AL'JIHAD : MESSENGERS (Angels & Devil) IN THE SKY (Captured Picture) AL'JIHAD Seventh Edition - Coker College copy - Page 403
30. IMAM H. S. MAHDI incorporate the allegation of Retaliation by Defendant. On
July 8, 2002, I, Imam Mahdi, filed a previous charge of discrimination with EEOC
(charge number 220A201149), based on Imam Mahdi religion and disability.
Plaintiff need to see EEOC for Documentation, but Plaintiff did file these Charges.
31. Defendant in an effort to discomfort Imam Mahdi, Defendant moved Imam Mahdi
to a location on July 25, 2002 to August 14,2002 to perform duties in a high chemical
area. The chemicals caused Imam Mahdi to receive headaches, which I complained
Defendant rejects the fact of statement Two of Third Claim; see
Exhibit - G of Chemical harassment for proof by Plaintiff.
32. Defendant on August 14, 2002, called Imam Mahdi into the office of Lou Boyd,
Human Resource Manager.
Mr. Boyd interrogated Imam Mahdi by saying that he
returned to work and entered the building on August 8, 2002 between the hours of
1:00 a.m. to 2:00 a.m. The only time Imam was in the building during those hour was
when Imam Mahdi was working third shift over a year ago prior to August 8, 2002.
Shortly after, Imam Mahdi was told to see the nurse. When Imam Mahdi arrived, Mr.
Boyd was present. We discussed medical issues and I, Imam Mahdi, was told to go
home to be on medical leave. Defendant rejects the fact of statement Three of Third
Claim; see Exhibit - B of proof in retaliation by Lou Boyd on page 8 for proof by
33. Defendant retaliated against Imam Mahdi for filing the previous charges in violation
of Title VII of the Civil Rights Act of 1964, as amended; and Title I of the Americans
with Disabilities Act of 1967. Defendant rejects the fact of statement Four of Third
“AL’JIHAD”– by, Imam Mahdi
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