AL'JIHAD : MESSENGERS (Angels & Devil) IN THE SKY (Captured Picture) AL'JIHAD Seventh Edition - Coker College copy - Page 408
45. Plaintiff was still in the care of Dr. Seitz during the dates on 06/28/04 (See Binder –
II, Exhibit – I, Page 10). And further dates Plaintiff was continuing under the car of
Dr. Seitz during 10/07/04, 10/11/2004, 10/18/04, and a date in January/February. Dr.
Seitz has concluded that Imam Mahdi has permanent damages due to the initial
accident on May 29, 2001 at L‘Oreal USA Products Inc. Imam Mahdi rights have
been violated Pain and Suffering and Wrongful Discharge by Defendant (Binder – II,
Exhibit – I, Pages 15 to 20). Defendant is in violation of Title I of the Americans
with Disabilities Act. Defendant rejects medical statement Two of Fifth Claim; see
Exhibit - D and E for proof of injury at L’Oreal USA Inc. and surgery by Dr. Seitz.
(See Exhibit – A, Section Five For Starting Details).
46. (Fed. R. Civ. P. of Emp P § 51:6 Harassment based on disability: The Americans
with Disabilities Act (ADA) allows employees to sue their employers if they are
harassed because of their disabilities.
Employers have an affirmative duty to
maintain a workplace free of harassment, but are not strictly liable for harassment.
Liability depends on the nature and extent of the employer’s preventive and remedial
measures, and in some cases, on its awareness of the offensive conduct. Whether an
employer is liable in a particular case depends on all of the circumstances
surrounding the claim. Many courts have proceeded on the assumption that the ADA
creates a cause of action for a hostile work environment, …”
47. Fed. R. Civ. P. of Emp. P. § 2:8 Federal Civil Rights and Employment
Discrimination Laws; Statutory Overview For a private employer, the most
significant of the host of federal civil rights laws and regulations are (1) Title VII of
the Civil Rights Act of 1964, as amended in 1972 and by the Civil Rights Act of
1991, therefore, which prohibits discrimination on the basis of race, color, religion,
“AL’JIHAD”– by, Imam Mahdi
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