Item No. 1 Emancipation Proclamation “A Deliberate Attempt to Excite Our
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Plaintiff's Reply
Case 1:07-cv-02067-NGG-RLM Document 174 Filed 06/25/2008 Page 1 of 38 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------------------------------------------------X UNITED STATES OF AMERICA, Plaintiff, -and- THE VULCAN SOCIETY, INC., ET AL, Civ. Action No. 07-CV-2067 (NGG)(RLM) Plaintiffs-Intervenors, ECF Case -against- Served June 25, 2008 THE CITY OF NEW YORK, ET AL, Defendants. ---------------------------------------------------------------------X MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFFS-INTERVENORS’ MOTION FOR THE CERTIFICATION OF A CLASS AND IN SUPPORT OF PLAINTIFFS-INTERVENORS’ MOTION TO AMEND AND SUPPLEMENT THE COMPLAINT SCOTT + SCOTT, LLP LEVY RATNER, P.C. 29 West 57th Street 80 Eighth Avenue, 8th Floor New York, NY 10019 New York, NY 10011 (212) 223-6444 (212) 627-8100 (212) 223-6334 (fax) (212) 627-8182 (fax) CENTER FOR Attorneys for Plaintiffs-Intervenors CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2399 (212) 614-6438 (212) 614-6499 (fax) On the brief: Richard A. Levy Dana Lossia Judy Scolnick Darius Charney 56-001-00001 15512.DOC Case 1:07-cv-02067-NGG-RLM Document 174 Filed 06/25/2008 Page 2 of 38 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 POINT I. Unlawful Employment Practices Uncovered During the Course of Discovery Are Properly Adjudicated In This Case ................................................2 A. The Employment Practices Being Challenged..................................................................2 B. The Challenged Practices Were Part of The EEOC Charges, And Have Been The Subject of Discovery In This Case...................................................5 C. The Challenge to Exam 6019 Should Be Included In This Action And Those Injured by Exam 6019 Are Proper Members of the Proposed Class..............10 POINT II. -
Medal Day Book 2006.Qxp
M E D A L D A Y Manhattan Box 33-1123, 80 Riverside Drive, May 13, 2005. Incident for which FF Francis G. Fee, Jr., received the Emily Trevor/Mary B. Warren Medal. 2 photo by FDNY Photo Unit 0 0 6 MEDAL BOARD Peter E. Hayden Salvatore J. Cassano Michael Canty Chief of Department Chief of Operations Battalion Chief Index of Medals Index of Medal Recipients Dr. Harry M. Archer Medal . .11 Brody, FF Terence F. (Firefighter Kevin C. Kane Medal) . .53 James Gordon Bennett Medal . .13 Burke, Capt. Michael J. (Fire Bell Club Medal) . .47 Cancro, FF Edward F. (Ner Tamid Society/Franklin Delano Brooklyn Citizens Medal/FF Louis Valentino Award . .14 Roosevelt Medal) . .28 Hugh Bonner Medal . .15 Cummins, FF Sean G. (Captain Denis W. Lane Memorial Medal) . .39 Emily Trevor/Mary B. Warren Medal . .16 Dennison, FF Darrell S. Thomas E. Crimmins Medal . .17 (Probationary Firefighter Thomas Wylie Medal) . .54 Dooley (2), Lt. John A. (John H. Prentice Medal) . .20 Thomas A. Kenny Memorial Medal . .18 Duffy, FF Stephen P. (Emerald Society Medal) . .35 Walter Scott Medal . .19 Durante, Lt. Kenneth J. (Henry D. Brookman Medal) . .21 Engine Company 283 John H. Prentice Medal . .20 Lt. Matthew T. Ferris (Bn-41), FF Dellon D. Morgan, Henry D. Brookman Medal . .21 FF Peter J. Fredriksen, FF Michael A. O’Neill, FF Thomas M. Moore, FF Scott D. Colquhoun M.J. Delehanty Medal . .22 (Lt. James Curran/NYFFs Burn Center Foundation Medal) 50 William F. Conran Medal . .23 Engine Company 298 Lt. Michael D. Golini, FF James Lagattolla, Mayor Fiorello H. -
CCR AR 2014.Pdf
