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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
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`Case No. 1:23-cv-02735
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`JURY TRIAL DEMANDED
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`EUGENE EDMOND AND QUINTON JONES, )
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`Plaintiffs,
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`vs.
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`AMAZON.COM INC.,
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`AMAZON.COM SERVICES LLC
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`Defendant.
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`__________________________________________)
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`NOW COMES the Plaintiffs, EUGENE EDMOND (“Edmond”) and QUINTON
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`COMPLAINT
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`JONES (“Jones”) (jointly “Plaintiffs”), by and through their attorneys, Lázaro Law Group,
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`LLC and for their Complaint against AMAZON.COM, INC. and/or AMAZON.COM
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`SERVICES LLC (“Amazon” or “Defendant”), state as follows:
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`NATURE OF ACTION
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`This action challenges pervasive race discriminatory and retaliatory practices at
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`Amazon’s fulfillment center located in Waukegan, Illinois. While employed by Defendant,
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`Plaintiffs and other similarly situated African-Americans were subjected to harassment,
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`discrimination, and retaliation based on their race and their opposition to the harassment
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`and discrimination they suffered.
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 2 of 17 PageID #:2
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`JURISDICTION AND VENUE
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`Plaintiffs’ claims arise under the Title VII of the Civil Rights Act (“Title
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`1.
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`VII”), Section 1981 of the Civil Rights Act of 1866, 42 U.S.C. § 1981 (“Section 1981”)
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`and the Illinois Human Rights Act. (“IHRA”), 775 ILCS 5 et seq.
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`2.
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`The Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 and
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`§1343 as this action involves federal questions regarding the deprivation of Plaintiff’s
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`rights under Title VII and Section 1981.
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`3.
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`The Court has supplemental jurisdiction over Plaintiffs’ related claims
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`arising under state law pursuant to 28 U.S.C. § 1367(a).
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`4.
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`Venue is proper in the Northern District of Illinois pursuant to 28 U.S.C. §
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`1391(b). Defendant’s unlawful conduct took place within the jurisdiction of this Honorable
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`Court.
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`5.
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`Plaintiffs filed timely charges with the Equal Employment Opportunity
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`Commission (“EEOC”) and the Illinois Department of Human Rights (“IDHR”) and
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`received Notice of Right to Sue, thereby fully complying with the procedural requirements.
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`PARTIES
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`6.
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`Eugene Edmond (“Edmond”) is an African American ex-manager of
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`Amazon who was employed from September 2016 until his unlawful termination on April
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`30, 2021.
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`7.
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`Quinton Jones (“Jones”) is an African American Human Resources
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`professional who was employed by Amazon from September 2017 until January 2021.
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`8.
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`Amazon.com, Inc. and/or Amazon.com Services LLC (“Defendant” or
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`“Amazon”) is a Delaware registered corporation with operations in Waukegan IL, and
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`2
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 3 of 17 PageID #:3
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`throughout the country. Amazon is the world’s largest online marketplace. To fulfill its
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`needs, Amazon has an extensive distribution network consisting of at least 75 fulfillment
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`centers and 25 sortation centers. One of these fulfillment centers is located in Waukegan,
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`Illinois.
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`FACTUAL ALLEGATIONS
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`Defendant engaged in Pervasive Systematic Race Discrimination, Harassment,
`and Retaliation against African Americans in its Distribution Centers
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`During Plaintiffs’ employment with Defendant and to this day, Defendant
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`9.
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`engaged in a pattern of discriminatory conduct against African American. As described
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`more fully below, Respondent has and continues to engage in a pattern and practice of
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`discriminating
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`against
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`its African-American
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`employees
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`employed
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`in
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`their
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`fulfillment/distribution centers, including Plaintiffs, and of failing to provide African-
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`Americans with equal opportunities to advance in their careers.
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`10.
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`Defendant maintains stereotypical views about African-Americans that
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`form the basis of personnel decisions and create an environment where occupational
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`segregation, disparate treatment, and harassment are pervasive and condoned.
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`11.
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`Respondent’s pattern and practice of race discrimination is ongoing, as
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`demonstrated in part by the dramatic, historic, and continued underrepresentation of
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`African-Americans in the upper echelons of management.
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`12.
