Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 1 of 19 Page ID #:1
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`Michael Peffer (SBN: 192265)
`Nilab Sharif (SBN: 231296)
`PACIFIC JUSTICE INSTITUTE
`2200 North Grand Ave.
`Santa Ana, CA 92704
`Tel: (714) 796-7150
`Emails: michaelpeffer@pji.org
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`Attorneys for Plaintiff, CHRISTOPHER KEY
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`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
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`CHRISTOPHER KEY, an individual,
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`Case No.:
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`Plaintiff,
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`vs.
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`CITY OF LOS ANGELES,
`DEPARTMENT OF BUILDING
`AND SAFETY; DOES 1-10,
`INCLUSIVE,
`Defendants.
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`VERIFIED COMPLAINT FOR
`VIOLATION OF RIGHTS UNDER
`TITLE VII OF THE CIVIL RIGHTS
`ACT OF 1964 [42 U.S.C. 2000e et
`seq.]
`(DEMAND FOR JURY TRIAL)
`
`COMES NOW, Plaintiff, CHRISTOPHER KEY (hereinafter
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`“PLAINTIFF”), and for his Complaint alleges as follows:
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 2 of 19 Page ID #:2
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`INTRODUCTION
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`Plaintiff worked for Defendant as a building mechanical inspector at
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`Defendant’s downtown Los Angeles, CA location. Defendant required its
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`employees to be vaccinated for SARS-CoV-2 (COVID-19). Because of the
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`Plaintiff’s faith, he sought an accommodation for his sincerely held religious to be
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`exempt from taking this vaccine. Plaintiff was placed on unpaid leave prior to a
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`review of his religious accommodation request.
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`Notwithstanding having legitimately sought an accommodation for sincerely
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`held religious beliefs, which kept Plaintiff from taking the vaccine, he was placed
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`on unpaid leave by Defendant on December 4, 2021. The gravamen of this
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`complaint is that Defendant refused to accommodate, otherwise discriminated
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`against, and subsequently placed Plaintiff on unpaid leave from his job because he
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`asked for accommodation due to his religious beliefs. Defendant knew or should
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`have reasonably known that Plaintiff held religious beliefs because he asserted
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`them. Defendant nevertheless failed to engage in an interactive process or review
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`of Plaintiff’s accommodation request, placed him on leave without pay, and
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`retaliated against him for filing a complaint with the Equal Employment
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`Opportunity Commission (EEOC).
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`JURISDICTION AND VENUE
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`1.
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`This Court has authority over this action pursuant to 28 U.S.C. §1331,
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`in federal questions raised under Title VII of the Civil Rights Act of 1964, 42
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`U.S.C. § 2000e et seq. This court has supplemental jurisdiction over Plaintiff's
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 3 of 19 Page ID #:3
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`related claims arising under corollary state anti-discrimination law pursuant to 28
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`U.S.C. § 1367(a).
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`2.
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`Venue is proper in the Central District of California under 42 U.S.C. §
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`2000e-5(f)(3), in that Defendant maintains significant operations within the Central
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`District of California, and the locations of the Defendant where the alleged
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`unlawful employment practices took place are within the Central District of
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`California. This case is appropriate for assignment to the San Fernando Valley
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`Division.
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`PARTIES
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`PLAINTIFF
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`3.
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`At all times relevant herein, Mr. Key was an employee of the Los
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`Angeles Department of Building and Safety as a building mechanical inspector at
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`Defendant’s downtown Los Angeles location. Mr. Key resided in the county of
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`Orange at the time of the events that gave rise to this Complaint.
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`DEFENDANT
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`4.
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`At all times relevant herein, Los Angeles Department of Building and
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`Safety was a compliance department presiding over the permit, inspection, and
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`code enforcement processes for construction in the city of Los Angeles, California,
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`and was the employer of PLAINTIFF.
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`5. The true names and capacities, whether individual, corporate, associate,
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`or otherwise, of DOES 1-100, inclusive are unknown to PLAINTIFF at this time,
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`who therefore sues said DEFENDANTS by such fictious names. PLAINTIFF is
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`informed and believes and thereon alleges that each of the factiously named
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`DEFENDANTS is in some way responsible for, or participated in, or contributed
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 4 of 19 Page ID #:4
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`to, the matters and things complained of herein, and is legally responsible in some
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`manner. PLAINTIFF will seek leave to amend this Complaint when the true
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`names, capacities, and responsibilities have been ascertained.
