Case 1:20-cv-11358-ADB Document 1 Filed 07/20/20 Page 1 of 17
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`
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`SUVERINO FRITH, SAVANNAH KINZER,
`CEDRICK JUAREZ, FAITH WALSH,
`MACKENZIE SHANAHAN, COREY SAMUEL,
`ABDULAI BARRY, LINDSAY VUONG,
`SAMANTHA BERIMBAU, CAMILLE TUCKER-
`TOLBERT, ANA BELÉN DEL RIO-RAMIREZ,
`LYLAH STYLES, KAYLA GREENE, and
`SHARIE ROBINSON, individually and on
`behalf of all others similarly situated,
`
` Plaintiffs,
`
`v.
`
`WHOLE FOODS MARKET, INC.
`
` Defendant
`
`
`
`
`
`Case No. _________________
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`
`
`
`
`
`CLASS ACTION COMPLAINT REQUESTING
`PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF
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`Due to the onset of the global coronavirus pandemic, grocery workers (like
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`1.
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`many other workers around the country) are now required to wear masks to work.
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`Following the death of George Floyd and demonstrations this spring around the country
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`protesting police violence and other discrimination against Blacks, more people have
`
`been showing their support for the Black Lives Matter movement. Recently, in a show of
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`solidarity, Whole Foods employees in a number of stores around the country began
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`wearing masks with the message Black Lives Matter. They did this to protest racism and
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`police violence against Blacks and to show support for Black employees.
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`2.
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` Although Whole Foods and its parent company Amazon have professed to
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`support the Black Lives Matter movement, Whole Foods began disciplining employees
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`for wearing these masks. Although Whole Foods had not previously strictly enforced its
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`Case 1:20-cv-11358-ADB Document 1 Filed 07/20/20 Page 2 of 17
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`dress code policy (and had not disciplined employees for wearing other messages,
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`including political messages), the company began sending employees home without pay
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`for wearing Black Lives Matters masks. Whole Foods has threatened employees with
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`termination if they continue wearing the masks. In some locations, employees have
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`been given disciplinary “points” when they are sent home for wearing the mask, which
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`put them at risk for termination. One of the lead organizers, Plaintiff Savannah Kinzer,
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`was terminated on Saturday, July 18, 2020, because of the discipline she received for
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`wearing a Black Lives Matter mask and for her involvement and leadership in organizing
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`her co-workers to wear the masks and protesting Whole Foods’ discipline of employees
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`for doing so.
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`3.
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`The above-named plaintiffs now bring this Complaint on behalf of themselves
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`and other similarly situated employees who have worked for Defendant Whole Foods
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`Market, Inc. (“Whole Foods”), alleging that Whole Foods has violated Title VII of the Civil
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`Rights Act of 1964, 42 U.S.C. § 2000e, et seq., by discriminating against Black employees
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`and other employees for showing support for Black employees and protesting racism in the
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`workplace by wearing Black Lives Matter masks. Whole Foods has further retaliated
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`against employees for protesting racism in the workplace and protesting Whole Foods’
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`failure to allow employees to wear Black Lives Matter masks at work.
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`4. Whole Foods’ selective enforcement of its dress code in disciplining
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`employees who wear apparel expressing support for the Black Lives Matter movement
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`constitutes unlawful discrimination on the basis of race and on the basis of employees’
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`affiliation with and advocacy for Black employees. Whole Foods has further unlawfully
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`Case 1:20-cv-11358-ADB Document 1 Filed 07/20/20 Page 3 of 17
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`retaliated against its employees in violation of Title VII for their opposition to its unlawful and
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`discriminatory practices.
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`5.
