AMERICAN CIVIL LIBERTIES UNION
OF NEW JERSEY
Edward L. Barocas (ELB-8251)
John C. Salyer (JS-4613)
35 Halsey Street, Suite 4B
Newark, NJ 07102
973.642.2084
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
Reginald T. Shuford
E. Vincent Warren
125 Broad Street,18th Floor
New York, NY 10004
212.549.2500
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
EDGARDO S. CUREG, and ) Civil Action No.:
)
THE AMERICAN ARAB ANTI- )
DISCRIMINATION COMMITTEE, on behalf ) COMPLAINT FOR
of its members and its constituents, ) DECLARATORY AND
) INJUNCTIVE RELIEF
)
Plaintiffs, )
)
vs. )
)
CONTINENTAL AIRLINES, INC., )
)
)
Defendant. )
_____________________________________ )
Plaintiffs Edgardo S. Cureg and the American-Arab Anti-Discrimination Committee, by and
through their counsel, American Civil Liberties Union and American Civil Liberties Union of New
as and for their Complaint allege the following:
SNIPPETS:
AMERICAN CIVIL LIBERTIES UNION OF NEW JERSEY
Newark, NJ 07102
Attorneys for Plaintiffs
Plaintiffs Edgardo S. Cureg and the American-Arab Anti-Discrimination Committee,
Edgardo S. Cureg and the American-Arab Anti-Discrimination Committee
bring this action seeking declaratory and injunctive relief against Continental Airlines for
agents of the defendant unlawfully removed Mr. Cureg
perceived race, color, ethnicity, alienage, ancestry, and/or national origin.
members and constituents of the ADC in like fashion.
New Jersey Law Against Discrimination,
injunctive relief requiring defendant to desist from and remedy such discriminatory action.
This civil rights lawsuit is brought to ensure that the promise of equal treatment
subject a person in air transportation to discrimination on the basis of race, color,
discriminating against passengers perceived to be Arab or Middle Eastern have risen
sending an e-mail to several major airlines, including Continental Airlines, in which it
propensity of members of any racial, ethnic, religious, or national origin group to engage in
first time added a category of complaints specifically addressing alleged incidents of
valid ticket simply because, he was told, a fellow passenger felt uncomfortable having him on
Continental Airlines, by its conduct during and after Mr. Cureg's removal from his flight,
It was his colleague, Dr. Saraleesan Nadarajah, a mathematics professor at USF.
Defendant's actions were intentional and done in violation of plaintiff Mr. Cureg's
Title VI of the Civil Rights Act of 1964
December 31, 2001, is a "place of public accommodation" within the terms of the New Jersey Law
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