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`Respondent’s success and speed in the marketplace have been possible
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`because Amazon and its founder, Jeff Bezos, pioneered new ways of mass-managing
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`people through technology, relying on a maze of systems and metrics that treats employees
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`as numbers.
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`3
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 4 of 17 PageID #:4
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`13.
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`In contrast to its precise, sophisticated processing of packages, Amazon’s
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`model for managing people is uneven and strained, resulting in mistreatment and unfairness
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`towards its minority employees – especially African Americans.
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`14.
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`Amazon’s human resources department is ineffective at resolving
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`complaints of race discrimination and harassment and, as a result, many African-
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`Americans recognize the futility of lodging internal complaints. Those who do come
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`forward are retaliated against.
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`15.
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`Respondent is and has been aware of the past and current discriminatory
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`impact of its actions, policies, and practices at the highest levels of the organization.
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`16.
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`Several former executives who helped design Amazon’s systems have made
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`public comments to the effect that the Company’s pressure over productivity and
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`consequences of scaling up has led to unfair results.
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`17.
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`David Niekerk, a former Amazon vice president who built the warehouse
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`human resources operation, has said that Amazon’s problems stemmed from ideas the
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`company had developed when it was much smaller. Mr. Bezos did not want an entrenched
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`workforce, calling it “a march to mediocrity.” As Amazon rapidly grew, Mr. Niekerk said,
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`its policies were harder to implement with fairness and care. “It is just a numbers game in
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`many ways,” he has said.
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`18.
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`Amazon has intentionally instituted a policy or practice that limits the
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`upward mobility of hourly workers and lower-level managers who – as a group -- are
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`largely African American. The result of this policy is especially evident in Amazon’s
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`warehouses where Amazon’s workforce is highly segregated. Whereas workers of color –
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`especially African Americans fuel Amazon’s warehouse operation and comprise around
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`4
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 5 of 17 PageID #:5
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`60% of the lower-paying jobs (e.g., laborers and helpers); most managers (around 70%)
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`are white or Asian.
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`19.
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`Indeed, Amazon’s diversity plan acknowledges that the company has an
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`occupational segregation problem. In the pertinent part, the plan states that the company
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`wants to “retain employees at statistically similar rates across demographics”.
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`20.
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`The Covid-19 pandemic only served to intensify Amazon’s discrimination
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`against African American warehouse workers. Amid the pandemic, Amazon’s systems
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`continued to track every minute of every worker’s shift. If productivity wanned, Amazon’s
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`systems assumed the worker was to blame, thus fostering the stereotype that African
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`American workers are lazy.
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`21.
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`During the Covid-19 pandemic, Amazon burned through workers –
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`disproportionately terminating African American workers when compared to non-African
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`American workers. African Americans are much more likely (some estimates go as high
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`as 50% more likely) to be terminated than their white peers.
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`22.
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`Amazon’s pattern and practice of discrimination and retaliatory conduct
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`against African Americans in its distribution centers include but is not limited to:
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`a)
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`b)
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`c)
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`d)
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`e)
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`the upward mobility of
`limit
`to promote and or
`failing
`AfricanAmericans, including to management;
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`underutilizing African-Americans in high paying jobs;
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`steering African-Americans into lower-paying positions;
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`employing discriminatory recruiting, hiring, and promotion
`practices;
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`taking race into account when making employment decisions,
`including but not limited to decisions regarding training;
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`5
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 6 of 17 PageID #:6
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`f)
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`g)
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`h)
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`i)
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`j)
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`k)
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`l)
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`failing to credit African-Americans for their experience on the same
`basis as non-African-Americans and failing to consider African-
`Americans for timely promotions on the same basis as non-African-
`Americans;
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`that disproportionately
`and practices
`employing policies
`disadvantage African-Americans and/or that reinforce and continue
`the disparate impact of past discrimination;
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`failing to apply and enforce Amazon’s policies in a consistent, race-
`neutral fashion;
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`systematically paying African-Americans lower wages and/or
`denying African-Americans opportunities to increase their earnings;
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`individuals with known
`negligently hiring and/or retaining
`propensities to discriminate against or harass African-Americans;
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`creating an environment that is hostile and offensive to African-
`Americans;
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`complain of
`against African-Americans who
`retaliating
`discrimination by, among other things, subjecting them to further
`discrimination, retaliation, verbal attacks, discipline, reassignment,
`and/or termination;
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`m) making employment decisions based on racial stereotypes;
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`n)
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`employing policies and practices that have a disparate impact
`against African-Americans.
