AL'JIHAD : MESSENGERS (Angels & Devil) IN THE SKY (Captured Picture) AL'JIHAD Seventh Edition - Coker College copy - Page 397
insubordination. Even though Defendant has a progressive disciplinary policy –
Defendant fail to initiate their polices, instead Defendant acted out of bad-faith
in Discriminatory Practices by Wrongfully Termination (Discharged) of Plaintiff
– Imam Mahdi for refusing to violate Defendant rules and policies (See Binder –
I, Exhibit – A, Section Four).
22. Defendant rejects the fact of their policies in L’Oreal USA - Solon Manufacturing
Guideline Manual on pages 16 to 19 -- and See National Liftor -- The Lift Truck
Operator Registry manual on page 13 for violation of pallet movement.
23. L'Oreal is without knowledge or information sufficient to form a belief as to the truth
of the allegations contained in paragraph 3 of the Complaint and therefore denies the
24. Plaintiff, Imam H. S. Mahdi (Pro Se), present proof and/or evidence that Defendant
and/or L’Oreal USA, Inc. are with knowledge or information sufficient to form a
belief as to the truth of the allegations contained in paragraph 3 of the Complaint,
therefore Defendant seek to position or cause the UNITED STATES DISTRICT
COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION to practice
obstruct the court in the administration of justice (see all of Exhibit – A).
a. Defendant’s retaliation was due to previous charges that I, Imam Mahdi, had
filed with EEOC in relations to Religion (Sabbath), Retaliation, Religion
(Harassment), and Disability. The Defendant has violated Title VII of the
Employment Act, Title VII of the Civil Rights Act of 1964, and Title I of the
Americans with Disabilities Act of 1964, all as amended.
“AL’JIHAD”– by, Imam Mahdi
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