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`STATEMENT OF FACTS
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`6.
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`At all times relevant hereto, the PLAINTIFF was performing
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`competently in the position he held with DEFENDANT.
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`7.
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`On or about August 18, 2021, the City of Los Angeles passed a
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`COVID-19 Ordinance No. 187134 (Ordinance). The City of Los Angeles allowed
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`its employees to submit requests for a religious exemption, as required by law, no
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`later than September 7, 2021. Employees were asked to submit their vaccine status
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`information to the third-party vendor, Bluestone.
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`8.
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`On October 8, 2021, PLAINTIFF submitted a request for religious
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`accommodation to the DEFENDANT’s COVID-19 vaccine requirement because
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`of his faith. Plaintiff’s accommodation request explained that his beliefs conflict
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`with the COVID-19 vaccine due to the use of aborted fetal cell lines in the testing
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`and manufacturing of the vaccine. Plaintiff also stated, “it is my sincerely held
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`religious belief that abortion is murder and a violation of one of the Ten
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`Commandments ("You shall not murder." Exodus 20:13). Thus, it would violate
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`my sincerely held religious beliefs to cooperate with or be complicit in abortion in
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`any way.” He further stated, “it is my sincerely held religious belief that, in being
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`vaccinated with any of the currently available COVID-19 vaccines, I would be
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`cooperating with and complicit in abortion - the terminating of an innocent human
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`life - and that such would constitute a sin against God and a violation of His
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`Commandments, for which I would be held morally accountable by God.”
`- 4 -
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 5 of 19 Page ID #:5
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`9. Mr. Key is a follower of the Christian faith.
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`10. Mr. Key believes that his body belongs to God and is a temple of the
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`Holy Spirit.
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`11. Mr. Key believes that it is against his religion to ingest or inject his
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`body with possible harmful substances, including a vaccine where aborted fetal
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`cell lines were used in its testing and manufacturing.
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`12. Mr. Key’s understanding is that the manufacturers of the COVID-19
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`vaccine use aborted fetal tissue, the lining of aborted fetal tissue, or both forms of
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`fetal tissue. Mr. Key’s faith strongly opposes injecting his body with the COVID-
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`19 vaccine.
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`13. On or about November 3, 2021, PLAINTIFF learned that he had been
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`registered with the third-party vendor, Bluestone, by DEFENDANT without his
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`consent. PLAINTIFF had not yet registered with Bluestone as he did not feel
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`comfortable with or confident in providing his private and personal information to
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`a third-party vendor.
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`14. On or about December 4, 2021, PLAINTIFF was invited to
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`Defendant’s Employee, Eric Jakeman's office. Mr. Jakeman issued to PLAINTIFF
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`General Form 77, which placed him on "off-duty without pay" because he would
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`not take the COVID-19 vaccine or consent to the Bluestone company's testing
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`process. PLAINTIFF requested a union representative to be present at this meeting,
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`however he was instead escorted out of the building by two security guards.
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`15. When PLAINTIFF was placed on leave, he still had not received
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`communication from DEFENDANT regarding his religious accommodation
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`request, including communication about COVID-19 testing with facilities other
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 6 of 19 Page ID #:6
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`than Bluestone.
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`16. PLAINTIFF, as a result of being placed on unpaid leave, was forced
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`to use his compensatory time. His compensatory time ran out on January 3, 2022.
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`17. On or about December 12, 2021, PLAINTIFF submitted an appeal to
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`the Civil Service Commission concerning his being placed on unpaid leave.
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`18. On or about December 12, 2021, PLAINTIFF also filed a complaint
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`with the EEOC alleging violation of his Title VII rights.
