DECLARATION OF ROSA CEJA

I, Rosa Cej a, under penalty of perj ury, state based on personal knowledge that the following
facts are true and correct:

1. I am over the age of 21 years.

I 2. I currently reside in Waukegan, Illinois.

3. I have been employed with Personnel Staf?ng Group, LLC df?bfa MVP 
since on or about March 1, 2014.

4. From approximately March 1, 2014 to June 22, 2014, I was employed by MVP as
an onsite manager at one of client companies located in Waukegan, Illinois (?Waukegan
Client?), which was primarily served by 'Waukegan of?ce located at 226 Sheridan Road in
Waukegan, Illinois (?Waukegan Of?ce?).

5. From approximately June 23, 2014 to approximater August 26, 2014, I was
transferred by MVP to work at its Elmwood Park Of?ce located at 7514 W. North Avenue in
Elmwood Park, Illinois (?Elmwood Park O?ce?) as a dispatcher. The manager of the Elmwood
Park O?ice is a man named Billy Flatt.

6. For approximately two or three weeks after August 26, 2014, I worked as an
assistant onsite manager assisting onsite manager Maciel Ramos at one of 3 client companies
in Niles, Illinois (?Niles Client?), which was primarily served by Elmwood Park Of?ce.
Dining this period, Mr. Ramos was the onsite manager for multiple client companies of WP.

7. In about mid-September of 2014, I became the cnsite manager at the Niles Client.

8. On or about early October 13, 2014, I was reassigned by Billy Platt to be a
dispatcher at the Ehnwood Park O?ce and scheduled to work a shift from 4:00 pm. to midnight

each day. On October 14, 2014, I emailed Mr. Platt to let him know that I could not work that late

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Shift at the Elmwood Park Of?ce because I did not feel safe closing the of?ce by myself at that
late hour. lhaire not been offered another assignment by MVP to this date.

9. As a dispatcher at the Elrnwood Park Of?ce, my job was to take applications from
laborers seeking work assignments, to ?ll orders for laborers given to me each day either by 
onsite managers at the various client companies or directly by a client company, and to submit the
hours worked by laborers, as reported to me by onsite managers or clients, to payroll of?ce.

10. Typically, laborers who came to Ehnwood Park Of?ce seeking a work
assignment would ?ll out an application With their contact information on the ?rst day they came
to the dispatch of?ce, even if not assigned to work, and would sign in on a sign-in sheet in the
dispatch of?ce each day. Whiie I was employed as a dispatcher at Elmwood Park Of?ce,
poiicy was to retain a copy of both laborers applications and the daily sign-in sheets. The
practice was to place the active applications on the top shelf sorted alphabetically in the diapatcher
area and the inactive applications on the bottom shelf. At the Elmwood Park Of?ce, an application
became inactive after three attempts to call and assign a laborer Without a response.

11. While employed at MVP, I regularly talked to other dispatchers in Cicero
o?ce located at 5637 W. Roosevelt in Cicero, Illinois (?Cicero of?ce?) and Waukegan Of?ce. I
also regularly visited each of those of?ces to see other dispatchers who are my friends and for
business reasons. For example, MV asked me to deliver checks to laborers assigned out of the

- Cicero Of?ce. So on multiple occasions I spent several hours on weekend days at the Cicero Of?ce
while laborers came to pick up their checks. While I Twas there, I had the Opportunity to talk to the
dispatchers there at length about the Cicero Of?ce?s practices and policies. As a result, I know that
these of?ces followed the same practices for taking applications, using sign-in sheets and
preserving active and inactive applications as described in paragraph 10, except that applications

became inactive at the Waukegan and Cicero O?ices a?er three (3) months of no assignment
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12. While employed as a dispatcher at the Ehnwocd Park Office, I know that MVP 

dispatchers, including myself, would ?ll client company orders for laborers using the following
methods: assigning laborers who walked into the dispatch o?ce seeking a work assignment;
calling laborers who had previously left their contact information; taking phone calls from laborers
with active applications who were seeking assignments; and assigning laborers who had been
recruited and were transported to the MVP Elmwood Park Of?ce by team of van drivers.

13. While I was employed as a diapateher, the Ehnwood Park Of?ce typically assigned
about (50) laborers on each of the three daily shifts, or aboat one hundred and ?fty (150)
laborers in total each day, although the number would vary somewhat

14. I know ?om conversations with dispatchers at Cicero Office, that the
practices of assigning laborers at the Elmwood Park Of?ce described in paragraphs 10 12 above
was the same protocol followed by the Cicero Of?ce in recruiting and assigning laborers, although
I was told by Cicero Of?ce dispatchers that they typically assigned a lot more laborers than
Ehnvvood Park to client companies each day.

