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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 1 of 10
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF PENNSYLVANIA
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`IGE ISIJOLA,
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`Plaintiff;
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`v.
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`PHARMACEUTICAL RESEARCH
`ASSOCIATES, INC. d/b/a PRA HEALTH
`SCIENCES,
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`Defendant.
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`JURY DEMANDED
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`Civil Action
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`No. _____________________
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`COMPLAINT
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`Plaintiff, Ige Isijola, by and through his undersigned counsel, files this Complaint and avers
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`as follows:
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`PARTIES AND JURISDICTION
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`1. Plaintiff, Ige Isijola (“Plaintiff”), is an adult individual residing in Feasterville, Bucks
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`County, Pennsylvania.
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`2. Upon information and belief, Defendant Pharmaceutical Research Associates, Inc., d/b/a
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`PRA Health Sciences is headquartered in Raleigh, North Carolina, at 4130 Parklake Avenue, Suite
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`400, Raleigh, North Carolina 27612.
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`3. At all times material hereto, Plaintiff was employed by Defendant.
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`4. At all times material hereto, Defendants acted by and through their agents, servants, and
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`employees, each of whom acted at all times relevant herein in the course and scope of their
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`employment with and for Defendants.
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`Page 1 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 2 of 10
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`5. Plaintiff has exhausted his administrative remedies pursuant to the Equal Employment
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`Opportunity Act and the Pennsylvania Human Relations Act. (See Exhibit “A”, a true and correct
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`copy of the “Notice of Rights” issued by the Equal Employment Opportunity Commission.)
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`6. This action is instituted pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. §
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`2000e, et seq., (“Title VII”); the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101, et
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`seq.; and the Pennsylvania Human Relations Act, 43 P.S. § 951, et seq. (the “PHRA”).
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`7. Jurisdiction is conferred by 28 U.S.C. § 1331 and § 1343.
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`8.
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`Supplemental jurisdiction over Plaintiff’s state law claims is conferred pursuant to 28
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`U.S.C. § 1367.
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`9. The venue is properly laid in this district because Defendant conducts business in this
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`district and because a substantial part of the acts and omissions giving rise to the claims set forth
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`herein occurred in this judicial district. 28 U.S.C. §§ 1391(b)(1) and (b)(2).
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`GENERAL ALLEGATIONS
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`10. Plaintiff is Nigerian.
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`11. At all times material hereto, Plaintiff suffered from a medical condition that caused him to
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`bleed when he sits and required a colonoscopy.
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`12.
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`In or around February 2013, Defendant hired Plaintiff as a Senior Clinical Researcher.
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`13. At the time of his termination, Plaintiff earned $110,000 annually.
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`14. Plaintiff performed his job duties to Defendant’s satisfaction and without any complaint or
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`issue.
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`15. Plaintiff’s supervisors included Emily Chambers and Kerri Cali.
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`16. Towards the end of 2018, Plaintiff began experiencing disparate treatment by Ms.
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`Chambers and Ms. Cali, including, without limitation:
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`Page 2 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 3 of 10
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`a. Ms. Chambers and Ms. Cali complained to Plaintiff that two of his clients
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`complained about his English, referring to his Nigerian accent;
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`b. Ms. Cali constantly nitpicked Plaintiff’s writing. For example, Ms. Cali had already
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`approved a report by a Caucasian co-worker but she had an issue with Plaintiff’s
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`identical report;
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`c. Ms. Cali had only negative feedback regarding Plaintiff; and
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`d. Plaintiff began receiving unwarranted write-ups from Ms. Chambers and Ms. Cali
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`regarding his work.
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`17. Ms. Chambers and Ms. Cali did not treat non-Nigerian and/or non-African-American
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`employees similarly.
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`18.
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`In the six years leading up to the write-ups, Plaintiff was never told there was an issue with
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`his work and he never received a write-up until there were complaints about his Nigerian accent.
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`19. Ms. Chambers and Ms. Cali were micromanaging Plaintiff’s work because they had a
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`problem with his Nigerian accent and wanted to get rid of him.