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`19. On or about December 15, 2021, PLAINTIFF received via email a
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`response from the Civil Service Commission confirming receipt of PLAINTIFF’s
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`appeal. The email explained that unpaid leave is not appealable because unpaid
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`Administrative Leave for failure to meet a condition of employee by not being
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`vaccinated or applying for and receiving a medical or religious exemption, is not
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`an open-ended action, but will result in a Skelly meeting and discharge; discharge
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`is appealable to the Civil Service Commission and must be filed within (5)
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`calendar days of being served with the General Form 77 detailing the reasons for
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`the discharge. The email also stated that unpaid leave only lasts 45 days. Based on
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`this response, PLAINTIFF waited for a copy of the disciplinary General Form 77
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`or Skelly hearing date paperwork to be sent to his place of residence.
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`20. On or about February 18, 2022, PLAINTIFF emailed Sean Cumbie,
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`Defendant’s Personnel Department Analyst, regarding his unpaid leave status and
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`religious accommodation request.
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`21.
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` On or about February 22, 2022, PLAINTIFF received a reply to his
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`February 18 email stating that his religious accommodation request was under
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`review.
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 7 of 19 Page ID #:7
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`22. PLAINTIFF contacted DEFENDANT’s personnel department
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`numerous times on different dates, until he was finally able to speak telephonically
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`with Mr. Cumbie regarding a Skelly hearing date. During this conversation,
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`PLAINTIFF was informed that the Personnel office had no record, nor could they
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`locate, the very important General form 77 within PLAINTIFF’s personnel file.
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`PLAINTIFF was also informed that his personnel file in fact appeared as though he
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`was recently terminated and newly re-hired. Therefore, with no General form 77
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`that could be located by the Personnel department, PLAINTIFF was informed
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`there was no disciplinary reason why he would not be allowed to return to work.
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`23. As a result of his conversation with Mr. Cumbie, PLAINTIFF returned
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`to work on May 2, 2022. However, upon returning to work, PLAINTIFF was
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`immediately assigned to the PACE department rather than his old position.
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`24. On or about January 6, 2023, PLAINTIFF was finally transferred
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`back to the same AIM desk/department to which he had been assigned prior to
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`being placed on unpaid leave. However, he was given almost double the work-
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`load of the other inspectors.
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`25. On or about February 22, 2024, Plaintiff was again moved to
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`the PACE department. PLAINTIFF has been moved six times in the span of five
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`years, which PLAINTIFF believes is not typical for LADBS employees.
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`26. At this position with the PACE department, PLAINTIFF was assigned
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`to two council districts, rather than one. Assignment of two districts versus one
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`district is not typical for LADBS employees. However, LADBS management
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`assigned to PLAINTIFF two council districts: one in Van Nuys and one in San
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`Pedro. Within the LADBS community, assigning an employee two districts is
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 8 of 19 Page ID #:8
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`considered a managerial "disciplinary" practice commonly known as giving an
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`employee "freeway therapy."
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`27. On or about June 15, 2023, Mr. Key’s request for a religious
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`accommodation was approved.
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`28. During the time period that Mr. Key was placed on leave, he was
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`denied the opportunity to register to take the exam to promote to Senior Building
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`Mechanical Inspector. Mr. Key was not notified or contacted about this exam
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`being offered and was therefore deprived of the opportunity to take this exam. This
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`particular exam is rarely offered, and it is Mr. Key’s understanding that it has not
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`been offered again and may not be offered for another several years.
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`29. It is PLAINTIFF’s belief that due to the discrimination and retaliation
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`he has already experienced at the hands of LADBS managers and supervisors, he
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`will continue to face further discrimination, retaliation, as well as denial of any
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`possible promotions in the future because the same managers and supervisors
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`currently oversee his work.
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`30. Mr. Key timely filed a complaint with the EEOC for religious
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`discrimination; and received a Notice of Right to Sue (NRTS) from the EEOC on
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`January 16, 2024. Mr. Key’s EEOC NRTS serves as “Exhibit One” for the purpose
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`of this Complaint.
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`FIRST CAUSE OF ACTION
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`Violation of Title VII of the Civil Rights Act of 1964 [42 U.S.C. § 2000e et seq.]
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`Failure to Accommodate Against Defendant
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`31. PLAINTIFF hereby incorporates and realleges the preceding
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`paragraphs as though fully set forth herein.
