Case Documentl 04/02/07 Pagelof 12 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA MORRIS STONE CIVIL ACTION NO: and MURRAY HEBERT 7 VERSUS SECTION: CLAYTON HOMES INC OR CHM HOMES INC JUDGE MAGISTRATE PETITION FOR DAMAGES AND TITLE RETALIATION PERFECTED CLAIMS OF MORRIS STONE AND MURRAY HEBERT NOW INTO COURT, through the undersigned counsel, comes MORRIS STONE, and MURRAY HEBERT who respectfully requests redress forthe following reasons, to-wit: 1. Jurisdiction and Venue The jurisdiction of this Honorable Court is invoked Pursuant to 28 USC 1331 "Federal Question" and accordingly plaintiffs specifically seeks relief pursuant to the Title VII of the Civil Rights Act of 1964 for damages as well as over all state law claims. 2. Venue is proper pursuant to 28 USC 1391 in that a substantial part of the events giving rise to this claim occurred in East Baton Rouge Parish which lies within the jurisdiction of this Court. Parties PLAINTIFFS: Morris Stone is a major domiciled in the Parish of East Baton Rouge, State of Case 3 Document 1 04/02/07 Page 2 of 12 Louisiana. Murray Hebert is a major domiciled in the Parish of Livingston in Denham Springs. Louisiana. DEFENDANTS: CHM Homes, inc. f/d/b/a Clayton Homes. Inc. is a foreign corporation licensed to do and doing business in the State of Louisiana, During all relevant times, Defendant has had at least 15 employees . 5, GENERAL ALLEGATIONS Clayton Homes, Inc. wasthe employerfor both Mr, Morris Stone and Murray Hebert. 6. Mr. Stone and Mr. Hebert were terminated from their employment after reporting harassment on several occasions to a direct supervisor on behalf of Melvin McNeal. 7. MORRIS STONE: Plaintiff, Morris Stone was hired as a Sales person for Clayton Homes in March 2003, 8. Murray Hebert was the Manager at Clayton Homes at the time Mr. Stone was hired. 9. While employed, Mr. Stone worked with several othersales people including - Case 3 Document 1 04/02/07 Page 3 of 12 10. Murry Hebert hired _in early 2004. 11. Mr. Stone had previously been a co-worker of -1 Sanders Mobile homes 12, Sometime after Mr. Stone began his employment. Mr. Murray Hebert hired Melvin McNeal in 2004. 13. Melvin McNeal, an Atrican American male wasthe onlyAfrican American employed during Mr. Stone's employment with Clayton Homes, Inc. 14. Mr. McNeal has previously filed petition for damages through the EEOC captioned Equal Employment Opportunity Commission v. Claylon Homes, lno.. Number 07-cv-91, wherein Mr. McNeal has alleged in part that he was discriminated on the basis of race in violation of law to which Plaintiffs herein seek consolidation out ofJudicial Economy. 15. Mr. Stone reported and supported Mr. McNeal's complaints of racial discrimination while both were employed at Clayton Homes. Inc. 16, Specifically, Mr. Stone reported to his supervisors, Mr, Hebert and late- that _did not like Melvm McNeal because he was black. She and - 3 Case 3 Document 1 04/02/07 Page 4 of 12 sat and starred at Melvin McNeal for no reason. 17. Mr. Stone later reponed that he heard Nancy call Melvin a mi t7, About two weeks af'terMerin was hired Mr. Stone heard_ the district/regional sales manager ask Murray Hebert if he knew Melvin was Black when he hired him. Murray responded didn't know." That was the end of the conversation. 18. Mr. Stone reported that he heard--refer to Melvin McNeal as "buckwheat". Mr. Stone reported that-- began referring to the lot as "niggerville" after Melvin McNeaI was hired and in his presence. 19. Mr. Stone reported that --used the word nigger at least a dozen times at work to Mr. Stone in general conversation wherein Melvin McNeaI may have been present. Mr. Stone told _after hearing these remarks. that's not right," 20. Mr. Stone reported tha_and another sales person. talked all the time. Mr. Stone reported that- and -- would stare at Melvin McNeal all the time In an intimating manner. Mr. Stone reported that he never heard - - refer to Melvin McNeaI by name, he simply said. can't stand that black man." 21. In July 2004, Murray Hebert was terminated. He was replaced as manager of the Baton Rogue store by_. Mr, Stone would go outside with-- from July until his termination in November 2004 and would report to Mr.