The Center for Constitutional Rights is dedicated to advancing and protecting the rights guaranteed by the United States Constitution and the Universal Declaration of Human Rights. Founded in 1966 by attorneys who represented civil rights move- ments in the South, CCR is a non-profit legal and educational organization commit- ted to the creative use of law as a positive force for social change. Design: Nicholas Coster, [email protected]. Photo credits: p 2: Yanick Salazar • p 4: Pam Bradshaw • p 6: Pam Bradshaw • p 7: Juan Manuel, Herrera/OAS • p 11: Qa’id Jacobs • p 12: Qa’id Jacobs • p 14: Alexis Agathocleous • p.15: Snowden: Laura Poitras/Praxis Films. Assange: Cancillería del Ecuador. Manning: courtesy of www.bradleymanning.org • p16: © RON- ALD KABUUBI/epa/Corbis • p.19: Courtesy of Iraq Veterans Against the War/Civil Soldier Alliance • p.20-21: Picture 2: Laura Raymond. Picture 5: Organization of Women’s Freedom in Iraq. Pictures 6, 11, 15: Pam Bradshaw. Picture 10: Courtesy of Iraq Veterans Against the War/Civil Soldier Alliance. Picture 12: Aliya Hana Hussain • p 22-23: Pictures 2, 6: Pam Brad- shaw. Pictures 4, 5: Sameer A. Khan • p 23: Pictures 4, 5 by Sameer Khan • p 27: Pam Bradshaw • p 29: David Hicks: Adam Thomas (devdsp@flickr) • p 30: Top left: Shayana Kadidal • p.32: Chelsea Manning by Alicia Neal, in cooperation with Chelsea herself, commissioned by the Chelsea Manning Support Network • p 33: Top: Pam Bradshaw. Bottom: Kevin Gay • p 34: Bot- tom left: Alexis Agathocleous • p 36: Bram Cymet (bcymet@flickr) • p 41: Bottom: Courtesy of Iraq Veterans Against the War/Civil Soldier Alliance • p 46: Douglas Gorenstein • p 62: Ruby Dee: Courtesy of MDCarchives The Center for Constitutional Rights is a 501(c)3 nonprofit organization. -
Case 1:17-Cv-09447-JPO Document 55 Filed 04/25/19 Page 1 of 74
Case 1:17-cv-09447-JPO Document 55 Filed 04/25/19 Page 1 of 74 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ANNETTE RICHARDSON, ) DEBORAH BOWMAN, ) DEBRA POE, ) DINO RIOJAS, ) STEPHANIE THOMAS, ) BRENDA McKIVER, ) JON WATSON, and ) ERICA RICHARDSON ) ) On behalf of themselves and all others ) similarly situated, ) Civil No. 17-CV-9447 (JPO) ) Plaintiffs, ) AMENDED COMPLAINT ) v. ) CLASS ACTION ) CITY OF NEW YORK, ) ) Defendant. ) ) I. INTRODUCTION 1. For well over a century, the Fire Department of New York (the “FDNY”) has engaged in a pattern or practice of systemic, continuous, and intentional discrimination against African American non-uniformed (“Civilian”) employees and job applicants in hiring, advancement, and compensation decisions. For about 100 years after the Civil War, white men, primarily of Irish and Italian descent, controlled the FDNY at all levels, from upper management to staff. Token integration began during the civil rights movement of the 1960s, but African Americans remained severely underrepresented at all levels of the agency and in all types of jobs. Case 1:17-cv-09447-JPO Document 55 Filed 04/25/19 Page 2 of 74 2. As a result of the broad pattern of racial discrimination, the percentage of African American employees in FDNY as a whole is far less than in other agencies of the New York City government, the percentage of African American employees in higher paying Civilian jobs in FDNY is far less than in lower compensated jobs, and African American Civilian employees are paid lower salaries or wages than white employees in the same job positions in the more highly compensated job categories. -
Case 1:17-Cv-09447-JPO Document 1 Filed 12/01/17 Page 1 of 59
Case 1:17-cv-09447-JPO Document 1 Filed 12/01/17 Page 1 of 59 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ANNETTE RICHARDSON, ) DEBORAH BOWMAN, ) LIZA HORSLEY, ) DEBRA POE ) DINO RIOJAS, ) ARLENE SIMMONS, and ) STEPHANIE THOMAS ) ) On behalf of themselves and all others ) similarly situated, ) Civil No. _____________ ) Plaintiffs, ) ) v. ) CLASS ACTION ) CITY OF NEW YORK, ) ) Defendant. ) ) I. INTRODUCTION 1. For well over a century, the Fire Department of New York (the “FDNY”) has engaged in a pattern or practice of systemic, continuous, and intentional discrimination against African American emergency medical services (“EMS”) and non-uniformed (“Civilian”) employees and job applicants in hiring, placement, advancement, and compensation decisions. For about 100 years after the Civil War, white men, primarily of Irish and Italian descent, controlled the FDNY at all levels, from upper management to staff. Token integration began during the civil rights movement of the 1960s, but African Americans remained severely underrepresented at all levels of the agency and in all types of jobs. 2. As a result of the broad pattern of racial discrimination, the percentage of African American employees in FDNY as a whole is far less than in other agencies of the New York City government, the percentage of African American employees in higher paying EMS and Civilian Case 1:17-cv-09447-JPO Document 1 Filed 12/01/17 Page 2 of 59 jobs in FDNY is far less than in lower compensated jobs, and African American Civilian employees are paid lower salaries or wages than white employees in the same job positions. -