15. To the best of my loiowledge, the MVP Cicero Of?ce has a total of eight (8)
dispatchers and the Elmwood Park O??ice has ?ve (5) dispatchers. All of the dispatchers work
under the close supervision and direction of the of?ce managers and Darren Grotollo, Director of
Operations for MVP, and company owners Daniel Barnett and David Barnett.

16. To the best of my knowledge, MVP employed approximately ten (10) van drivers
in total. Through conversations with van drivers and other dispatchers, I know that the van
drivers generally recruit laborers from the Little Village area of Chicago, particularly in the area
of 26d? Street and St. Louis Street. I know that all of the laborers recruited and transported by the
MVP van drivers to the Elmwood Park Of?ce While I was working at that of?ce were Latinos. I

also know, through conversations with van drivers and other dispatchers at Elnawood Park
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Of?ce and Cicero O?ce, that van drivers recruited and transported only Latino Iaborer?s
to dispatch of?ces.

17. I know that certain clients of MVP do not want African American?s assigned to
work at their companyr and that MVP has a policy and practice of accommodating these requests.
In fact, I have personally bean yelled at by representatives of client companies, including the
Waulcegan Client, about African Americans I assigned, and I have been warned by David Barnett
and o?ce managers not to send African-Americans because MVP could lose the account if I did.

18. I know through my experiences and conversations with other dispatchers, of?ce
managers and other MVP management that MVP has a policy and practice of preferring Latino
laborers, without consideration of individual factors such as special skills or abilities.

19. I believe that many of clients preferred immigrant workers because they are
less liker to complain about things like being injured on the job or being underpaid. MVP had a
rule in all of its branch emcee in Illinois that dispatchers and onsite managers could not refer to a
laborer?s race when communicating about orders for laborers but instead should use code words.
For example, dispatchers, including myself, were told to use the term ?fees? (translated as ?ueg
ones?) to refer to Latinos and ?guapos? (translated as ?handsome ones?) to refer to African
Americans, or to use ?bilingues? or ?bilinguals? to refer to Latinos and ?no bilingues? or ?not
bilinguals? to refer to African-Americans. I know this because I was told this directly by of?ce
managers and because I regularly talked to diapatchers in other of?ces and learned that they were
told the same thing.

20. The Waukegan Of?ce Manager, for example, told me directly that these had been
the rules for MV ?forever? and that if Darren Grotollo ever found us using the terms ?black?,
?mean-American?, ?Hispanic? or ?Latino? instead of these code words to describe a laborer?s

race, we would be ?red.

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21. I know them conversations with other dispatchers, including at Cicero
Of?ce, that they were similarly warned to follow the same policy and practice when a client does
not want A?ican?iamericans assigned at its company. I know from conversations udth dispatchers
at Cicero Of?ce that Gold Standard Baking, Inc. did not want A?ican?Americans
assigned to work there.

22. In a conversation with diapatchers ?'om Cicero O?ce, I learned that MVP
employees also used the expression ?los que escuchan a La Lay? or ?a La Que Buena? (translated
as ?those who listen to La Ley? or to ?La Que Buena?, the names of Spanish-language radio
stations in the Chicagoland area) to refer to Latinos.

23. When Cicero O?ce did not have enough laborers to ?ll orders for its client
companies, those dispatchers would call Elmwood Park Of?ce to request that we provide
extra laborers to them from the Elmwood Park Office and vice versa. This exchange of laborers
between offices happened almost every day? On several occasions, I took calls ?'om Cicero
Of?ce making such a request myself. I

24. When dispatchers at the Cicero O?ice requested extra laborers from the Elmwood
Park Of?ce to complete orders at GSB, we were told GSB only wanted Latinos.

25. In fact, one time when I was at the Elmwood Park Of?ce, Darren Grotollo called
and asked me if we had any laborers available to work at GSB ?que escuchan a La Ley? (translated
as ?who listen to [Spanish-language radio station] La Ley?, which I understood to mean Latinos.

26. To be able to work at GSB, laborers only needed to participate in an orientation and
watch a video which was provided after MVP made the assignment. No special prior training or
skills were required for a laborer to be assigned to GSB.

27. I am not suffering any impediments and am competent to testify to all of the

foregoing.

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I declared under penalty 0f perjury that the foregoing is true and correct.

Executed Dated: Nevember 20, 20 14

   

Rosa Ceja

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