-bout 4 Case 3 Document 1 04/02/07 Page 5 of 12 --calling Melvin McNeal names and staring at him. Mr. Stone told - -on several occasions that was not right. Mr. Stone would tell--"You ought to do something about this, it is just not right. They are picking on this guy for no reason. 22. In November 2004, Mr Stone and Melvin McNeal were fired on the pretext that we didn't meet quotas. There was supposed to be a two new home sales quota for November 2004 for all sales people, however after Mr. Stone spoke with employees at another location ofCIayton Homes in Lafayette, Louisiana, and Gonzales, Louisiana, his suspicions were confirmed that the sales quota was only for his office. and the purported sales quota was enforced on himself and Mr. McNeal as_was not terminated and did not sell two houses, 23. Carol Woodall, who was a contractor to repair the repossessed homes also confirmed there was no company policy to sell two new homes in the month of November 2004 making the termination pretexural. 24. Mr. Stone reported that sometime in August or September Melvin McNeal asked Mr. Stone to report racial harassment with him to the then supervisor, to report racial harassment of_ against Mr. McNeal. 25. -- a manager, fired Mr. Stone after reporting harassment of- _against Melvin McNeaI for reporting the harassment, 5 Case 3 Document 1 04/02/07 Page 6 of 12 26. The day after Mr. Stone and Mr. McNeal were terminated._ who had previously left the employment of Clayton Homes. Inc. to take a job at Conn's came back as a sales person. 27. Mr. Stone reported that-would never talk to Mr. Stone and-- condoned the discrimination of - and- against Melvin McNeal, in fact Mr. - himself told Carol Woodall to take a black family out to a foreclosing property 'to show them the house and maybe the family (who was white) will pay off the house and property". 28. Mr. Stone would report to--about slurs that--used in the office and he would only say know, I know." He never responded with any other comments. 29. Mr. Stone filed a oomplaintwith the EEOC forthe retaliatitory termination on based on his reports of racial discrimination and harassment of Melvin McNeal to while working at Clayton Homes, Inc. 30. On February 8. 2007. Mr. Stone received a right to sue letter from the EEOC which found "reasonable cause to believe that violations of the statute(s) occurred With respect to some or all of the matters alleged in the See attached exhibit 31 . 6 Case 3 Document 1 04/02/07 Page 7 of 12 After his termination Mr. Stone suffered losses attributable to the loss of his job including a loss of insurance benefits and a loss of income which forced Mr. Stone to declare bankruptcy. 32' MURRAY HEBERT: Murray Hebert was the general manager of Clayton Homes, Inc. for approximately one and a half years until July 7. 2004, when he was discharged from his position in retaliation of reporting racial discrimination of Melvrn McNeal by a co-worker under his supervision,--to his supervisor,_. And also in retaliation for hiring Melvin McNeal. an African American to work as a sales person in Baton Rouge, Louisiana 33. Mr. Hebert received complaints of racial discrimination from Melvin McNeaI and Mr Morris Stone regarding a co-employee, referring to the place of employment'niggerville" also, she also starred at Mr. McNeal and treated Mr. McNeal with disdaint 34. Mr. Hebert reported to_the regional manager that he had a racial problem with--. He relayed to_that_called the place of employment "niggervillev" Mr. Hebert reported to_that_would treat African American customers differently with disdain; and Mr. Hebert reported to Mr -tnat--would not report after hours sales calls left for Mr. McNeal to 7 Case 3 Document 1 04/02/07 Page 8 of 12 him. 35 _responded to Mr. Herbert that he did not consider those reports that important or serious. Mr. Hebert also reported possible theft problems and- him to investigate further. 