5Oth Anniversary Edition |October 2020
IABPFF “SMOKE" VOLUME 2 |5OTH ANNIVERSARY EDITION |OCTOBER 2020 MEMBER ORGANIZATIONS: The Membership of the lABPFF is comprised of 90 Chapters and represents 5100 fire service personnel and a 200 Lifetime Members. 1 ORGANIZED: Organized Table of Content in Hartford, Connecticut, Words from the President October 3, 1970. Tribute to a Black Fireman (p.2) Inception of the IABPFF (p.3-5) From the Archives (p.6) History of the IABPFF (p.7-13) IABPFF Presidents (p.14) Member Spotlight (p.15) FOUNDING ORGANIZATIONS: Capt. David James Floyd (p.16-17) Vulcan Society Inc., Through the Eyes of a Black Woman (p.18-19) New York, N.Y., Phoenix Society Inc., Health and Wellness (p.20) Hartford, Connecticut, Vulcan Pioneers of New Jersey Inc., Call to Action (p.21) Newark, N.J., Vulcan Pioneers of Hudson County Inc., Election 2020 (p.22-23) Jersey City, N.J., Valiants Inc., Philadelphia, Pennsylvania. VOLUME 2 | 50TH ANNIVERSARY EDITION | IABPFF SMOKE 2 IABPFF “SMOKE” 50th Commemorative Edition We are thrilled to celebrate IABPFF's Semicentennial! Our organization is rooted in its rich history and strong fraternal foundation. Dr. King once said "We are not makers of history; we are made by history" so this newsletter honors those who paved the way and reminds us to never forget how far we have come. In these uncertain times, it is clear that our work is not done. The IABPFF will continue the work of our founders and strive to make every new day better than the last.” Carrie Edwards-Clemons, President VOLUME 2 | 50TH ANNIVERSARY EDITION | IABPFF SMOKE 3 Inception of the IABPFF My introduction to how the IABPFF first Just remember the year before in 1968 Dr. -
FDNY Medal Day 2019
FDNY Medal Day 2019 Honoring Members of the Fire Department — June 5, 2019— MEDAL DAY 2019 Publication of this 2019 edition of the FDNY Medal Day Book Daniel A. Nigro was made possible by several grants. The FDNY gratefully Fire Commissioner acknowledges the generosity of the following contributors: John Sudnik Chief of Department The FDNY Honorary Fire Officers Association Laura R. Kavanagh Jack Lerch, President First Deputy Commissioner Francis X. Gribbon Deputy Commissioner Dorothy Marks Office of Public Information Honorary Fire Commissioner The FDNY Foundation Stephen L. Ruzow, Chairman Jean O’Shea, Executive Director MEDAL DAY STAFF PUBLICATIONS DIRECTOR Joseph D. Malvasio EDITOR Janet Kimmerly GRAPHICS/PRODUCTION Thomas Ittycheria WRITERS Lieutenant John Amsterdam Lieutenant John C. Berna Deputy Assistant Chief Christopher Boyle Captain Patrick Burns Lieutenant Anthony Caterino EMT Nathan Chang Lieutenant Michael Ciampo Captain Michael Doda Assistant Chief Fire Marshal Michael B. Durkin Proudly Serving Since 1865 Firefighter Jacob Dutton Captain Christopher Flatley Lieutenant James Gerber Lieutenant Nick Graziano Firefighter Stephen Interdonati Chief Fire Marshal Thomas G. Kane Lieutenant Ralph L. Longo Battalion Chief Stephen Marsar EMS Division Chief Paul Miano Firefighter Thomas Morrison Battalion Chief Sean Newman Battalion Chief Anthony Pascocello Lieutenant Stephen Rhine EMT Patricia Scaduto Photo Credits Lieutenant Sean Schneider EMS Lieutenant Linda A. Scott Cover Firefighter William Staudt Bronx Box 77-3072, 1547 Commonwealth Avenue/East Tremont Avenue, January 2, 2018. Lieutenant Jon Templeton Photo by FF Michael Gomez, Squad 288. Firefighter Francis Valerio EMT Michael Walsh Firefighter Daniel W. Gordon, Ladder 47, operated at this incident and is receiving the Company EMS Lieutenant Brandy Washington Officers Association Medal. -
