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1
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COMPLAINT
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EXTRACTED KEY WORDS
BELLSOUTH PROMOTION AFRICAN AMERICAN GRIFFIN DISCRIMINATION PRACTICES COMPENSATION PLAINTIFFS LEVERT WILLIAMS JOHNSON EMPLOYMENT JENKINS MANAGEMENT POSITIONS VII CAUCASIAN EMPLOYEES PEGGY JOHNSON EXCESSIVE SUBJECTIVITY CIVIL RIGHTS ACT TECHNICIAN SUPERVISOR BELLSOUTH CORPORATION EQUAL COMPENSATION EEOC GLADYS JENKINS DENISE LEVERT BMAT TEST PREDECESSOR COMPANIES SALARIED EMPLOYEES |
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
________________________________________
GLADYS JENKINS, DENISE LEVERT, DAVID )
WILLIAMS, PEGGY JOHNSON, and SHARON )
GRIFFIN on behalf of themselves and all similarly )
situated persons, ) No.
__________
)
Plaintiffs, )
)
vs. ) COMPLAINT
)
)
BELLSOUTH CORPORATION, ) JURY TRIAL DEMANDED
)
Defendant. )
________________________________________ )
I. NATURE OF THE CLAIMS
1. The Plaintiffs bring this action to challenge a pattern and practice of race
discrimination committed by BellSouth Corporation ("BellSouth," "Defendant" or "the
Company") against current and former African American employees as defined below at
paragraph 28. The violations are systemic in nature, and constitute a pattern and practice of
conduct that for many years has permeated, and continues to permeate, BellSouth's domestic
operations. The employment policies and practices of BellSouth have the effect and have been
undertaken with the purpose of denying promotional opportunities and equal compensation to
qualified African American employees in violation of 42 U.S.C. § 1981 ("Section 1981") and
Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, ("Title VII") and
Civil Rights Act of 1991, 42 U.S.C. § 1981a. Plaintiffs Gladys Jenkins, Denise Levert, David
SNIPPETS:
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