36. After the report, Mr. Hebert actually overheard state that she "hated niggers" at the office. Mr, Hebert heard_ commentto a contractor, can't help myself, hate niggers." 37. Mr. Hebert then completed the investigation of her background and theft and faxed a report of character to-- 38. At that time. Mr. Hebert terminated--on her day off. by telephone. and asked her to come in to meet him. 39. Ms-apparenlly called Mr.-from herhome and informed Mr. - of her termination. 40. Mr. - called Mr. Hebert at the place of employment a few hours after Mr. Herbert had informed Ms.-she would need to come in to determination paperwork and Mr.-told Mr. Hebert he could not fire Ms. -. 41. 8 Case 3 Document 1 04/02/07 Page 9 of 12 The following day, Mr. Hebert then confronted Ms. - regarding her discriminatory comments and actions. He used a three B's approach. He talked to her about her breath, body odor, and the black comments and treatment. He told herthat her actions were despicable that depriving Melvin McNeal of his sales calls was depriving him of his Iivelyhood. 42. Mr-then terminated Mr. Herbert within a week of Mr. Herbert's attempted termination of Ms-and his attempted intervention into her discrimantroy actions. 43. Mr.-did not give any reason for the termination. Mr.- offered a demotion to Hammond. Louisiana, which Mr. Hebert did not take. 44. Mr. Hebert reported to the EEOC that afteer. Hebert hired Mr. McNeal, Mr, Hebert was questioned by Mr.- "did you know he was black?" 45. Such acts constitute intentional infliction of emotional distress. 46. The actions and/or inactions of defendants caused Plaintiffs severe emotional distress, mental anguish. past and future lost wages and benefits. loss ofearning capacity, humiliation, embarrassment, medical expenses. togetherwith such other damages as will be more fully shown at trial of this matter. 47. Mr. Hebert filed a complaint with the EEOC forthe retaliatitorytermination on based 9 Case Documentl 04/02/07 Page 10 of 12 on his reports of racial discrimination and harassment of Melvin McNeal to while working at Clayton Homes, Inc. 48. On February 8, 2007, Mr. Hebert received a right to sue letterfrom the EEOC which found ?reasonable cause to believe that violations of the statute(s) occurred with respect to some or all of the matters alleged in the See attached exhibit 49. The following claims for relief are pled collectively and in the alternative. 50. FIRST CLAIM FOR RELIEF Plaintiffs seek relief under Title VII or 42 USC 2000e et seq., for which an administrative complaint has been administratively filed, and a rightto sue has been issued for Mr. Stone and Mr. Hebert. 51. SECOND CLAIM FOR RELIEF Mrrs. Stone and Murray were retaliated against in violation of Title VII or 42 USC 2000e et seq. and are entitled to damages pursuant to 42 U.S.C.A. 1981a for Damages in cases of intentional discrimination in employment having a right of recovery in an action brought by a complaining party. . . under section 703, 704U.S.C.A. 2000e-2, 2000e-3, or 2000e-16], and provided that the complaining party cannot recover under section 1981 of this title, the complaining party may recover compensatory and punitive damages. 1O Case Documentl 04/02/07 Page 11 of 12 52. THIRD CLAIM FOR RELIEF Plaintiffs pray for appropriate compensation for past and future pecuniary losses resulting from the unlawful employment practices described above, including all reasonable expenses, in amounts to be determined at trial. 53. FOURTH CLAIM FOR RELIEF Plaintiffs pray for appropriate compensation for all past, present and future emotional pain, suffering, inconvenience, loss of enjoyment of life, and humiliation, in amounts to be determined at trial 54. FIFTH CLAIM FOR RELIEF Plaintiffs pray for all other relief reasonable in premises. 55. This Court has jurisdiction over this claim pursuant to 28 USC 1367. 