United States and Vulcan Society V. City of New York City
11-5113 (L) No. 12-491 (XAP) IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT __________________ VULCAN SOCIETY, CANDIDO NUNEZ, ROGER GREGG, MARCUS HAYWOOD, Appellees / Cross-Appellants UNITED STATES OF AMERICA, Appellee v. MICHAEL BLOOMBERG, MAYOR, NEW YORK FIRE COMMISSIONER NICHOLAS SCOPPETTA, in their individual and official capacities, CITY OF NEW YORK, Appellants / Cross-Appellees __________________ ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK _________________ BRIEF FOR THE UNITED STATES AS APPELLEE _________________ THOMAS E. PEREZ Assistant Attorney General DENNIS J. DIMSEY LISA J. STARK HOLLY A. THOMAS Attorneys Department of Justice Civil Rights Division, Appellate Section Ben Franklin Station P.O. Box 14403 Washington, DC 20044-4403 (202) 514-4491 TABLE OF CONTENTS PAGE STATEMENT OF JURISDICTION..........................................................................1 STATEMENT OF THE ISSUES...............................................................................3 STATEMENT OF THE CASE ..................................................................................3 A. Overview................................................................................................3 B. Factual Background..............................................................................6 C. Procedural History..............................................................................11 1. Disparate Impact Liability And Relief ......................................11 2. Disparate -
Fdny Medal Day 2009
FDNY MEDAL DAY 2009 Honoring The Courage, Commitment and Compassion of FDNY Fire & EMS Members MEDAL DAY 2009 Nicholas Scoppetta Fire Commissioner Salvatore J. Cassano Chief of Department Francis X. Gribbon Deputy Commissioner Office of Public Information MEDAL DAY STAFF PUBLICATIONS DIRECTOR Stephen Paul Antonelli EDITOR Janet Kimmerly GRAPHICS/PRODUCTION Thomas Ittycheria FDNY WRITERS Lieutenant Peter W. Blaich Proudly Serving Since 1865 Division Chief James Booth, EMS Operations Battalion Chief Christopher Boyle Assistant Chief Edward C. Butler (retired) Thomas DeMatas Lieutenant Christopher Flatley Captain John Flynn Barry D. Gintel Firefighter Nick Graziano David Joseph Harney Deputy Chief Fire Marshal John David Lynn Battalion Chief Frank Montagna Lieutenant Sean Newman Photo Credits Lieutenant Anthony Pascocello Front Cover Photo and Photo on Opposite Page FF Jack Thompson (retired) Manhattan Box 44-0861, Captain John T. Vigiano (retired) 305 East 50th Street/2nd Avenue, March 15, 2008. Captain Thomas Woods FDNY Fire and EMS personnel remove victim from crane collapse. Ladder Company 4 members--Lieutenant Christopher M. King and FFs Edward M. MEDAL DESK Coyle, Louis Esposito, Patrick Moore, Daniel Squire and George T. Young-- Firefighter Robert Hart are the recipients of the Company of the Year, World Trade Center Memorial EMT Jeanette Perez Medal; and Paramedic Marco A. Girao, EMS Lieutenant Louis Cook, Dr. EMT Edgar Pitre Dario Gonzalez and Paramedic Juan Henriquez are the recipients of the Christopher J. Prescott Medal for their efforts at this incident. DIRECTOR OF photos by FF Michael Gomez, Squad 288 SPECIAL PROJECTS & EVENTS Lenore Koehler Back Cover Photo PHOTOS BY FDNY PHOTO UNIT Bronx Box 75-2122, 354 East 134th Street, March 17, 2008. -
Engine 249 and Ladder 113