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 9 of 19 Page ID #:9
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`32. Pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. §
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`2000e-2(a)(1), it is an unlawful employment practice for an employer: (1) to fail or
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`refuse to hire or discharge any individual, or otherwise discriminate against any
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`individual with respect to his or her compensation, terms, conditions, or privileges
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`of employment, because of such individual's race, color, religion, sex, or national
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`origin; or (2) to limit, segregate, or classify his or her employees or applicants for
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`employment in any way which would deprive or tend to deprive any individual of
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`employment opportunities or otherwise deprive or tend to deprive any individual of
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`employment opportunities or otherwise adversely affect his or her status as an
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`employee, because of such individual’s race, color, religion, sex, or national origin.
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`33. A plaintiff can make out a Title VII prima facie case for a failure to
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`accommodate by showing (1) he held a bona fide religious belief, the practice of
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`which conflicted with an employment duty; (2) the employer took adverse action—
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`including the refusal to hire—because of the plaintiff’s inability to fulfill the job
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`requirement; and (3) the plaintiff’s religious practice was a motivating factor in the
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`employer’s decision. Chin et al., Cal. Prac. Guide: Employment Litigation (The
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`Rutter Group 2019) ¶ 7:620; see also Abercrombie & Fitch, 575 U.S. at 775.
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`34. Mr. Key was, at all times relevant herein, an employee and applicant
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`covered by U.S.C. 42 § 2000e et seq.
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`35. Mr. Key held a deeply sincere religious objection to receiving the
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`COVID-19 vaccine injection, and asked DEFENDANT to accommodate his
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`sincerely held religious belief.
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`36. Mr. Key’s request for a religious accommodation was neither
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`approved nor denied when he was placed on unpaid leave. In fact, he was not given
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 10 of 19 Page ID #:10
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`any information regarding his request when DEFENDANT chose to place him on
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`unpaid leave claiming it was due to his vaccination status and failure to enroll with
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`Bluestone, even though DEFENDANT had already enrolled PLAINTIFF with
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`Bluestone on November 3, 2021.
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`37. Due to DEFENDANT’s complete absence of communication with
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`PLAINTIFF regarding his religious accommodation request, it is clear that
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`DEFENDANT never intended to meet with or discuss PLAINTIFF’s
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`accommodation request with him when the decision to place him on unpaid leave
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`was made.
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`38. Therefore, Mr. Key’s religious beliefs and practices were a motivating
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`factor in his being placed on unpaid leave.
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`39. PLAINTIFF suffered significant damages because of DEFENDANT’s
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`unlawful discriminatory actions, including emotional distress, lost wages and
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`benefits, and the costs of bringing this action.
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`40. DEFENDANT intentionally violated PLAINTIFF’S rights under
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`Title VII with malice or reckless indifference.
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`41. PLAINTIFF is entitled to backpay, compensatory damages, attorney’s
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`fees, costs of suit, a declaration that DEFENDANT violated his rights under Title
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`VII, and an injunction preventing DEFENDANT from enforcing its discriminatory
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`policies.
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`42. PLAINTIFF is entitled to further relief as set forth below in his Prayer
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`for Relief.
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`/ / /
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`/ / /
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`SECOND CAUSE OF ACTION
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`Violation of Title VII of the Civil Rights Act of 1964 [42 U.S.C. § 2000e et seq.]
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`Retaliation Against Defendant
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`43. PLAINTIFF hereby incorporates and realleges the preceding
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`paragraphs as though fully set forth herein.
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`44. Pursuant to Title VII of the Civil Rights Act of 1964, it is “an
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`unlawful employment practice for an employer to discriminate against any of his
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`employees or applicants for employment, for an employment agency, or joint
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`labor-management committee controlling apprenticeship or other training or
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`retraining, including on-the-job training programs, to discriminate against any
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`individual, or for a labor organization to discriminate against any member thereof
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`or applicant for membership, because he has opposed any practice made an
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`unlawful employment practice by this subchapter, or because he has made a
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`charge, testified, assisted, or participated in any manner in an investigation,
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`proceeding, or hearing under this subchapter.” 42 U.S.C. §2000e-3(a).
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`45. A plaintiff can make out a Title VII prima facie case for retaliation by
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`showing that (1) he engaged in a protected activity; (2) his employer subjected him
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`to an adverse employment action; and (3) a causal link exists between the protected
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`activity and the adverse action.” Ray v. Henderson, 217 F.3d 1234, 1240 (9th Cir.
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`2000).