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`Plaintiffs bring this claim on behalf of themselves and similarly situated
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`Whole Foods employees across the country who have been subject to Whole Foods’
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`discriminatory and retaliatory policy. Plaintiffs seek preliminary and permanent injunctive
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`relief, calling for an end to Whole Foods’ policy of not allowing employees to wear Black
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`Lives Matter masks at work. They also seek redress for employees who have been
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`disciplined for wearing Black Lives Matter masks, including expungement of discipline
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`from the records of those employees who have been disciplined, back pay for employees
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`who have been sent home without pay, and reinstatement of Plaintiff Savannah Kinzer
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`who was terminated in retaliation for wearing a Black Lives Matter mask and protesting
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`Whole Foods’ discriminatory and retaliatory policy.
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`II.
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`PARTIES
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`6.
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`Plaintiff Suverino Frith resides in Randolph, Massachusetts, and works for
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`Whole Foods at the River Street location in Cambridge, Massachusetts.
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`7.
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`Plaintiff Savannah Kinzer resides in Boston, Massachusetts, and worked
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`for Whole Foods at the River Street location in Cambridge, Massachusetts, until her
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`termination on July 18, 2020.
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`8.
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`Plaintiff Cedrick Juarez resides in Boston, Massachusetts, and works for
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`Whole Foods at the River Street location in Cambridge, Massachusetts.
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`9.
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`Plaintiff Faith Walsh resides in Boston, Massachusetts, and works for
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`Whole Foods at the River Street location in Cambridge, Massachusetts.
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`10. Plaintiff Mackenzie Shanahan resides in Cambridge, Massachusetts, and
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`works for Whole Foods at the River Street location in Cambridge, Massachusetts.
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`11. Plaintiff Corey Samuel resides in Dorchester, Massachusetts, and works
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`for Whole foods at the River Street location in Cambridge, Massachusetts.
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`12. Plaintiff Abdulai Barry resides in Cambridge, Massachusetts, and works for
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`Whole Foods at the Alewife Parkway (Fresh Pond) location in Cambridge,
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`Massachusetts.
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`13. Plaintiff Lindsay Vuong resides in Belmont, Massachusetts, and works for
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`Whole Foods at the Alewife Parkway (Fresh Pond) location in Cambridge,
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`Massachusetts.
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`14. Plaintiff Samantha Berimbau resides in Melrose, Massachusetts, and
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`works for Whole Foods at the Alewife Parkway (Fresh Pond) location in Cambridge,
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`Massachusetts.
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`15. Plaintiff Camille Tucker-Tolbert resides in Federal Way, Washington, and
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`worked for Whole Foods at the Westlake Avenue in Seattle, Washington.
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`16. Plaintiff Ana Belén Del Rio-Ramirez resides in Oakland, California, and
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`worked for Whole Foods at the Telegraph Avenue location in Berkeley, California.
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`17. Plaintiff Lylah Styles resides in Manchester, New Hampshire, and works for
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`Whole Foods at the Orchard Street location in Bedford, New Hampshire.
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`18. Plaintiff Kayla Greene resides in Manchester, New Hampshire, and works
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`for Whole Foods at the Orchard Street location in Bedford, New Hampshire.
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`19. Plaintiff Sharie Robinson resides in Manchester, New Hampshire, and
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`works for Whole Foods at the Orchard Street location in Bedford, New Hampshire.
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`20. Plaintiffs brings these claims on behalf of themselves and similarly situated
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`Whole Foods employees across the country who have been subjected to Whole Foods’
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`discriminatory and retaliatory policy of not allowing employees to wear Black Lives
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`Matter masks at work.
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`21. Defendant Whole Foods Market, Inc. is a corporation headquartered in
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`Austin, Texas. Whole Foods operates hundreds of grocery stores throughout the United
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`State. Whole Foods is owned by parent corporation Amazon.com, Inc., a corporation
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`headquartered in Seattle, Washington.
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`III.
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`JURISDICTION AND VENUE
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`22.
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`This Court has general federal question jurisdiction over this matter
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`pursuant to 28 U.S.C. § 1331, as this case arises under federal law, namely, Title VII of
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`the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq.
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`23.