56. JURY TRIAL REQUESTED In accord with FRCP Rule 38, Plaintiffs pray forjury trial on all issues. WHEREFORE, Plaintiffs pray that Defendant be cited to appear and answer and that after resolution of this matter that this Court enter Judgment in favor of Plaintiffs against defendants with legal interest from the date of demand as follows: (1) Lost back and front pay and all other lost employment benefits; 11 Case Documentl 04/02/07 Page 12 of 12 (5) For emotional and mental distress, pain and suffering, humiliation, embarrassment and loss of employment opportunity; Medical and pharmaceutical bills and services past, present and future; All litigation expenses; For attorneys fees, punitive damages and for costs as may be allowable by law; For such other relief that the Court may deem just, equitable or proper. Respectfully submitted: S/Charlotte McDaniel McGehee Donna U. Grodner, T.A. (20840) Charlotte C. McDaniel McGehee (26411) GRODNER ASSOCIATES 2223 Quail Run, B-1 Baton Rouge, Louisiana 70808 (225) 769-1919 FAX 769-1997 PLEASE SERVE: THROUGH REGISTERED AGENT FOR SERVICE CHM HOMES INC f/d/b/a CLAYTON HOMES, INC. WILMINGTON TRUST SP SERVICES, INC. 1105 N. Market Street, Ste 1300 Wilmington, DE 19801 12 Case Document 1-1 04/02/07 Page 1 of 1 e13 44 (Rev-11m) CIVIL COVER SHEET The 44 civil cover sheet and the information contained herein neither re lace nor supplement the ?ling and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference 0 the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) I. PLAINTIFFS DEF ENDANTS Morris Stone and Murray Hebert Clayton Homes Inc. or CHM Homes Inc. County of Residence of First Listed Plaintiff EaSt Baton Rouge County of Residence of First Listed Defendant Wilimngton Daleware (EXCEPT IN US. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOLVED. (C) Attorney?s (Firm Name, Address, and Telephone Number) Attorneys (If Known) Grodner Associates, 2223 Quail Run Drive Suite B-l, Baton Rouge, Unknown Louisiana 70808, 225-769-1919 II. BASIS OF JURISDICTION (Place an in One Box Only) CITIZENSHIP 0F PRINCIPAL an in One Box for Plaintiff (For Diversity Cases Only) and One Box for Defendant) CI 1 U.S. Govemment 3 Federal Question PTF DEF PTF DEF Plaintiff (U.S. Govemment Not a Party) Citizen of This State 1 CI 1 Incorporated or Principal Place CI 4 CI 4 of Business In This State Cl 2 U.S. Government Cl 4 Diversity Citizen of Another State CI 2 CI 2 Incorporated and Principal Place CI 5 5 Defendant of Business In Another State (Indicate Citizenship of Parties in Item Citizen or Subjectof a Cl 3 Cl 3 Foreign Nation CI 6 CI 6 Foreign Counn-v IV. NATURE OF SUIT ?Place an in One Box Onlv't CONTRACT TURTS BANKRUPTCY OTHER STATUTES I 110 Insurance PERSONAL INJURY PERSONAL INJURY 610 Agriculture [3 422 Appeal 28 USC 158 CI 400 State Reapportionment Cl 120 Marine 310 Airplane CI 362 Personal Injury - Cl 620 Other Food Drug Cl 423 Withdrawal 410 Antitrust Cl 130 Miller Act CI 315 Airplane Product Med. Malpractice Cl 625 Related Seizure 28 USC 157 CI 430 Banks and Banking Cl 140 Negotiable Instrument Liability CI 365 Personal Injury - of Property 21 USC 881 CI 450 Commerce 150 Recovery of Overpayment CI 320 Assault, Libel Product Liability El 630 Liquor Laws PROPERTY RIGHTS Cl 460 Deportation Enforcement of Judgment Slander CI 368 Asbestos Personal Cl 640 R.R. Truck CI 820 Copyrights Cl 470 Racketeer In?uenced and 151 Medicare Act CI 330 Federal Employers? Injury Product Cl 650 Airline Regs. CI 830 Patent Corrupt Organizations 152 Recovery of Defaulted Liability Liability CI 660 Occupational CI 840 Trademark Cl 480 Consumer Credit Student Loans CI 340 Marine PERSONAL PROPERTY Safety/Health Cl 490 Cable/Sat TV (Excl. Veterans) Cl 345 Marine Product 370 Other Fraud CI 690 Other Cl 810 Selective Service [3 153 Recovery of Overpayment Liability CI 371 in Lending LABOR SOCIAL SECURITY Cl 850 Securities/Commodities/ of Veteran?s Bene?ts 350 Motor Vehicle El 380 Other Personal CI 710 Fair Labor Standards 861 HIA (1395ft) Exchange CI 160 Stockholders? Suits CI 355 Motor Vehicle Property Damage Act CI 862 Black Lung (923) CI 875 Customer