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`46. Mr. Key was, at all times relevant herein, an employee and applicant
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`covered by U.S.C. 42 § 2000e et seq.
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`47. Mr. Key held a deeply sincere religious objection to receiving the
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`COVID-19 vaccine injection, and asked DEFENDANT to accommodate his
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 12 of 19 Page ID #:12
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`sincerely held religious belief.
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`48. Mr. Key’s request for a religious accommodation was neither
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`approved nor denied when he was placed on unpaid leave without DEFENDANT
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`following the proper procedure, such as conducting a Skelly hearing.
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`49. As a result of DEFENDANT’s violation of PLAINTIFF’s Title VII
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`rights, PLAINTIFF filed a complaint with the EEOC.
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`50. Following his being placed on unpaid leave in December 2021,
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`PLAINTIFF was left in the dark regarding his unpaid status as DEFENDANT
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`ceased to communicate with him. In fact, it was PLAINTIFF who followed up
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`with DEFENDANT’s personnel department regarding the status of his unpaid
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`leave, only to learn that he could return to work because his personnel file did not
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`contain any paperwork for his being placed on unpaid leave.
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`51. Due to DEFENDANT’s complete absence of communication with
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`PLAINTIFF regarding his religious accommodation request and unpaid leave
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`status, it is clear that DEFENDANT was engaging in discriminatory acts against
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`PLAINTIFF.
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`52. PLAINTIFF date of filing his EEOC complaint was on December 12,
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`2021. His return-to-work date was in May 2022. During that time, PLAINTIFF
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`missed a significant opportunity to take the exam for a possible promotion.
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`53. Following his return to work at LADBS, PLAINTIFF was not
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`permitted to return to his former position. DEFENDANT retaliated against
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`PLAINTIFF by immediately assigning him to a different department. When
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`PLAINTIFF was finally transferred back to the same AIM desk/department to
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`which he had been assigned prior to being placed on unpaid leave, he was given
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`almost double the work-load of the other inspectors. DEFENDANT further
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`retaliated against PLAINTIFF when he was moved again to the PACE department
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`in February 2024, where he was assigned to two council districts instead of known.
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`Such an assignment was known as “freeway therapy” within the LADBS
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`community, a type of managerial disciplinary action.
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`54. DEFENDANT did not approve PLAINTIFF’s religious
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`accommodation request until June 15, 2023.
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`55. Therefore, Mr. Key’s filing of an EEOC complaint led to
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`DEFENDANT taking adverse employment actions against him following his
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`return to work.
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`56. PLAINTIFF suffered significant damages because of DEFENDANT’s
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`unlawful discriminatory actions, including emotional distress, lost wages and
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`benefits, and the costs of bringing this action.
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`57. DEFENDANT intentionally violated PLAINTIFF’S rights under
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`Title VII with malice or reckless indifference.
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`58. PLAINTIFF is entitled to backpay, compensatory damages, attorney’s
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`fees, costs of suit, a declaration that DEFENDANT violated his rights under Title
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`VII, and an injunction preventing DEFENDANT from enforcing its discriminatory
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`policies.
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`59. PLAINTIFF is entitled to further relief as set forth below in his Prayer
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`for Relief.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff prays this Court grant relief as follows:
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`- 13 -
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 14 of 19 Page ID #:14
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`A. Award PLAINTIFF backpay, including past loss of wages and
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`benefits, plus interest;
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`B. Award PLAINTIFF other and further compensatory damages in an
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`amount according to proof;
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`C. Award PLAINTIFF noneconomic damages, including but not limited
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`to mental health suffrage;
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`D. Award PLAINTIFF his reasonable attorney’s fees and costs of suit;
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`Enjoin DEFENDANT from enforcing its discriminatory policies;
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`Declare that DEFENDANT has violated Title VII of the Civil Rights
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`E.
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`F.
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`Act; and
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`G. Grant PLAINTIFF such additional or alternative relief as the Court
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`deems just and proper.
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`DATED: 4/15/2024
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`PACIFIC JUSTICE INSTITUTE
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`By:___________________________
`MICHAEL J. PEFFER, ESQ.,
`Attorney for Plaintiff,
`CHRISTOPHER KEY
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`DEMAND FOR JURY TRIAL
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`PLAINTIFF, CHRISTOPHER KEY, hereby demands a jury trial in this
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`matter.