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`The District of Massachusetts is a proper venue for this action pursuant to
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`28 U.S.C. § 1391(b)(2) because a substantial part of the events giving rise to the claim
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`took place in Massachusetts.
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`IV.
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`STATEMENT OF FACTS
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`24.
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`In recent weeks, Plaintiffs and other Whole Foods employees across the
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`country have been subject to unlawful discrimination and retaliation by Whole Foods
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`through its selective enforcement of its dress code policy.
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`25. Specifically, Whole Foods has prohibited its employees from wearing
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`masks and other apparel and accessories with the message Black Lives Matter.
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`26. Across its stores, Whole Foods maintains a dress code policy which
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`nominally prohibits employees from wearing clothing with visible slogans, messages,
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`logos, or advertising that are not company-related.
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`27. Until recently, however, this policy was generally unenforced.
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`28.
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`For example, Whole Foods employees have worn apparel bearing various
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`logos, such as those of local sports teams, as well as apparel with other messages and
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`slogans, including political messages, without facing discipline. Employees have
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`commonly worn Pride flags in support of their LGBTQ+ coworkers without being
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`disciplined by Whole Foods. Employees have not been sent home or received discipline
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`for wearing Pride pins or apparel.
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`29. When employees have violated the dress code policy, in the past, it has
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`either been ignored, or sometimes management has informed employees about it but
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`without sending them home or imposing other discipline.
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`30. Due to the onset of the global coronavirus pandemic, grocery workers (like
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`many other workers across the country) are now required to wear masks to work.
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`31. Whole Foods employees began wearing masks emblazoned with different
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`images or slogans. For example, at the Bedford, New Hampshire, Whole Foods
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`location, one employee was allowed to wear a SpongeBob mask without any
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`repercussions. At the Seattle, Washington, location, another Whole Foods employee
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`wore a mask with images and names of vegetables, without being disciplined. At the
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`Berkeley, California location, employees have been allowed to wear masks with prints.
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`32.
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`Following the death of George Floyd and demonstrations this spring
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`around the country protesting police violence and other discrimination against Blacks,
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`more people have been showing their support for the Black Lives Matter movement.
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`33. Around June 2020, many Black Whole Foods employees and their non-
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`Black coworkers began wearing masks with the message Black Lives Matter.
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`34. Plaintiffs and other Whole Foods employees expected Whole Foods would
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`support their decision to wear these masks because Whole Foods has expressed
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`support for inclusivity and equality and because it previously allowed its employees to
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`express support for their LGBTQ+ coworkers through their apparel without discipline.
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`35.
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`Following the death of George Floyd and nationwide protests against police
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`violence and racism against Blacks, Whole Foods stated on its website: “Racism has no
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`place here.” The text is in a large banner with the caption: “Racism and discrimination of
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`any kind have no place at Whole Foods Market. We support the black community and
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`meaningful change in the world.”
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`36. Whole Foods parent company Amazon ran a “Black Lives Matter” banner
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`on its website and CEO Jeff Bezos defended the statement.
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`37. Nonetheless, although Whole Foods had not previously done so, Whole
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`Foods began strictly enforcing its dress code policy once its employees started wearing
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`Black Lives Matter masks and other Black Lives Matter apparel, such as pins or
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`sneakers. Whole Foods began subjecting Plaintiffs and other employees to discipline if
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`they refused to remove their Black Lives Matter masks.
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`38.
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`For example, at the River Street location in Cambridge, Massachusetts,
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`Whole Foods has been sending home employees (including Plaintiffs Frith, Kinzer,
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`Juarez, Walsh, Shanahan, and Samuel) who show up to work wearing a Black Lives
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`Matter mask.1 The employees receive no pay for reporting to work and are given
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`disciplinary “points” and sent home for wearing the mask. These points are part of a
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`progressive discipline policy, and employees are subject to termination once they
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`accumulate a certain amount of points.
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`39.