Challenge [3 190 Other Contract Product Liability CI 385 Property Damage CI 720 Relations CI 863 (405(g)) 12 USC 3410 195 Contract Product Liability CI 360 Other Personal Product Liability [3 730 CI 864 SSID Title XVI CI 890 Other Statutory Actions CI 196 Franchise Injurv Disclosure Act CI 865 RSI (405(3)) Cl 891 Agricultural Acts I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Cl 740 Railway Labor Act FEDE RAL- TAX SUITS 892 Economic Stabilization Act CI 210 Land Condemnation CI 441 Voting CI 510 Motions to Vacate CI 790 Other Labor Litigation [3 870 Taxes (U.S. Plaintiff Cl 893 Environmental Matters CI 220 Foreclosure 442 Employment Sentence Cl 791 Empl. Ret. Inc. or Defendant) 894 Energy Allocation Act CI 230 Rent Lease Ejecnnent Cl 443 Housing/ Habeas Corpus: I Security Act CI 871 IRS?Third Party Cl 895 Freedom of Information 240 Torts to Land Accommodations CI 530 General 26 USC 7609 Act 245 Tort Product Liability CI 444 Welfare 535 Death Penalty CI 900Appeal of Fee Determination 13 290 All Other Real Property CI 445 Amer. w/Disabilities - CI 540 Mandamus Other Under Equal Access Employment CI 550 Civil Rights to Justice CI 446 Amer. w/Disabilities - CI 555 Prison Condition Cl 950 Constitutionality of Other State Statutes 440 Other Civil Rights V. ORIGIN (Place an in One Box OnlyTransferred from 6 I [j 7 Ju g_e from Original Removed from Remanded from Retnstated or another Magistrate Proceeding State Court Appellate Court Reopened tspecifv) Litigation udement Ci U. . ivil St uteu er which on are ?l?n onot cite 'urisdictional statutes unless diversit LIE gA 20 121th Ights? etanatto?ita) Brief'description of cause: 7 Plaintiffs were employees OT Clayton Homes who were termlnated tor reporting race of Mt VI. CAUSE OF ACTION VII. REQUESTED IN 5 CHECK IF THIS IS A CLASS ACTION DEMAND CHECK YES only if demanded in complaint: COMPLAINT: UNDER F-R-C-P- 23 JURY DEMAND: t2! Yes No RELATED IF ANY cc ??Smms)? JUDGE Brady DOCKET NUMBER 07?00091 DATE . SIGNATURE OF ATTORNEY OF RECORD ?Ll ?1 SW L. I) FOR OFFICE I I RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE Case Document 1-2 04/02/07 Pagelof2 440 (Rev. 8/01) Summons in a Civil Action UNITED STATES DISTRICT COURT Middle District of Louisiana Morris Stone and Murray Hebert SUMMONS IN A CIVIL ACTION V. CHM Homes Inc. f/d/b/a Clayton Homes, Inc CASE NUMBER: TO: (Name and address of Defendant) CHM Homes, Inc. f/d/b/a Clayton Homes, Inc. Wilmington Trust SP Services, Inc. 1105 N. Market Street, STE 1300 Wilmington, DE 19801 YOU ARE HEREBY SUMMONED and required to ATTORNEY (name and address) Donna U. Grodner Grodner Associates 2223 Quail Run Drive Suite B-l Baton Rouge, Louisiana 70808 an answer to the complaint which is served on you with this summons, Within days after service of this summons on you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. Any answer that you serve on the parties to this action must be ?led with the Clerk of this Court within a reasonable period of time after service. CLERK DATE (By) DEPUTY CLERK Case Document 1-2 04/02/07 QAO 440 (Rev. 8/01) Summons in aCivil Action Page 2 of 2 RETURN OF SERVICE DATE Service of the Summons and complaint was made by me?) NAME OF SERVER (PRINT) TITLE Check one box below to indicate appropriate method of" service Served personally upon the defendant. Place where served: Left copies thereof at the defendant?s dwelling house or usual place of abode with a person of suitable age and discretion then residing therein. Name of person with whom the summons and complaint were left: Returned unexecuted: Cl Other (specify): STATEMENT OF SERVICE FEES TRAVEL SERVICES TOTAL $0.00 DECLARATION OF SERVER I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and Statement of Service Fees is true and correct. Executed on Date Signature of Server Address of Server (1) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure. Case Document 173 04/02/07 Page 1 of zinc U.S. EQUAL EMPLOYMENT COMMISSION OF RIGHT TO SUE FAILURE) Morris Stone Fm": Equal Employment Opportunity Comm sion New Orleans Field Office 1555 Poydras Street, Suite 1900 New OrleansV Louisiana 70112 Du aggrieved whose idennMs CW5 1501.714.