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`Amazon Subjected Plaintiffs to Unlawful Discrimination and Retaliation
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`23.
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`Consistent with Amazon’s pattern and practice of unlawful treatment
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`towards African-Americans, Plaintiffs were subjected to race discrimination throughout
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`their careers at Amazon.
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`24. Amazon failed to provide Plaintiffs with the same opportunities to
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`succeed and for promotion as non-African-Americans.
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`25.
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`Plaintiffs did not receive the same level of resources, mentoring, and
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`managerial support as their white and/or non-African American counterparts.
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`6
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 7 of 17 PageID #:7
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`26. As a result, Plaintiffs received lower wages than similarly situated non-
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`African-Americans.
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`27.
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`Like other African-Americans at Amazon’s distribution centers, Plaintiffs
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`were subjected to a hostile work environment in which African-Americans are treated
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`as inferior.
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`A.
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`28.
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`Quinton Jones
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`Jones was employed by Amazon at its Waukegan Illinois fulfillment
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`center from September 27, 2017, until his unlawful termination on January 21, 2021.
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`29.
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`As soon as Jones commenced his employment with Amazon he noticed
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`the stark racial disparities at the Waukegan location. Most -- if not all -- of the senior
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`leadership at the location was white. In terms of leadership in general, out of about 18
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`supervisors, there were only 3 to 4 minorities who held leadership positions.
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`30.
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`The numbers are equally dreadful at Human Resources. At the time of
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`Jones’ employment all the leaders who work at Human Resources were white.
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`31.
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`During Jones’ employment a Human Resources Assistant (HRA) full-
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`time position opened up. Even though Jones was highly qualified for the position, was
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`the only HR person working at the location, and expressed interest in the same, Amazon
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`denied him the promotion. Instead, Amazon promoted a white male. The reasons for
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`the failure to promote Jones were a pretext for discrimination.
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`32.
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`Eventually, Jones applied again to the HRA position, and based on his
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`past performance he was finally promoted in March 2019. Amazon however refused to
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`pay Jones what other non-African American HRAs were making. Whereas the position
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`7
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 8 of 17 PageID #:8
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`was listed as a Level 4 position, for no justifiable reason Amazon placed Jones in a
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`Level 3 position.
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`33.
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`As an HRA, Jones did not receive the necessary support from his
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`superiors. At Amazon, Jones reported to six (6) Human resources managers – all of
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`whom were white. All of Jones’ superiors were located outside Illinois.
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`34.
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`As the Assistant Human Resources for the Waukegan location, Jones
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`became privy to acts of discrimination committed by Amazon leaders. At the Waukegan
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`location, Jones observed that leaders belonged to a “club” and protected each other to
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`the detriment of African-Americans.
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`35.
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`During his time at Human Resources, Jones learned of at least eight (8)
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`complaints of discrimination and/or mistreatment brought by African American
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`employees. Rather than appropriately investigate and take corrective action, Amazon
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`brushed off the complaints and threw them under the rug.
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`36. At times Jones would push back pointing out, for example, that the white
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`manager subject to a complaint had been the subject of discrimination complaints in the
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`past. Jones’ input was ignored.
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`37. At one point, Brad Dietz, the Operations Manager called African-
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`American females who were protesting the brutal working conditions “worthless” and
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`asked Jones whether the females could be “terminated.” Jones was shaken by what is
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`clearly retaliatory behavior.
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`38.
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`Leaders at the Waukegan location would overwork the two black
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`managers of the location and give them the worst jobs.
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`39.
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`Jones observed the mistreatment of one of the African-American
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`8
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 9 of 17 PageID #:9
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`managers and co-plaintiff Eugene Edmond. The white leaders of the location would
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`ignore his needs, not give him credit for the excellent job he was doing, sidetracked his
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`career, and retaliated against him after he complained.
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`40.
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`Edmond was moved to the worst days to accommodate a white woman
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`in clear retaliation for his complaints and eventually terminated.
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`41.
