FORMAL CHARGE or DISCRIMINATION

1, Willie Vaughn, an African Anterican over the age of fem-years, applied 
Stand-By Personnel in February 200?. I still have a current application with Stand-By.
Throughout the yearsthat I have been listed as available to work with Stand-By, I have
not been placed in any positions. Iain aware that Stand-By engages in a pattern and
practice of discrimination based upon race, age, disability, and gender by ?lling open
positions with its? client companies in'a discriminatory fashion or pursuant to the client?s
discriminatory requests. I have'been personally affected by this practice of
discrimination, as I am aware of companies who have requestedthat Stand-By 
Caucasian individuals in positions with them. This request and Staud?By?s achiescence
to this request directly affected me as an African American Who was quali?ed and
available, for the open position. I have also been personally a??ected by Stand-By?s
acquiescence to company requests to send only individuals who are under thirty-?ve
years old. Because I amiover forty, I was automatically. eliminated from consideration for
the position due to my age.

I, Gloria Ferrell, an African American female over the age of forty-years applied
with Stand-By Personnel in December 2007. I updated my application in March 2011 and
I still have a current application with Stand?By. Throughout the years that I have been
listed as available to,work with Stand-By, I have not been placed in any pesitions. I am
aware that Stand-By engages in a pattern and practice of a discrimination based upon race,
age, disability, and gender by ?lling open positions with its? client companies in a
discriminatory fashion or  to the client?s diSeriminatory requests. Ithave been
personally affected by  pattern and, practice of discrimination, as I am aware of
companies who have requested that Stand-By only place Caucasian individuals in
positions with them. I am alsoawa're of companies that have requested that no women be
placed in positions with them and over the age of thirty-?ve be sent to them
either. These requests and these. requests directly a??eicted me
as an African American female over the age of forty who was quali?ed and available fer
the open pesitions. I have also been personally a?ecte'd by Stand-By?s acquiescence to
company req?bests to send only individuals who are under thirty~?ve years Old; Becausel.
am over forty, I was automatically eliminated from Consideration for the position due to
my age.

I, Cara Brown, an African American female over the age of ferty-years applied 
with Stand-By Personnel in 2008. updated my application in December 2010 and I still
have a current applicatiOn with Stand-By. Throughoutthe years that I hare-been listed as
available to work with StandaB'y, I have not been placed in any positions. I am aware that
Stand-By engages in a pattern and practice of discriminatiozr based upon race, age,
disability, and gender by ?lling open positions with its? client companies in a
discriminatory fashion or pursuant to the client?s discriminatory requests. I have been
personally affected by  pattern and practice of discrimination, as I am aware of
companies who have requested that Stand?By only place Caucasian individuals in
positions with them. I amalSO aware of companies have requested that noiwomen be
placed in positions with them and no one over the age of thirty??ve be Sent to. them
either. These to these requests directl affected 

 

  

 

as an African American female over the age of forty who was qualified-and available for
the open positions. I have also been personally a?ected by Stand-By"s acquiescence to
company requests to send only individuals who are under thirty-?ve years old. Because I
am over forty, I was automatically eliminated from consideration forthe position due to

my age. -

1, Curtis Counce, an African American overthe age of forty-years, applied with
Stand-By Personnel in72007. I reapplied with Stand :By' in 2009 and wasinever'place'd in? a
position upon my reapplication. I am aware that Stand-By engages in, a pattern and
practice of discrimination based upon race, age, disability, and gender by ?lling open
positions with its? client companies in a fashion or pursuant to the
company client?s discriminatoryrequests. I have been personally affected by this pattern
and practice of discrimination, as I am aware of companies who have requested that
Stand-By only place Caucasian individuals in positions with them. This request and
Stand?By?s acquiescence to: this'request directly affected me as an African American who
was quali?ed and'available- for  Open position, I have also been personally affected by
Stand?By?s acquiescence to company requests to send only individuals-who are under
thirty~?ve years old. Because I am over forty, 71 was automatically eliminated from
Consideration for the position due to my age.

The following companies are the Companies that we areaware ?of that have placed
discriminatory requirements on their job order forms  Stand-By has ?lled:

Brown Engraving

BLM Equipment andpManufacturing, Inc.
Arno Battery and Electric

Halcyon Marble and Granite, Inc.

There is another companyrequest for which I do not yet blow the name of the
company but it requested that no black people be-psent for open positions and used- the
term, ?Good ?01 Boy? in its request as a means to request that StandaBy send only
Caucasian individuals to work.

We are also aware that SStandi?By has used a-coding system to identify minoiity
applicants in order to:  in  and job planement based upon race.

We believe that the alanine?described unfavorable treatairent by Stand-By and it?s
client companies is the result of a; company-wide, general pattern and practice of
discrimination against African Americans and all other minorities, individuals over the
age of forty, women, and: individuals with disabilities; I believe the above described
unfavorable treatment and employment practices also have a disparate impact on African
Americans, individuals over the age of forty, women, as well as individuals with
disabilities. We bring this charge alleging both disparate treatment and disparate impact
discrimination on our own, individual own behalves and on behalf of all Stand?By
employees who are or were employed by Stand?By, and all Stand?By applicants who.

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were rejected for positions in Oklahoma with Stand-By or its client'COmpanies at any
time during the liability period as detennined by the courtly Stand-By and its elith
companies have disc?minatecl and: continue to discriminate on the basis of race, age,
disability and sex against its  and employees by placing discriminatory
requirements on job -requeStS' and in? ?llng those job requests. By ?lling these
discriminatory requests, every" other protected class who has an application with Stand-
By and is available to work is, adversely affected.

Through this conduct, I believe that Stand-By and its client companies discriminate

against its African American employees, its female employees, its (Wear the
age of forty years, as well as its disabled employees in violation of Title VII of the Civil
Rights Act of 1964, as amended, 42 {1.87.0 Sec. et seq., and the Americans with

Disabilities Act.

We are exhausting these claims on behalf of individuals izvith applications at
Stand-By currentbr, and during-the liability period as determinedby the Court, who are
Oklahoma residents. 

 
 
  
 
    

 

me saves true and correct-

 

 

the abOVe charge mid that it is  to the
best of my knowledge, information and belief.

 

 

 under penalty 'pezjmy ?iat the.;above is true and 6033?-

  

 

       
 

 



f: - . a read th? aboVe charge  that-it is true to $6

be of my kn Wedge, information and belief.

SIGNATURE OF COMPLAINT

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under penalty perjury

. j"  

theiaboiie is true  Contact

 
     

 

  
  

  

or af?rm. that I

 

 

achr'ead the above charg?  _.fji; is"  t0 the

 

Iswear

best of my knowledge, informa?dn and belief.? 
SIGNATURE OF COWLAJNT