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`DATED: 4/15/2024
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`PACIFIC JUSTICE INSTITUTE
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`By:___________________________
`MICHAEL J. PEFFER, ESQ.,
`Attorney for Plaintiff,
`CHRISTOPHER KEY
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`

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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 16 of 19 Page ID #:16
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`VERIFICATION
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`I, CHRISTOPHER
`KEY, am the Plaintiff
`in the above-captioned
`matter.
`I
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`have read the VERIFIED
`COMPLAINT FOR VIOLATION
`OF RIGHTS UNDER
`7
`
`s TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 [42 U.S.C.
`2000e et seq.] and
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`9 am familiar
`with same. The contents
`are true and accurate
`and known to me by
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`10
`personal
`knowledge
`except
`for those matters
`asserted
`on information
`and belief.
`A
`
`11
`to those matters,
`I believe
`them to be true. I declare
`under penalty
`of lying under
`12
`oath, under the laws of the United States and the State of California, that the
`13
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`xecuted this 15th d
`foregoing is true and correct. E
`ay of April 2024, in Orange
`14
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`County,
`State of California.
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`CHRISTOPHER
`KEY
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`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND f-OR JURY TRIAL
`
`

`

`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 17 of 19 Page ID #:17
`ase 2:24-cv-03069-DMG-SK Document1 Filed 04/15/24 Page17o0f19 Page ID #:17
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`EXHIBIT ONE(1)
`EXHIBIT ONE (1)
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`-17-
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`COMPLAINT FOR VIOLATIONOFTITLE VII; DEMAND FOR JURY TRIAL
`COMPLAINT FOR VIOLATION OF TITLE VII; DEMAND FOR JURY TRIAL
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`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 18 of 19 Page ID #:18
`U.S. Department of Justice
`Civil Rights Division
`NOTICE OF RIGHT TO SUE WITHIN 90 DAYS
`
`
`VIA EMAIL
`
`150 M Street, N.E.
`Karen Ferguson , EMP, 4CON, Room 9.514
`Washington, DC 20530
`
`January 16, 2024
`
`
`Mr. Christopher N. Key
`355 West Linden Drive
`Orange, CA 92865
`
`Re: EEOC Charge Against Los Angeles Dept. of Building & Safety, et al.
`(cid:9)(cid:9)(cid:9)(cid:9)(cid:9)(cid:9)(cid:9) No. 480202400259
`
`Dear Mr. Key:
`
` Because you filed the above charge with the Equal Employment Opportunity Commission, and the
`Commission has determined that it will not be able to investigate and conciliate that charge within
`180 days of the date the Commission assumed jurisdiction over the charge and the Department has
`determined that it will not file any lawsuit(s) based thereon within that time, and because you have
`specifically requested this Notice, you are hereby notified that you have the right to institute a civil
`action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e, et seq., against
`the above-named respondent.
`
` If you choose to commence a civil action, such suit must be filed in the appropriate Court within
`90 days of your receipt of this Notice. If you cannot afford or are unable to retain an attorney to
`represent you, the Court may, at its discretion, assist you in obtaining an attorney. If you plan to ask
`the Court to help you find an attorney, you must make this request of the Court in the form and
`manner it requires. Your request to the Court should be made well before the end of the time period
`mentioned above. A request for representation does not relieve you of the obligation to file suit
`within this 90-day period.
`
` The investigative file pertaining to your case is located in the EEOC Los Angeles District Office,
`Los Angeles, CA.
`
` This Notice should not be taken to mean that the Department of Justice has made a judgment as to
`whether or not your case is meritorious.
`
` Sincerely,
`
` Kristen Clarke
` Assistant Attorney General
` Civil Rights Division
`
` by /s/ Karen L. Ferguson
` Karen L. Ferguson
` Supervisory Civil Rights Analyst
` Employment Litigation Section
`
`
`

`

`Case 2:24-cv-03069-DMG-SK Document 1 Filed 04/15/24 Page 19 of 19 Page ID #:19
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`
`cc: Los Angeles District Office, EEOC
` Los Angeles Dept. of Building & Safety, et al.
`
`