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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA

ROCK HILL DIVISION

EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,



Plaintiff,

v.

EAGLE ALLOYS, INC. d/b/a
AMERICAN EAGLE WHEEL and
AMERICAN EAGLE WHEEL
CORPORATION,

______________________________________

Defendants.

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CIVIL ACTION NO.

COMPLAINT

JURY TRIAL DEMAND

NATURE OF THE ACTION

This is an action under Title VII of the Civil Rights Act of 1964, as amended, and Title I

of the Civil Rights Act of 1991, to correct unlawful employment practices on the basis of

retaliation, and to provide appropriate relief to Angelita Sanchez, who was adversely affected by

such practices. Specifically, Plaintiff, the United States Equal Employment Opportunity

Commission, alleges Defendants Eagle Alloys, Inc. d/b/a American Eagle Wheel and American

Eagle Wheel Corporation discharged Angelita Sanchez in retaliation for opposing a practice

which she reasonably believed was a violation of Title VII and for otherwise engaging in

protected activity.



JURISDICTION AND VENUE

1.

Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451, 1331, 1337,

1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of

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Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(1) and (3) ("Title

VII") and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.

2.

The employment practices alleged to be unlawful were committed within the

jurisdiction of the United States District Court for the District of South Carolina, Rock Hill

Division. The lawsuit is being filed in the Rock Hill Division because a substantial part of the

events or omissions giving rise to the claims alleged in this suit occurred within the Rock Hill

Division.

PARTIES

3.

Plaintiff Equal Employment Opportunity Commission (“the Commission”) is the

agency of the United States of America charged with the administration, interpretation and

enforcement of Title VII of the Civil Rights Act and is expressly authorized to bring this action

by Sections 706(f)(1) and (3) of Title VII, 42 U.S.C. § 2000e-5(f)(1) and (3).

4.

At all relevant times, Defendant Eagle Alloys, Inc. has continuously been a South

Carolina corporation doing business in the State of South Carolina and the City of York, and has

continuously had at least 15 employees.

5.

At all relevant times, Defendant Eagle Alloys, Inc. has continuously been an

employer engaged in an industry affecting commerce under Sections 701 (b), (g) and (h) of Title

VII, 42 U.S.C. §§ 2000e(b), (g) and (h).

6.

At all relevant times, Defendant American Eagle Wheel Corporation has

continuously been a California corporation doing business in the State of South Carolina and the

City of York, and has continuously had at least 15 employees.

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7.

At all relevant times, Defendant American Eagle Wheel Corporation has

continuously been an employer engaged in an industry affecting commerce under Sections 701

(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).

8.

On information and belief, at all relevant times Defendants Eagle Alloys, Inc. and

American Eagle Wheel Corporation have operated as an integrated business enterprise, or in the

alternative as joint employers.

STATEMENT OF CLAIMS

9.

More than thirty days prior to the institution of this lawsuit, Angelita Sanchez

filed a charge of discrimination with the Commission alleging violations of Title VII by

Defendants. All conditions precedent to the institution of this lawsuit have been fulfilled.

10.

Since at least April 18, 2005, Defendants engaged in unlawful employment

practices in violation of Section 704(a) of Title VII, 42 U.S.C. §2000e-3(a), by discharging

Angelita Sanchez in retaliation for her opposition to practices she reasonably believed to be

declared unlawful by Title VII.

11.

The effect of the practices complained of in paragraph 10 above has been to

deprive Angelita Sanchez of equal employment opportunities and otherwise adversely affect her

status as an employee because of her opposition to employment practices that she reasonably

believed to be declared unlawful by Title VII.

12.

The unlawful employment practices complained of in paragraph 10 above were

intentional.

13.

The unlawful employment practices complained of in paragraph 10 above were

done with malice or with reckless indifference to the federally protected rights of Angelita

Sanchez.

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PRAYER FOR RELIEF

Wherefore, the Commission respectfully requests that this Court:

A.

Grant a permanent injunction enjoining Defendants, their officers, successors,

assigns, and all persons in active concert or participation with them, from discriminating against

current or former employees based on their opposition to unlawful employment practices or

employment practices which the employee reasonably believes to be declared unlawful by any

statute enforced by the Commission.

B. Order Defendants to make Angelita Sanchez whole by providing appropriate back

pay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief

necessary to eradicate the effects of the unlawful employment practices described in paragraph

10 above, including but not limited to reinstatement of Ms. Sanchez or an award of front pay.

C.

Order Defendants to make Angelita Sanchez whole by providing compensation

for past and future pecuniary losses resulting from the unlawful employment practices described

in paragraph 10 above, including but not limited to job search expenses, in amounts to be

determined at trial.

D.

Order Defendants to make Angelita Sanchez whole by providing compensation

for past and future non-pecuniary losses resulting from the unlawful employment practices

complained of in paragraph 10 above, including but not limited to emotional distress,

inconvenience, loss of enjoyment of life, humiliation, and loss of civil rights, in amounts to be

determined at trial.

E.

Order Defendants to pay Angelita Sanchez punitive damages for their malicious

and reckless conduct described in paragraph 10 above, in amounts to be determined at trial.

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F.

Grant such further relief as the Court deems necessary and proper in the public

interest.

G.

Award the Commission its costs of this action.

JURY TRIAL DEMAND

The Commission requests a jury trial on all questions of fact raised by its complaint.

DATED this 29th day of September 2006.

Respectfully submitted,

RONALD S. COOPER
General Counsel

JAMES L. LEE
Deputy General Counsel

GWENDOLYN YOUNG REAMS
Associate General Counsel
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
1801 L Street, N.W.
Washington, D.C. 20507

LYNETTE A. BARNES
Regional Attorney

TINA BURNSIDE
Supervisory Trial Attorney

KARA L. GIBBON HADEN
Senior Trial Attorney

/s/ Mary M. Ryerse
MARY M. RYERSE (Federal Bar No. 9604)
Trial Attorney
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
Charlotte District Office
129 W. Trade Street, Suite 400
Charlotte, NC 28202
Telephone: 704.344.6886
704.344.6780
Facsimile:
E-mail:
[email protected]

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