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`Likewise, at the Fresh Pond location in Cambridge, Massachusetts, Whole
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`Foods has also sent employees home without pay for refusing to remove their Black
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`Lives Matter masks (including Plaintiffs Barry, Vuong, and Berimbau).
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`40.
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`In Seattle, Washington, Whole Foods has been writing its employees up for
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`wearing the Black Lives Matter mask. The employees have also been placed on a
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`“corrective action pathway,” that requires employees to re-train.2 Plaintiff Tucker-Talbot
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`was placed on a corrective action pathway and was sent home on two occasions for
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`wearing her Black Lives Matter mask. She recently left the position due to feeling
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`unwelcome in the workplace after having been disciplined for wearing her Black Lives
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`Matter mask. Despite giving two weeks notice of her resignation, she was told to leave
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`immediately.
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`41.
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`In Berkeley, California, Whole Foods has sent employees home for
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`wearing Black Lives Matter masks and pins, including Plaintiff Del-Rio Ramirez. She
`
`
`Katie Johnston, Whole Foods workers sent home for wearing Black Lives Matter
`1
`masks, Boston Globe (June 25, 2020),
`https://www.bostonglobe.com/2020/06/25/business/whole-foods-workers-sent-home-
`wearing-black-lives-matter-masks/.
`
`2
`Irina Ivanova, Whole Foods Workers Protest for Right to Wear ‘Black Lives
`Matter’ Masks, CBS News (June 28, 2020), https://www.cbsnews.com/news/black-lives-
`matter-whole-foods-workers-protest-masks/.
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`likewise left the position due to feeling unwelcome in the workplace after having been
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`disciplined for wearing her Black Lives Matter pin.
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`42.
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`In Bedford, New Hampshire, Whole Foods has also been assigning
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`employees a disciplinary “point” for wearing the Black Lives Matter mask and sending
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`workers home without pay if they refuse to take off the mask.3 Plaintiffs Styles and
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`Greene have both been sent home without pay and subject to discipline for wearing
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`Black Lives Matter masks. After witnessing the discipline, Plaintiff Robinson stopped
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`wearing her mask because she could not afford to be sent home or risk termination.
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`43.
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`It is widely reported that Whole Foods employees at other locations as well,
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`such as in Philadelphia, Pennsylvania; Wilmington, North Carolina; Michigan; and
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`Milford, Connecticut, have also been subjected to similar discipline for wearing the Black
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`Lives Matter masks or other apparel (or Black Lives Matters statements of support) to
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`work.4
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`
`3
`Melanie Tynn, 2 NH Whole Foods Employees Sent Home for Wearing Black
`Lives Matter Masks: Report, NECN (June 15, 2020).
`https://www.necn.com/news/local/new-hampshire/two-nh-whole-foods-employees-sent-
`home-for-wearing-black-lives-matter-masks-report/2286102/.
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` 4
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`See, e.g., Allison Steele, Whole Foods Employees Demanding the Right to Wear
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`Black Lives Matter Apparel at Work, The Philadelphia Inquirer (June 21, 2020).
`https://www.inquirer.com/news/whole-foods-black-lives-matter-protest-employees-
`masks-starbucks-20200621.html (reporting that several employees at the South Street
`location in Philadelphia, PA, had been sent home for wearing Black Lives Matter
`masks); Zach Murdock, Milford Whole Foods Employees Join Nationwide Protests to
`Allow Staff to Wear Black Lives Matter Items, Hartford Courant, July 7, 2020,
`https://www.courant.com/breaking-news/hc-br-milford-whole-foods-black-lives-matter-
`20200707-2o7maelsnvdbrkdn63xx4657mq-story.html (reporting that several employees
`were sent home for wearing shirts with the statement “Racism has no place here”); Kate
`Taylor & Hayley Peterson, Workers Speak Out Against Black Lives Matter Face Mask
`Bans, as Companies Like Starbucks, Taco Bell, and Whole Foods Grapple with Viral
`Backlash, Business Insider, July 12, 2020, https://www.msn.com/en-
`us/money/companies/workers-speak-out-against-black-lives-matter-face-mask-bans-as-
`
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`44. Whole Foods has made a corporate decision not to allow its employees to
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`wear the Black Lives Matter masks. Employees at the River Street location in
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`Cambridge, Massachusetts, were told by their managers that store-level management
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`had no discretion over the decision. Management likewise told employees at the
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`Berkeley, California, location that the decision came from above and was out of their
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`hands.