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`Jones has knowledge that: (a) Edmond’s termination violated Amazons’
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`own established practices and (b) that at least two other white managers engaged in the
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`same behavior that led to Edmond’s termination but were not terminated. In fact, the
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`behavior was caught on camera, but white managers decided to protect their own and
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`turn a blind eye. White managers were heard saying – “the footage does not exist – you
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`never saw it”.
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`42. On January 21, 2021, Jones was unlawfully terminated for the pretextual
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`reason of “stealing time from the company.”
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`43.
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`Peak season would require warehouse employees to work 50-60 hours a
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`week. Part of Jones’ duties included handling overtime changes for seven hundred
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`employees and updating schedules for the twenty two different cohorts of the
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`warehouse. On many occasions, Jones had less than twenty-four hours to make these
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`changes.
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`44. Without the necessary support, making the changes required Jones to
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`work overtime, often from home. Indeed, throughout his time at Amazon, every year
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`Jones had worked overtime during peak season to ensure business continuity.
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`45.
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`In the later part of 2020, Jones was asked by leaders in operations to do
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`whatever was necessary – including working overtime -- to change schedules. Jones
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`9
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 10 of 17 PageID #:10
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`followed instructions and worked tirelessly to ensure that schedules were timely
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`updated.
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`46.
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`Even though Jones was asked to work overtime, had worked overtime in
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`past years, and had never been warned or disciplined relating to his prior overtime
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`requests (or for any reason) he was summarily fired for “stealing time.”
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`47.
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`Jones requests for a full investigation that would have shown that he
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`charged only time that he worked was denied. Other employees who are not African
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`American also worked overtime but were not fired.
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`B.
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`48.
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`Eugene Edmond
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` Edmond was employed by Amazon from September 2016 until his
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`unlawful termination on April 30, 2021.
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`49.
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`Edmond was originally hired by Amazon in an entry-level position at its
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`Joliet location – a Level 1 position.
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`50. During his job orientation, Edmond asked about the possibility of
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`obtaining a more senior position as he has an undergraduate degree and had prior
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`managerial experience. Edmond was immediately shot down by white managers who
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`simply told him that “he wasn’t qualified.”
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`51.
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`Shortly thereafter Edmond obtained a seasonal process assistant position.
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`Although normally the position is only held for about 90 days and individuals move to
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`full-time positions thereafter Edmond stayed in the position for more than 180 days.
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`52.
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`In or around March 2017, Edmond interviewed for a full-time Process
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`Assistant position. During the interview, the white manager – Robert Borges
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`(“Borges”) – asked only one question which was related to football. Edmond was so
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`10
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 11 of 17 PageID #:11
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`concerned about the interview that he went to Human Resources and explained that he
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`felt uncomfortable with the way Borges handled the interview.
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`53. During the next several months Edmond continued to have contact with
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`Borges. During these meetings, Borges would insist on calling Edmond by the name of
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`another black associate. Edmond would correct Borges and Borges would respond “you
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`guys all look alike” or words to that effect. Edmond would correct him that they did not,
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`but Borges would continue to call him by the wrong name. It got to the point where
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`Edmond’s manager – a black female – made a complaint to Human Resources on
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`Edmond’s behalf.
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`54.
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`Eventually, Edmond found out that Human Resources had taken no action
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`after he complained about the interview he had with Borges. He was told by the head of
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`Human Resources that there was no record of him interviewing for the position.
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`Edmond’s fears that the process was rigged were confirmed when ultimately the position
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`was given to a white male who – in contrast to Edmond – only had a high school diploma
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`and no previous experience.
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`55.
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`In 2018, Edmond finally moved to a full-time Process Assistant position.
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`To obtain this position, however, Edmond was relegated to the night shift. Initially,
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`Edmond received only 2 days of training (whereas others received 3 to 5 weeks).
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`56.
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`Edmond complained to the general manager about the lack of training as
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`he was being blamed by his manager for “not being able to keep up”. Even though
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`eventually Edmond received a few weeks of training his manager denied his request for
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`additional cross-training that would have allowed better performance.
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`57.
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`Edmond spent two years on the night shift. During this time, Edmond
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`11
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 12 of 17 PageID #:12
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`would repeatedly ask his managers for better opportunities. Edmond however was told
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`that “he was not a leader.”
