 ofthe Civil Rights Act of 1991,42 U.S.C. § 1981a. 2. The employment practices alleged to be unlawful were committed within the jurisdiction ofthe United States District Court for the District ofMaryland and other jurisdictions. PARTIES 3. Plaintiff, the United States Equal Employment Opportunity Commission (the "Commission"), is the Agency ofthe United States ofAmerica charged with the administration, interpretation and enforcement ofTitle I of the ADA and is expressly authorized to bring this action by Section 107(a) ofthe ADA, 42 U.S.c. § 12117(a), which incorporates by reference Sections 706(f)(1)& (3) and 707 ofTitle VII, 42 U.S.C. §§ 2000e-5(f)(I) & (3) and 2000e-6. 4. At all relevant times, Defendant Verizon Maryland Inc. has continuously been a Maryland corporation doing business in many states, including the State ofMaryland, and has continuously had at least 15 employees. 5. At all relevant times, Defendant Verizon Delaware LLC, a wholly owned subsidiary ofVerizon Communications, Inc. has continuously been a Delaware corporation doing business in many states, including the State ofDelaware, and has continuously had at least 3 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 4 of 11 15 employees. 6. At all relevant times, Defendant Verizon New England Inc. has continuously been a New York corporation doing business in many states, including the State of Massachusetts, and has continuously had at least 15 employees. 7. At all relevant times, Defendant Verizon New Jersey Inc. has continuously been a New Jersey corporation doing business in many states, including the State ofNew Jersey, and has continuously had at least 15 employees. 8. At all relevant times, Defendant Verizon New York Inc. has continuously been a New York corporation doing business in many states, including the State of New York, and has continuously had at least 15 employees. 9. At all relevant times, Defendant Verizon Pennsylvania Inc. has continuously been a Pennsylvania corporation doing business in many states, including the State of Pennsylvania, and has continuously had at least 15 employees. 10. At all relevant times, Defendant Verizon Virginia Inc. has continuously been a Virginia corporation doing business in many states and the Commonwealth of Virginia and has continuously had at least 15 employees. 11. At all relevant times, Defendant Verizon Washington, DC Inc. has continuously been a New York corporation doing business in many states, including the District of Columbia, and has continuously had at least 15 employees. 12. At all relevant times, Defendant Verizon Florida LLC has continuously been a Florida corporation doing business in many states, including the State of Florida, and has continuously had at least 15 employees. 4 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 5 of 11 13. At all relevant times, Defendant Verizon South Inc. has continuously been a Virginia corporation doing business in many states, including the State of Virginia, and has continuously had at least 15 employees. 14. At all relevant times, Defendant Verizon California Inc. has continuously been a California corporation doing business in many states, including the State of California, and has continuously had at least 15 employees. 15 . At all relevant times, Defendant Verizon Avenue Corp. D/B/A Verizon Enhanced Communities has continuously been a Delaware corporation doing business in many states, including the State ofMaryland, and has continuously had at least 15 employees. 16. At all relevant times, Defendant Verizon Services Corp. has continuously been a Delaware corporation doing business in many states, including the State of Maryland, and has continuously had at least 15 employees. 17. At all relevant times, Defendant Verizon Corporate Services Corp. has continuously been a Delaware corporation doing business in many states, including the State of Maryland, and has continuously had at least 15 employees. 18. At all relevant times, Defendant Verizon Connected Solutions Inc. has continuously been a Delaware corporation doing business in many states, including the State of Maryland, and has continuously had at least 15 employees. 19. At all relevant times, Defendant Verizon Corporate Services Group Corp. has continuously been a New York corporation doing business in many states, including the State of Maryland, and has continuously had at least 15 employees. 5 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 6 of 11 20. At all relevant times, Defendant Verizon Global Networks, Inc. has continuously been a Delaware corporation doing business in many states, including the State ofMaryland, and has continuously had at least 15 employees. 21. At all relevant times, Defendant Verizon Enterprise Delivery LLC has continuously been a Delaware corporation doing business in many states, including the State of Maryland, and has continuously had at least 15 employees. 22. At all relevant times, Defendant Verizon North Retain Co. has continuously been a Pennsylvania corporation doing business in many states, including the State ofPennsylvania, and has continuously had at least 15 employees. 23 . At all relevant times, Defendant Verizon Select Services Inc. has continuously been a Delaware corporation doing business in many states, including the State ofMaryland, and has continuously had at least 15 employees. 24. At all relevant times, Defendant Verizon Teleproducts Corp. has continuously been a Delaware corporation doing business in many states, including the State ofMaryland, and has continuously had at least 15 employees. 25. At all relevant times, Defendant Empire City Subway Company (Limited) has continuously been a New York corporation doing business in many states, including the State of New York, and has continuously had at least 15 employees. 26. At all relevant times, Defendant GTE Southwest DIBI A Verizon Southwest has continuously been a Delaware corporation doing business in many states, including the State of Texas, and has continuously had at least 15 employees. 6 Case 1:11-cv-01832-JKB Document 1 Filed 07/05/11 Page 7 of 11 27. At all relevant times, Defendant Telesector Resources Group Inc., D/B/A Verizon Services Group, has continuously been a Delaware corporation doing business in many states, including the State ofNew York, and has continuously had at least 15 employees. 28 . At all relevant times, Defendants have continuously been employers engaged in an industry affecting commerce within the meaning of Section 101(5) of the ADA, 42 U.S.c.§ 12111(5), and Section 101(7) ofthe ADA, 42 U.S.c. § 12111(7), which incorporates by reference Sections 701(g) and (h) of Title VII, 42 U.S.c.
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