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`45.
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`Indeed, a Whole Foods Market spokesperson has confirmed that Whole
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`Foods employees are being prohibited from wearing Black Lives Matter masks and
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`apparel across locations.5
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`46. Whole Foods’ policy of not allowing its employees to wear Black Lives
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`Matter masks is discriminatory, both against Black employees who are participating in
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`and leading the employee protest, and against other employees who are associating with
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`and advocating for Black Whole Foods employees and protesting racism and
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`discrimination in the workplace, by wearing the masks and showing support for their
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`Black co-workers.
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`47.
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`Further, as the protest has proceeded over the last weeks, employees are
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`wearing the masks in order to challenge what they perceive to be racism and
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`discrimination by Whole Foods for not allowing employees to wear the Black Lives
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`companies-like-starbucks-taco-bell-and-whole-foods-grapple-with-viral-backlash/ar-
`BB16DWsc (reporting that Whole Foods employees at stores in Michigan, Connecticut,
`and North Carolina had worn Black Lives Matter gear to work and were told by
`management to either remove it or go home).
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`
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` 5
`
`See Nicole Karlis, Whole Foods is Quietly Telling Workers Not to Show Black
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`Lives Matter Support at Work, June 27, 2020, https://www.salon.com/2020/06/27/whole-
`foods-is-quietly-telling-workers-not-to-show-black-lives-matter-support-at-work/.
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`Matter masks. Whole Foods’ discipline of these employees constitutes retaliation
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`against the employees for engaging in protected activity, namely opposing discrimination
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`and racism in the workplace.
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`48.
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`This retaliation has deterred many Whole Foods employees from
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`supporting the protest and wearing Black Lives Matter masks at work. For example,
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`Plaintiff Sherie Robinson’s daughter was disciplined for wearing a mask, and so Ms.
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`Robinson, who wants to wear one, has refrained from continuing to do so because she is
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`afraid of losing her job or being sent home without pay.
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`49. Whole Foods has forced Plaintiffs and other Whole Foods employees to
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`remove their Black Lives Matter masks and has disciplined, refused to pay, and has sent
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`home, and continues to discipline, deny pay, and send home employees, in response to
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`their wearing the Black Lives Matter masks on their shifts.
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`50. Plaintiffs and other Whole Foods employees believe that the decision by
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`Whole Foods to selectively enforce its dress code policy in order to ban Black Lives
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`Matter masks is discriminatory and unlawful because Whole Foods has not strictly
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`enforced the dress code policy before and did not discipline employees for wearing
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`apparel with other political messages, including apparel similarly supportive of their
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`LGBTQ+ coworkers.
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`51. Whole Foods has retaliated and continues to retaliate against Plaintiffs and
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`other employees for their ongoing opposition to the discriminatory and retaliatory policy
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`by subjecting them to discipline for their protected activity in opposing what they
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`reasonably believe are discriminatory and retaliatory policies.
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`52. On July 18, 2020, Plaintiff Savannah Kinzer, who has been a leader in
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`organizing employees to wear the Black Lives Matter masks (and has led a number of
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`protests outside Whole Foods stores, challenging the company’s policy of not allowing
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`employees to wear the masks), was fired. She was terminated due to her accumulation
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`of disciplinary points, most of which she received as a result of wearing the Black Lives
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`Matter mask. She was also terminated in retaliation for being a leader in organizing the
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`employees to wear the masks and protesting the company’s policy of disciplining
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`employees for wearing the masks.