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`58.
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`Edmond noticed the stark racial disparities at the Waukegan location for
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`those that were considered “leaders”. Most -- if not all -- of the senior leadership at the
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`location was white. In terms of leadership in general, out of about 18, there were only 3
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`to 4 minorities who held leadership positions.
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`59.
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`Edmond strived to obtain a manager position but was consistently shot
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`down. He was told he needed two years of experience and a bachelor’s degree. Even
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`though Edmond amply complied with the requirements for a promotion, white leaders
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`would often tell him that he was “not qualified” as he was “not a leader”.
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`60.
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`Even though his numbers were excellent, Amazon hired several outside
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`white managers instead of Edmond. At one point a white operations manager told
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`Edmond that his numbers were “ok” and that “in his case” he needed to deep dive.
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`61.
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`Edmond complained and specifically stated that he wasn’t being
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`promoted due to his race. He asked the general manager why others were being hired to
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`better positions while he was being left behind even though he had excellent numbers.
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`The general manager provided no viable explanations.
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`62. Ultimately, Edmond became a Level 4 manager in or around December
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`2019. Without the benefit of support or training, Edmond persisted. Edmond came up
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`with a new process. Under his leadership, he took the Waukegan distribution center from
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`one of the highest defect rates to zero defects. Edmond wrote a white paper which was
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`recognized nationally, and his process was incorporated throughout Amazon.
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`63.
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`Edmond desired and commenced training for an operations manager
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`12
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 13 of 17 PageID #:13
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`position. His white managers, however, set him up for failure. They moved Edmond to
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`the most excruciating position in the whole operation (outbound), failed to support him
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`and train him, and gave him an unrealistic amount of work. The general manager, as
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`well as his direct manager, would overwork Edmond, change his goals constantly and
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`not even talk to Edmond except to provide criticism.
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`64.
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`Edmond complained to the Operations Manager Mike Casale as well as
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`to Human Resources.
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`65.
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`Eventually Edmond was moved to inbound where he ran 2 shifts during
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`the night shift. Even though his numbers were excellent, and he had obtained the shift
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`plant manager position, Edmond was passed over for promotion and moved again to
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`outbound where he was told he would need to “start from the bottom and move up.”
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`66. During this time, Edmond was given the worst schedule, he was again
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`denied the appropriate training, denied a transfer request, given higher goals than his
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`colleagues, given more difficult end of shift requirements and exposed to racial
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`comments. For example, his manager would make negative comments about the black
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`lives matter movement stating such things as “the Black Lives Matter movement is just
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`a façade to get free stuff” and “your friends are protesting to loot and get free stuff.”
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`67.
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`Edmond complained again to Mike Casale and specifically stated that he
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`was being targeted because he is black.
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`68.
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`Rather than protect Edmond, Amazon leaders permitted the same
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`individuals against who Edmond had complained about to falsely accuse Edmond of
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`theft, and proceeded to conduct a shoddy investigation against Edmond. Edmond was
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`told that he was allegedly observed taking food from the kiosk and not paying for it.
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`13
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 14 of 17 PageID #:14
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`69. On April 30, 2021, Edmond received a voice mail from his direct manager
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`(a person who he had accused of discrimination) stating that his employment was being
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`terminated. The reasons for the termination were a pretext for discrimination and
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`retaliation.
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`70.
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`Edmond has uncovered evidence that (a) his termination violated
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`Amazons’ own established practice and/or policy and (b) that at least two other white
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`employees engaged in the same behavior that led to his termination but were not
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`terminated.
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`71.
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`Indeed, the behavior of a white employee was caught on camera, but white
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`managers decided to protect their own and turn a blind eye. White managers were heard
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`saying – “the footage does not exist – you never saw it”.
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` COUNT I
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`Title VII—Discrimination and Retaliation on the Basis of Race
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`72.
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` Plaintiffs reallege the foregoing paragraphs as though fully set forth
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`herein.
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`73.
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`Plaintiffs are members of a protected class on the basis of race. They are
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`African-Americans.
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`74.
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`Plaintiffs, in all respects, were performing their jobs in a manner that was
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`consistent with Defendant’s legitimate business expectations.
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`75.