>> EEOC charge Nov EEOC Representative Telephune No. 2704005411120 James Sacher, Reglonal Attorney (113) 209-3398 TO THE PERSON This Notice iha EEOCs processing ulthe above-numbered charge. The EEOC laund reasonable muse to believe lhat violations at the stainle(s) occurred with respect ta same or all at the matters alleged in the charge but could not obtain a settlement with the Respondent that would pravide relief (or you. In addition, the EEOC has deoided that is will not bring suit against the Respondent at this time based on this charge and will close its tile in this use. This does not mean that the EEOC is cerian that the Respondent Is in compliance with the law. or that the EEOC will not we the Respondent laierar intervene later in if you decide In sue on your own hehall. -- NOTICE OF RIGHTS -- (See the addmanni [Mamafim alumni to this tom) Title vii, the Americans with Disabilities Act. Indior the Age Discrimination In Employment Act: This will be the only rumors of your righllo sue thatwe will send you. You may file a lawsuit resuondenfls) under federal law based an this charge in lederai ornate mun. Vour lawsuit must he flied WITH so DAYS of your recetpt at this limits: or yvur righlia sue based an this charge will he lost. (The time limit for tiling suit based on a stale daim may be diflerent.) Equal Pay Act (EPA): EPA suits must be filed In Iederai er state noun within 2 years (a years lor wtiitui of the aiiegea EPA underpayment. This means than backpay due for any violations that seemed befall you file suit may not be collectible. ll yuu file still, based on this charge, please send a copy nyonr mun wmplaimw lhis Dfl'loel On behalf olthe ODmm'tsslon Mr ,2/3/07 Enclosureis) mill 1. FIELD FICE DIRECTOR (Date Mailed) Clayton Homes, Inc., Respondent (I, Case Document 174 04/02/07 Page 1 of Ecol: murmur u.s. EQUAL EMPLOYMENT COMMISSION NOTICE OF RIGHT TO SUE (CONCIUA TION FAILURE) TD: ebelt From: Equal Employment Opportunity Commission New Orleans Field Office 1555 Poydras street, Suite 1900 New Orleans, Louisiana 70112 On aggrieved wnose identity is CONFIDENTIAL {29 cm 1501.70>>) EEOC charge No, EEOC Representative Telephone No. 270-2110502366 James Sacher. Regional Attorney (113) 209$398 TO THE PERSON AGGRIEVED: This lece concludes live pmoessing olihe above--numbered charge, The EEOC found masonable cause In believe trial violations oi the slant-2(5) Downed with respem to some or all of ihe malters alleged in the charge but could not obtain a settlement lna Responder" lhalwmiId provide lel'lefllor you, In addition, the EEOC has decided mat is will nD'l bring suil agalnfl Respondent at this lime based on this charge and will close its file in lhis cases This does not mean that the EEOC is wniiylng inst the Respondent Is in compliance with lire law. urihai the EEOC will no: sue me Respondent Isler or intervene Isler in your lawsuit ii you decide to sue on your own hens". NOTICE OF SUIT RIGHTS (59: in: addirionalwonnatlon Mellan Title VII, Americana with Disabilities Act, andlor the Age Discrimination In Empiwmemm This will be lha only notice ul your righl lo sue thalwe will send you. You may file a Iawsuil againsl the respondsm(s) underfedelal law based on this chalge in federal ix slate court Ynurlawsun must be filed 90 DAVS of your recelp: of this Notice: or your iighlio sue based on this charge win be Iosl. (The time limit lnrfiling sutl based on a slate claim may be diileienl.) Equal Pay AC1. (EPA): EPA suits musl be filed in ledeml or slate mun within 2 year! (3 years lor willful Violations) of lhe alleged EPA underpaymenl, This means that backm due ior any violations that m" than 2 (3 Elm) below you file suit may not be collectibles II you file suil. based on lhis marge, please send a cow at your soul complain! lo lhis oliioe. on when oiihe Commission arslosurem KEIT T. HILL. FIELD OFFI EDIRECTOR (Dale 09' Claylon Homes, Inc., Respondent