ENGINE 249 AND LADDER 113 FLATBUSH AND THE CAMP Engine 249 and Ladder 113 were placed in service on January 20, 1896. Then it was not part of the FDNY and the fire trucks were not painted white over red or diesel powered. One hundred years ago both, rigs were pulled buy a team of horses and were painted a 2 tone green. Engine 249 and Ladder 113 were called Engine 49 and Ladder 23 back then and were part of the City of Brooklyn, the fourth largest city in the country. One hundred years ago a new tradition was started, a paid fire department, replacing the volunteer system in the town of Flatbush that had been in existence since 1821. One of the six towns making up the City of Brooklyn, Flatbush was first settled in 1652. This rural village would remain a sleepy town until the mid 1880's, at which time the railroad lines were extended through the town. Flatbush became the suburbs for the fourth largest City in America, Brooklyn. The town of Flatbush was annexed by the City of Brooklyn on April 24, 1894. The Brooklyn Fire Department kept the volunteers active until the City could build fire stations, buy equipment and hire manpower. For their services, each of the volunteer fire companies were paid $1,000.00 a year. The Flatbush Department had one engine, five hose companies and three ladder companies. The Brooklyn department had to hire members from the Flatbush Department to man the new companies. Over three hundred members belong to the Flatbush Department, but only forty-four could be picked. -
Guantánamo Still Matters
Winter 2011 CCR and SNAP Charge Vatican Officials With Crimes Against Humanity In the early 80s, in California, Rita was planning to become a nun. But at just 16, she began to be sexually molested by her parish priest, Father Santiago Tamayo. It began with inappropriate touching in the confessional booth, and escalated over two years to Tamayo, and a second priest, coercing sex. Rita was then “introduced” to six other priests and coerced into sex with each of them as often as once a week. Unsurprisingly, Rita soon became pregnant. Father Tamayo urged her to get an abortion but unable to bring herself to that decision, he (with the assistance (financial and otherwise) of the Church and Diocese) arranged for her to be sent to the Philippines under the auspices of a “scholarship” and Survivors and allies spread the word about the ICC filing during European tour. threatened her into silence. While there, at Father Tamayo’s brother’s clinic, Rita attempted to bring a civil case, but Archdiocese had been paying him to Rita was neglected and malnourished church officials insisted they did not remain in the Philippines for years falling into a coma and eventually know the whereabouts of the priests. after the baby was born. Tamayo also giving birth to her daughter in that The case was ultimately dismissed on produced letters which showed that state. Fortunately, Rita’s mother statute of limitations grounds. In March he was being paid by the Diocese discovered her whereabouts and that 1991, Tamayo returned to California and urged to keep that fact secret. -
Rankin & Taylor
Case 1:08-cv-01034-AT-HBP Document 547 Filed 04/20/17 Page 1 of 1 Rankin & Taylor Attorneys at Law __________________________________________________________________________ 11 Park Place, Suite 914 [email protected] New York, New York 10007 Phone: 212-226-4507 Fax: 212-658-9480 VIA ECF ONLY April 20, 2017 The Honorable Analisa Torres United States District Judge United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Floyd, et al. v. City of New York, et al., 08-CV-1034 (AT) Ligon, et al. v. City of New York, et al., 12-CV-2274 (AT) Davis, et al. v. City of New York, et al., 10-CV-0699 (AT) Your Honor: I am member of Rankin & Taylor, PLLC and counsel to Communities United for Police Reform (“CPR”), proposed amici curiae in the above-referenced matters. CPR is a non-partisan campaign with close to 70 formal members which are nonprofit and community-based organizations from across New York City. CPR is a named community stakeholder in the remedial process in Floyd et al. v. City of New York. In such capacity CPR has been engaged in the remedial process since its inception. In support of the Floyd plaintiffs’ objections to the Monitor’s April 11, 2017 Memorandum to the Court regarding the Approval of Body-Worn Camera Policies, they respectfully request permission to file the attached amius curiae statement. As Your Honor knows, “[f]ederal courts have discretion to permit participation of amici where such participation will not prejudice any party and may be of assistance to the court.” Strougo v.