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`Amazon discriminated against Plaintiffs as described above, including but
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`not limited to subjecting them to a hostile work environment, denying them promotions and
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`terminating their employment.
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`76.
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`Amazon also retaliated against Plaintiffs as described above.
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`14
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 15 of 17 PageID #:15
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`77.
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`Amazon’s actions were taken with a willful and wanton disregard of
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`Plaintiffs’ rights under Title VII.
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`78.
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`As a direct and proximate result of said unlawful employment practices and
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`in disregard of Plaintiffs’ rights, Plaintiffs have suffered humiliation, degradation,
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`emotional distress, other consequential damages, and lost wages.
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`COUNT II
`Illinois Human Rights Act —Discrimination and Retaliation
`on the Basis of Race
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`Plaintiffs reallege the foregoing paragraphs as though fully set forth herein.
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`Plaintiffs are members of a protected class on the basis of race.
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`Plaintiffs, in all respects, were performing their job in a manner that was
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`79.
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`80.
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`81.
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`consistent with Defendant’s legitimate business expectations.
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`82.
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`Amazon discriminated against Plaintiffs as described above, including but
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`not limited to subjecting them to a hostile work environment, denying them promotions and
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`firing them.
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`83.
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`84.
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`Amazon also retaliated against Plaintiffs as described above.
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`Amazon’s actions were taken with a willful and wanton disregard of
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`Plaintiffs’ rights under the IHRA.
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`85.
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`As a direct and proximate result of said unlawful employment practices and
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`in disregard of Plaintiffs’ rights and sensibilities, Plaintiffs have suffered humiliation,
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`degradation, emotional distress, other consequential damages, and lost wages.
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`COUNT III
`Section 1981—Discrimination and Retaliation on the Basis of Race
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`86.
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`Plaintiffs reallege the foregoing paragraphs as though fully set forth herein.
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 16 of 17 PageID #:16
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`87.
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`88.
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`Plaintiffs are members of a protected class on the basis of race.
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`Plaintiffs, in all respects, were performing their job in a manner that was
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`consistent with Amazon’s legitimate business expectations.
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`89.
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`Amazon discriminated against Plaintiffs as described above, including but
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`not limited to subjecting them to a hostile work environment, denying them promotions and
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`firing them.
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`90.
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`91.
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`Amazon also retaliated against Plaintiffs as described above.
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`Amazon’s actions were taken with a willful and wanton disregard of
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`Plaintiffs’ rights under Section 1981.
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`92.
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`As a direct and proximate result of said unlawful employment practices and
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`in disregard of Plaintiffs’ rights and sensibilities, Plaintiffs have suffered humiliation,
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`degradation, emotional distress, other consequential damages, and lost wages.
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`WHEREFORE, Plaintiffs requests that this Honorable Court enter judgment
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`in their favor and against Defendant, and enter an Order awarding the following relief:
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`a.
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`b.
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`c.
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`d.
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`e.
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`g.
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`All wages and benefits he would have received but for the
`discrimination and prejudgment interest;
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`Reinstatement to their positions or, in the alternative, front pay for a
`reasonable period of time;
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`Compensatory damages;
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`An award of costs and reasonable attorney’s fees;
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`Damages as provided under Illinois law;
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`Such other relief as the Plaintiff may be entitled to under the Title VII,
`Section 1981 and the IHRA and any other statute or law which the Court
`deems equitable and just.
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`Case: 1:23-cv-02735 Document #: 1 Filed: 05/01/23 Page 17 of 17 PageID #:17
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`JURY TRIAL DEMAND
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`Plaintiffs hereby demand a jury trial as provided by Rule 38(a) of the Federal Rules
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`of Civil Procedure.
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`RESPECTFULLY SUBMITTED.
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`In Chicago, Illinois this 1st day of May 2023.
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`LÁZARO LAW GROUP, LLC
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`Attorneys for Eugene Edmond and Quinton Jones
`321 S. Plymouth Ct. Ste. 1250
`Chicago, IL 60604
`Tel. 312-461-9900
`Fax. 312-858-6735
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`____________________________
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`Rafael E. Lázaro
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` Pedro Giner
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`rlazaro@lazarolawgroup.com
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` Pginer@lazarolawgroup.com
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