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`20.
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`In or around August of 2019, Plaintiff spoke to Megan Jung, his manager, about needing
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`time off for medical reasons.
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`21. Plaintiff constantly asked Ms. Jung if she would approve one day off for him to have a
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`medical procedure done.
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`22. Ms. Jung continuously delayed approving Plaintiff a day off for his medical procedure.
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`23. On or about November 07, 2019, Defendant terminated Plaintiff.
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`Page 3 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 4 of 10
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`CAUSES OF ACTION
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`Count I
`Discrimination and Wrongful Termination Based on National
`Origin in Violation of Title VII
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`24. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`25. Plaintiff is Nigerian and, as such, is a member of a class protected by Title VII, i.e. national
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`origin.
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`26. Plaintiff suffered disparate treatment by his supervisors, which was motivated by Plaintiff’s
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`national origin.
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`27. Plaintiff suffered adverse employment action by way of termination of employment.
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`28. Defendant’s decision to terminate Plaintiff was motivated by his national origin.
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`29. As such, Defendant’s actions are unlawful employment practices under Title VII.
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`30. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`31. As a result of Defendant’s malicious or reckless indifference to Plaintiff’s rights, Plaintiff
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`demands punitive damages.
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`32. Pursuant to Title VII, Plaintiff demands attorneys’ fees and costs.
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`Page 4 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 5 of 10
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`Count II
`Discrimination and Wrongful Termination Based on Disability
`in Violation of the ADA
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`33. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`34. At all times material hereto, Plaintiff suffered from a medical condition that caused him to
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`bleed when he sits and required a colonoscopy and, as such, is a member of a class protected by
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`the ADA, i.e. having a disability.
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`35. Plaintiff suffered adverse employment action by way of termination of employment.
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`36. Defendant’s decision to terminate Plaintiff was motivated by his disability.
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`37. As such, Defendant’s actions are unlawful employment practices under the ADA.
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`38. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`39. As a result of Defendant’s malicious or reckless indifference to Plaintiff’s rights, Plaintiff
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`demands liquidated damages.
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`40. Pursuant to the ADA, Plaintiff demands attorneys’ fees and costs.
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`Count III
`Discrimination and Wrongful Termination Based on National
`Origin in Violation of the PHRA
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`41. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`Page 5 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 6 of 10
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`42. Plaintiff is Nigerian and, as such, is a member of a class protected by the PHRA, i.e.
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`national origin.
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`43. At all times material hereto, Plaintiff is a “person” and “individual” as such terms are
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`defined pursuant to the PHRA.
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`44. At all times material hereto, Defendant is an “employer” of Plaintiff as such term is defined
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`pursuant to the PHRA.
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`45. Plaintiff suffered disparate treatment by his supervisors, which was motivated by Plaintiff’s
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`national origin.
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`46. Plaintiff suffered adverse employment action by way of termination of employment.
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`47. Defendant’s decision to terminate Plaintiff was motivated by his national origin.
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`48. As such, Defendant’s actions are unlawful employment practices under the PHRA.
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`49. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`50. Pursuant to the PHRA, Plaintiff demands attorneys’ fees and costs.
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`Count IV
`Discrimination and Wrongful Termination Based on Disability
`in Violation of the PHRA
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`51. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`Page 6 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 7 of 10
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`52. At all times material hereto, Plaintiff suffered from a medical condition that caused him to
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`bleed when he sits and required a colonoscopy and, as such, is a member of a class protected by
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`the PHRA, i.e. having a disability.
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`53. At all times material hereto, Plaintiff is a “person” and “individual” as such terms are
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`defined pursuant to the PHRA.
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`54. At all times material hereto, Defendant is an “employer” of Plaintiff as such term is defined
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`pursuant to the PHRA.
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`55. Plaintiff suffered adverse employment action by way of termination of employment.
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`56. Defendant’s decision to terminate Plaintiff was motivated by his disability.