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`53.
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`Just prior to being terminated, Ms. Kinzer informed management that she
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`was legally challenging Whole Foods for its discriminatory and retaliatory policy and that
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`she had filed a charge of discrimination and retaliation with the Equal Employment
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`Opportunity Commission and a charge of unfair labor practices with the National Labor
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`Relations Board. She provided a manager with a copy of the filed charges. She was
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`fired about an hour later and escorted out of the store.
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`V.
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`CLASS ACTION ALLEGATIONS
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`54. Plaintiffs bring this case as a class action on behalf of all Whole Foods
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`employees who have been subject to Whole Foods’ policy of not allowing employees to
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`wear Black Lives Matter masks, including employees who have been disciplined or
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`subject to adverse employment action for wearing the masks or for opposing Whole
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`Foods’ practice of disciplining employees for wearing Black Lives Matter masks.
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`55.
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`This class will meet the prerequisites of Fed. R. Civ. P. 23(a) and Fed. R.
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`Civ. P. 23(b)(2) and 23(b)(3) specifically, in that:
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`a. The class is so numerous that joining all members is impracticable. The
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`exact number of the members of the class is unknown, but Whole Foods
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`employees across the country have been prohibited from wearing Black
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`Lives Matter masks and other related apparel at work. In addition, well
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`more than forty (40) Whole Foods employees have been disciplined for
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`wearing Black Lives Matter masks and opposing Whole Foods’ practice of
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`disciplining employees for wearing Black Live Matter masks. As a result,
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`joinder of all of these individuals is impracticable.
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`b. There are questions of fact and law common to all of these potential class
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`members, because all of these individuals have been subject to Whole
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`Foods’ policy of not allowing employees to wear Black Lives Matter
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`masks.
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`c. The claims of the named plaintiffs are typical of the claims of employees
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`across the country who have been subject to Whole Foods’ policy of not
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`allowing employees to wear Black Lives Matter masks and who have been
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`disciplined for wearing the masks.
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`d. Plaintiffs and their counsel will fairly and adequately represent the
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`interests of each class. The named plaintiffs have no interests adverse to
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`or in conflict with the class members whom they propose to represent.
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`Plaintiffs’ counsel are well qualified to litigate this case, as they have been
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`recognized as leading counsel nationally for representing the rights of
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`employees in class action and other employment litigation across the
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`nation.
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`e. The questions of law or fact common to all members of each class
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`predominate over any questions affecting only individual members. The
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`common questions include, among other things, whether Whole Foods’
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`policy of prohibiting employees from wearing Black Lives Matter masks
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`and disciplining employees who do so is discriminatory and retaliatory.
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`f. Litigating these claims as a class action is superior to other available
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`methods for the fair and efficient adjudication of these claims. Among
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`other things, individual adjudications would result in a highly inefficient
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`duplication of discovery, legal briefing, court proceedings, and the risk of
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`inconsistent legal rulings. Further, the alternative to a class action may be
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`no redress for the rights of many Whole Foods employees across the
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`country who would not litigate these claims individually.
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`VI. EXHAUSTION OF ADMINISTRATIVE REMEDIES
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`56. Plaintiffs Frith, Kinzer, Del-Rio Ramirez, and Tucker-Tolbert timely filed
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`Class Charges of Discrimination with the Equal Employment Opportunity Commission
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`(“EEOC”) prior to filing this complaint. Based on the urgent circumstances, Plaintiffs are
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`filing this lawsuit in court so that they may seek emergency preliminary injunctive relief
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`prior to receiving “right to sue” letters from the EEOC.
