(¶¶ 112- 117.) Count III alleges age discrimination in violation of the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. §621 et seq. (¶¶ 118-127).

¶ 11.) Specifically, Plaintiff claims that she was subjected to gender, disability and age discrimination and retaliated against for engaging in protected activity in violation of Title VII of the Civil Rights Act of 1964 (“Title VII”), the Americans with Disabilities Act (42 U.S.C. § 12101 et seq. (“ADA”), the Age Discrimination in Employment Act, 29 U.S.C. § 621 et. seq. (“ADEA”), the Equal Pay Act, 29 U.S.C. § 206(d) et seq., the Family Medical Leave Act 29 U.S. Code § 2601 (“FMLA”) and the Pennsylvania Human Relations Act, 43 P.S. §§ 951-963 (“PHRA”).

On October 18, 2004, plaintiff Robert Creasy commenced this action in the Middle District of Pennsylvania. The complaint alleges that Creasy's employment was wrongfully terminated by defendant Novelty, Inc. (“Novelty”), in violation of the Age Discrimination in Employment Act, 29 U.S.C. § 621 (“ADEA”), the Americans with Disabilities Act, 42 U.S.C. §§ 12101-12213 (“ADA”), and the Pennsylvania Human Relations Act, 43 Pa.C.S.A. §§ 951-63. Plaintiff alleges that he was discharged from his job because of his age, fifty-five, and because of a physical impairment, sleep apnea.

6. Plaintiff’s claim for violation of the Gender Discrimination in Employment Act, 29 U.S.C. §§621-34 (Complaint, Sixth Cause of Action) should be dismissed for Case 1:16-cv-00576-NCT-LPA Document 17 Filed 10/13/16 Page 2 of 5 failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b) (6). 7.

218. As set forth more fully above, Accenture has utilized practices, policies and procedures that have disparately impacted the above named Plaintiffs and other similarly situated present and former employees of Accenture in the IT department and other departments or units, resulting in an unlawful pattern or practice of age discrimination in violation of the ADEA, 29 U.S.C. § 621, et seq. 219.

Gov’t Code § 12940 (“FEHA”). The Complaint also asserted non-class claims of age discrimination on behalf of Ms. Jaffe individually under the Age Discrimination in Employment Act of 1967, 29 U.S.C. § 621, et seq. and under California’s FEHA. (Complaint at ¶¶ 51-58.)

Such claims by Richard, where the decision to not give him a raise occurred prior to January 29, 2009, would likewise be barred. III. Conclusion GE prays that this court grants its motion and dismisses the following of Richard’s claims: state law race and age discrimination claims under La. R.S. 23:301, et seq., race discrimination claim under 42 U.S.C. §1981; Title VII race discrimination and retaliation claims arising before January 29, 2009, under 42 U.S.C. §2000e, et seq., and Richard’s alternative a claim of age discrimination under the Age Discrimination in Employment Act, 29 U.S.C. §621, et seq. Respectfully submitted: OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. /s/ Andrew J. Halverson Gregory Guidry, T.A., La. Bar No. 06489 Andrew J. Halverson, La. Bar.

Defendants. DEFENDANT’S MEMORDUM OF LAW IN SUPPORT OF ITS MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION Defendant Association of Classified Employees/American Federation of State, County and Municipal Employees Local 2250 (AFL-CIO)(“Union” or “Local 2250”), by and through its undersigned counsel, hereby submits this memorandum of law in support of its motion to dismiss Plaintiff’s claim under the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621, et seq., because this Court lacks subject matter jurisdiction. For the reasons discussed below, Plaintiff cannot establish that the Union satisfies the definition of “employer” under the ADEA.

On September 6, 2016, the EEOC issued a Notice of Right to Sue. Then, on October 3, 2016, Plaintiff filed his Complaint in the this Court alleging various claims for unlawful discrimination and retaliation arising under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq. (“Title VII”), the Civil Rights Act of 1866, 42 U.S.C. § 1981 (“Section 1981”), the Pennsylvania Human Relations Act, 43 P.S. § 951, et seq. (the “PHRA), and presumably, although not specifically cited, the Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq. (“ADEA”). More specifically, the Complaint contained three causes of action for (i) national origin discrimination, (ii) age discrimination, and (iii) retaliation.

v. ) ) 1:16-cv-00920-LMM-LTW INTERDENOMINATIONAL ) THEOLOGICAL CENTER, INC., ) ) Defendant. ) ) DEFENDANT INTERDENOMINATIONAL THEOLOGICAL CENTER, INC.’S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT Plaintiff Betty R. Jones (“Plaintiff”) alleges that the Interdenominational Theological Center, Inc. (“ITC”) discriminated and retaliated against her unlawfully in violation of the Age Discrimination in Employment Act of 1967, as amended, 29 U.S.C. §§ 621 et seq. (the “ADEA”), and Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq. (“Title VII”). Plaintiff also alleges that ITC breached the parties’ purported employment agreement.