UNITED STATES DISTRI
SOUTHERN DISTRICT OF
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:
EQUAL EMPLOYMENT OPPORTUNITY : Civil Action
COMMISSION, :
Plaintiff, : cmrPLAINT
-against-
MORGAN STANLEY & CO., )[NC., and
MORGAN STANLEY DEAN WITTEIR,
Defendants.
NATURE OF THE ACTION
This is au action under Title VII of the Civil Rights Act of 1964 and
. . Rights Act of 1991 to .co~ect+nl+ul employment practices on
to provide appropriate.reli&to Allison Schieffelm and a +ss of. female
affected by such practices. Plaintiff, the U.S. Equal Employment Opporttmity
contends that since 1995, Defeudarlts, Morgan Stanley & Co., Inc. and Morgan
Witter ("Morgan Stanley"), have engaged in a pattern or practice of discrimination
Schieffelin, a woman, and other females who hold the positions of Associate,
Principal and Managing Director in Defendant's Institutional,Equity
promote and compensate them and by discrimina ting against them in terms,
privileges of employment, all in continuing violation of Title VU.
contends that Morgan Stanley retaliated against and terminated Allison Schieffelin
rights under Title VII by complaining about sex discrimination.
JUFUSDICTION AND VENUE
1, Jurisdictionoftbis Courtisinvokedpursuant to 28 USC. $9
SNIPPETS:
-against-This is au action under Title VII of the Civil Rights Act of 1964 and Title I. of
contends that since 1995, Defeudarlts, Morgan Stanley & Co., Inc. and Morgan Stanley Dean
Schieffelin, a woman, and other females who hold the positions of Associate, Vice-President,
contends that Morgan Stanley retaliated against and terminated Allison Schieffelin for
rights under Title VII by complaining about sex discrimination.
The unlawful employment practices alleged below were and are now being committed
witbin, but not limited to, the jurisdiction of the United States District Court for the
in an industry affecting commerce witbin the meaning of Sections 701,, and of Title VII,
More than thirty days prior to the institution of this lawsuit,
Morgan Stanley has engaged in a pattern or practice of unlawful
positions ofAssociate, Vice-President, Principal andManaging Director in Defendant's
Equity Division, in promotion, compensation, terms, conditions and privileges of employment,
discrimination, all in continuing violation of Sections 703and 704of Title VII, 42 USC.
The effect of the practices complained of in Paragraph 7 above ha5 been to deprive
Allison Schieffelin and a class of female employees who hold the positions of Associate,
the Commi55ion respectfully requests that this Court:
Grant a permanent injunction enjoining Morgan Stanley's officers, successors,
which discriminate on the basis of sex and retaliation;
Order Morgan Stanley to make whole all those individuals affected by the unlawful
and frontpay, in amounts to be determined at trial, and other afkmative relief necessary to
by providing compensation for past and future pecuniary
H. Award the Commission its costs in this action.
The Commission requests a jury trial on all questions of fact raised by its Complaint.
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