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`COUNT I
`
`RACE DISCRIMINATION
`in Violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2
`
`
`
`Plaintiffs re-allege and incorporate the above paragraphs by reference as if fully
`
`set forth herein. The conduct of Whole Foods in selectively enforcing its dress code
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`policy to ban employees from wearing Black Lives Matter masks and related apparel
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`constitutes unlawful discrimination based on race, because the policy has both
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`adversely affected Black employees and it has singled out for disfavored treatment
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`advocacy and expression of support for Black employees, by both Black employees and
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`their non-Black coworkers who have associated with them and shown support for them
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`through wearing, or attempting to wear, the Black Lives Matter masks at work. This
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`claim is brought on behalf of a class of Whole Foods employees across the country who
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`have been affected by Whole Foods’ policy challenged here.
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`
`
`COUNT II
`
` RETALIATION
`in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-3
`
`
`Plaintiffs re-allege and incorporate the above paragraphs by reference as if fully
`
`set forth herein. Whole Foods’ discipline of its employees for opposing its
`
`discriminatory policy in not allowing employees to wear Black Lives Matter masks at
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`work constitutes unlawful retaliation in violation of Title VII, 42 U.S.C. § 2000e-3. This
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`claim is brought on behalf of a class of Whole Foods employees across the country who
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`have been affected by Whole Foods’ policy challenged here.
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`JURY DEMAND
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`Plaintiffs request a trial by jury on all claims.
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`WHEREFORE, Plaintiffs request that this Court enter the following relief:
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`Find and declare that Whole Foods’ policy of not allowing employees to
`1.
`wear Black Lives Matter masks and related apparel at work, and disciplining
`employees who challenge the policy, constitutes discrimination and retaliation in
`violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq.;
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`Issue an injunction, immediately enjoining Whole Foods from terminating
`2.
`or otherwise continuing to discipline employees for wearing Black Lives Matter
`masks or related apparel during their shifts; and ordering that Whole Foods
`expunge any discipline accumulated by employees for wearing Black Lives
`Matter masks or related apparel;
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`Certify a class action pursuant to Fed. R. Civ. P. 23(b)(2) and Fed. R. Civ.
`3.
`P. 23(b)(3) and appoint Plaintiffs as class representatives and their counsel as
`class counsel;
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`Award compensatory damages, including back pay, for employees who
`4.
`have been sent home from work without pay, due to Whole Foods’ unlawful
`policy;
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`Reinstate Plaintiff Savannah Kinzer, who was fired in retaliation for
`5.
`wearing a Black Lives Matter mask, opposing racism in the workplace, and
`organizing her coworkers to wear the masks and protest Whole Foods’
`discriminatory and retaliatory policy;
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`Award any other damages that may be appropriate, including damages for
`5.
`emotional distress and punitive damages, including for employees who have
`been constructively discharged from their positions, based upon Whole Foods’
`discriminatory and retaliatory policy;
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`6.
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`7.
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`8.
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`Award all costs and attorneys’ fees incurred prosecuting this action;
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`Award interest;
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`Any other relief to which Plaintiffs and class members may be entitled.
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`16
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`Case 1:20-cv-11358-ADB Document 1 Filed 07/20/20 Page 17 of 17
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`Dated: July 20, 2020
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`Respectfully submitted,
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`SUVERINO FRITH, SAVANNAH KINZER,
`CEDRICK JUAREZ, FAITH WALSH,
`MACKENZIE SHANAHAN, COREY SAMUEL,
`ABDULAI BARRY, LINDSAY VUONG,
`SAMANTHA BERIMBAU, CAMILLE TUCKER-
`TOLBERT, ANA BELÉN DEL RIO-RAMIREZ,
`LYLAH STYLES, KAYLA GREENE, and
`SHARIE ROBINSON, individually and on
`behalf of all others similarly situated,
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`By their attorneys,
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`/s/ Shannon Liss-Riordan________________
`Shannon Liss-Riordan, BBO #640716
`Anastasia Doherty, BBO #705288
`LICHTEN & LISS-RIORDAN, P.C.
`729 Boylston Street, Suite 2000
`Boston, MA 02116
`(617) 994-5800
`Email: sliss@llrlaw.com, adoherty@llrlaw.com
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`17
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