`
`
`TASHEKA YOUNG,
`Plaintiff,
`
`
`v.
`
`COX RADIO, INC. d/b/a COX MEDIA
`GROUP JACKSONVILLE,
`Defendant.
`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`JACKSONVILLE DIVISION
`
`Case No. 3:21-cv-497
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`COMPLAINT
`
`COMES NOW the Plaintiff, TASHEKA YOUNG (“Plaintiff”), by and through the
`
`undersigned Counsel, and hereby sues COX RADIO, INC. d/b/a COX MEDIA GROUP
`
`JACKSONVILLE (“Defendant”), and alleges the following:
`
`1.
`
`Plaintiff is an individual resident and citizen of Jacksonville, Duval County,
`
`Florida.
`
`2.
`
`Defendant is a Florida corporation whose principal place of business is in Atlanta,
`
`Georgia.
`
`3.
`
`4.
`
`This Court has jurisdiction over this lawsuit, pursuant to 28 U.S.C. § 1331.
`
`The unlawful employment practices alleged in this complaint were committed
`
`within the State of Florida in this judicial district and division.
`
`5.
`
`6.
`
`Venue is proper in this judicial district and division.
`
`Plaintiff timely filed a discrimination charge against Defendant with the Equal
`
`Employment Opportunity Commission (the “EEOC”). The EEOC issued Plaintiff a right to sue
`
`letter on February 9, 2021. Plaintiff received the notice of her right to sue from the EEOC on or
`
`about February 12, 2021. A copy of the notice is attached hereto as Exhibit 1.
`
`
`
`1
`
`
`
`Case 3:21-cv-00497-MMH-JBT Document 1 Filed 05/10/21 Page 2 of 4 PageID 2
`
`GENERAL ALLEGATIONS
`
`Plaintiff is an African American, black female.
`
`In or about July 2013, Defendant hired the Plaintiff to work as an on-air announcer
`
`7.
`
`8.
`
`with Power 106.1 FM, one of Defendant’s radio stations.
`
`9.
`
`During her employment with the Defendant, Plaintiff performed her job duties well
`
`and received consistently positive feedback from her supervisor, the radio station’s program
`
`director.
`
`10.
`
`Between March 2019 and June 2019, Plaintiff took a maternity leave of absence
`
`from her employment with Defendant after giving birth to a child.
`
`11.
`
`12.
`
`In 2020, Plaintiff became pregnant again.
`
`On or about June 29, 2020, Defendant terminated the Plaintiff, citing Plaintiff’s
`
`“performance issues.”
`
`13.
`
`In reality, Defendant was motivated to terminate the Plaintiff by discriminatory
`
`animus on the basis of Plaintiff’s pregnancy status and sex.
`
`14.
`
`Defendant’s stated reason for terminating her (“performance issues”) was nothing
`
`more than a pretext to conceal its true, unlawful discriminatory motive.
`
`COUNT I: PREGNANCY/SEX DISCRIMINATION (TITLE VII)
`
`Plaintiff realleges paragraphs 1-14 above.
`
`This is an action for compensatory damages, punitive damages, attorney fees and
`
`15.
`
`16.
`
`costs, pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq.
`
`17.
`
`Defendant is an employer that is subject to Title VII of the Civil Rights Act of 1964,
`
`because at all times material, Defendant had more than 15 employees.
`
`
`
`2
`
`
`
`Case 3:21-cv-00497-MMH-JBT Document 1 Filed 05/10/21 Page 3 of 4 PageID 3
`
`18.
`
`Plaintiff is a member of a protected class, because she is female and, at the time her
`
`employment was terminated, she was pregnant.
`
`19.
`
`Although Defendant reasonably accommodated the Plaintiff during Plaintiff’s first
`
`pregnancy, Defendant did not want to make similar accommodations for the Plaintiff during her
`
`2020 pregnancy.
`
`20.
`
`Therefore, rather than accommodate the Plaintiff during her 2020 pregnancy, the
`
`Defendant terminated Plaintiff by reason of her pregnancy.
`
`21.
`
`As a direct and proximate result of Defendant’s discriminatory conduct, Plaintiff
`
`suffered loss of past and future wages, loss of his ability to earn income, extreme emotional
`
`distress, mental pain and suffering, and loss of capacity for the enjoyment of life. The losses are
`
`permanent and continuing in nature and Plaintiff will suffer the losses in the future.
`
`WHEREFORE, Plaintiff demands judgment against Defendant for the following:
`
`a. Compensatory damages, including general and special damages;
`
`b. Punitive damages;
`
`c. Costs of suit;
`
`d. Reasonable attorney fees; and
`
`e. Such other and further relief as this Honorable Court deems just and proper.
`
`DEMAND FOR JURY TRIAL
`
`22.
`
`Plaintiff demands a trial by jury on all issues so triable as of right.
`
`
`
`3
`
`
`
`
`
`
`
`Case 3:21-cv-00497-MMH-JBT Document 1 Filed 05/10/21 Page 4 of 4 PageID 4
`
`Dated May 10, 2021.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`THE BONDERUD LAW FIRM, P.A.
`
`/s/ Andrew Bonderud
`Andrew M. Bonderud, Esq.
`TRIAL COUNSEL
`Florida Bar No. 102178
`2130 Riverside Ave.
`Jacksonville, FL 32204
`904-438-8082 (telephone)
`904-800-1482 (facsimile)
`Andrew@Jax.Lawyer
`Kinnette@Jax.Lawyer
`BonderudLaw@gmail.com
`Counsel for Plaintiff
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