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`57. As such, Defendant’s actions are unlawful employment practices under the PHRA.
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`58. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`59. Pursuant to the PHRA, Plaintiff demands attorneys’ fees and costs.
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`Count V
`Failure to Accommodate Disability in Violation of the ADA
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`60. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`61. At all times material hereto, Plaintiff suffered from a medical condition that caused him to
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`bleed when he sits and required a colonoscopy and, as such, is a member of a class protected by
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`the ADA, i.e. having a disability.
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`Page 7 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 8 of 10
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`62. Plaintiff requested a leave of absence of one day to accommodate his need to have a
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`colonoscopy.
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`63. A one day leave of absence was reasonable and would not have caused an undue burden
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`upon Defendant’s business.
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`64. Defendant did not permit Plaintiff to take a leave of absence, thereby failing to
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`accommodate his disability.
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`65. Defendant terminated Plaintiff’s employment.
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`66. As such, Defendant’s actions are unlawful employment practices under the ADA.
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`67. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`68. As a result of Defendant’s malicious or reckless indifference to Plaintiff’s rights, Plaintiff
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`demands liquidated damages.
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`69. Pursuant to the ADA, Plaintiff demands attorneys’ fees and costs.
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`Count VI
`Failure to Accommodate Disability in Violation of the PHRA
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`70. By way of reference, Plaintiff repeats and incorporates each and every foregoing paragraph
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`as if fully set forth herein.
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`71. At all times material hereto, Plaintiff suffered from a medical condition that caused him to
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`bleed when he sits and required a colonoscopy and, as such, is a member of a class protected by
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`the PHRA, i.e. having a disability.
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`Page 8 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 9 of 10
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`72. Plaintiff requested a leave of absence of one day to accommodate his need to have a
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`colonoscopy done.
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`73. A one day leave of absence was reasonable and would not have caused an undue burden
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`upon Defendant’s business.
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`74. Defendant did not permit Plaintiff to take a leave of absence, thereby failing to
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`accommodate his disability.
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`75. Defendant terminated Plaintiff’s employment.
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`76. As such, Defendant’s actions are unlawful employment practices under the PHRA.
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`77. As a proximate result of Defendant’s conduct, Plaintiff sustained significant damages,
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`including, but not limited to: great economic loss, future lost earning capacity, lost opportunity,
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`loss of future wages, loss of front pay, loss of back pay, as well as emotional distress, mental
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`anguish, humiliation, pain and suffering, consequential damages, and Plaintiff has also sustained
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`work loss, loss of opportunity, and a permanent diminution of earning power and capacity and a
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`claim is made therefore.
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`78. Pursuant to the PHRA, Plaintiff demands attorneys’ fees and costs.
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`RELIEF REQUESTED
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`WHEREFORE, Plaintiff, Ige Isijola, demands judgment in his favor against Defendant,
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`Pharmaceutical Research Associates, Inc., in an amount in excess of $75,000.00 together with:
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`A. Compensatory damages, including but not limited to: back pay, front pay, past lost
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`wages, future lost wages, lost pay increases, lost pay incentives, lost opportunity, lost
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`benefits, lost future earning capacity, injury to reputation, mental and emotional
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`distress, pain and suffering;
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`B. Punitive damages;
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`Page 9 of 10
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`Case 2:22-cv-00040 Document 1 Filed 01/06/22 Page 10 of 10
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`C. Attorneys’ fees and costs of suit;
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`D. Interest, delay damages; and
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`E. Any other further relief this Court deems just, proper, and equitable.
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`Respectfully Submitted,
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`Law Offices of Eric A. Shore, P.C.
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`/s/ Yvette C. Cave
`By: Yvette C. Cave, Esq. (PA # 329607)
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`600 North Jackson Street, Suite 201
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`Media, Pennsylvania 19063
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`T: (610) 355-1999
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`F: (215) 944-6124
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`E: YvetteC@EricShore.com
`Attorneys for Plaintiff, Ige Isijola
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`Dated: January 06, 2022
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`Page 10 of 10
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