Defendant Philippe Quix

In the case of Lue v. JPMorgan Chase & Co. et al (U.S. Supreme Court: Case # 19-260)

Defendants Declarations aka LIES under Penalty of Perjury | THE TRUTH | THE EVIDENCE | SHOP CandiceLue®

Taken from “SUMMARY OF ARGUMENTS - DEFENDANT PHILIPPE QUIX” of my Memorandum of Law in Opposition to Defendants JPMorgan Chase & Co., et al’s Motion for Summary Judgment

Quix, whose position at JPMorgan Chase was Global Investment Management Chief Risk Officer/Managing Director, failed to take steps to prevent the employment racial discrimination, retaliation and harassment in Violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981 that were being perpetrated against me.

Quix, who was Khavin’s direct manager became aware of my employment racial discrimination complaint when I copied him on an email trail dated May 27, 2015 (EXHIBIT B - RE: Monthly CRG Governance Meeting included in my Amended Complaint) in which I complained about the unfairness and the demeaning nature of Khavin treating me as the team’s help obviously on the basis of my race. That particular email stated, “In the interest of team spirit, can you please print, sort, organize and staple as well as send out your own presentation materials to the team? I find it unfair and demeaning that the task of printing, sorting, organizing, stapling, sending out and lugging YOUR presentation materials to the meetings is placed on me.” In the other email on which Quix was copied, I reminded Khavin that in the April 24, 2015 meeting that I had with her about her racially assigning demeaning tasks solely to me, I rhetorically asked “Am I the help? Is this 1910”. And, with the issue of employment racial discrimination so obviously evident, I was literally ignored by Quix. Not only by him not responding in anyway to the emails on which I copied him but also in passing or as a member of the Counterparty Risk Group.

The failure and negligence of Quix, who in his senior level position, had the authority to take corrective actions against employment racial discrimination or to at least exercise some curiosity about it, showed that disparate treatment against Blacks is condoned and ratified by JPMorgan Chase and its senior level managers.

The disparate treatment of me being subjected to be treated as the house slave reminiscent of the 1800s era of slavery that I endured at the hands of Defendants, Khavin and Shillingford, of whom Quix was their direct manager and skip level manager, respectively, and Quix’s failure and negligence to take steps to prevent the employment racial discrimination, retaliation and harassment that were being perpetrated against me, at times caused me to become overwhelmed with stress and anxiety which resulted in physical pain. It was difficult to pass Quix in the hallways as, with him totally ignoring my emails, my obvious cries to him for help, I felt like he thought of me as being less of a person. I felt shamed.

Quix was aware of my due diligence and the integrity of the work that I was able to produce especially as it related to tackling data quality issues. These were issues that I bravely highlighted to Quix in the first one to one meeting I had with him in March 2015 when I was less than 6 months on the job and even more so in a meeting on November 17, 2015 which occurred due to the fact that the data quality issues that I had brought to light, needed escalated attention. My findings as it related to the data quality issues were of such concern that after this meeting, Quix had to schedule subsequent meetings with other senior level managers to address the issue.

With that said, any involvement that Quix had in my termination on January 6, 2016 from JPMorgan Chase would have to be in retaliation of me raising claims of employment racial discrimination against me to HR and me reporting the said claims to the Equal Employment Opportunity Commission (EEOC) and not due to “performance issues”. It should be interesting to note that on January 6, 2016, within half an hour of receiving an email from Quix addressed to all the employees in Asset Management – Risk Management naming a replacement for Khavin as Head of the Counterparty Risk Group for Global Investment Management, I was called away from doing my work and told that I was terminated. Then, under careful supervision, I went back to my desk, logged out of the applications and closed out of the files in which I was working, gathered my belongings then I was escorted out of JPMorgan Chase.

Quix, who was in a position to take corrective actions against the employment racial discrimination that was being perpetrated against me by his direct report and his skip level report but was negligent and failed to do so show that he ratified and condoned the said employment racial discrimination that was perpetrated against me. These acts of employment racial discrimination were despicable, willful, malicious, callous, rancorous and oppressive. They also violated my civil rights and my constitutional rights pursuant to Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981.

Lue v. JPMorgan Chase & Co. et al (1:16-CV-03207)

Harriet Tubman, Rosa Parks, Dr. Martin Luther King, Jr., Nelson Mandela, Bob Marley, Marcus Garvey and so many others “paid it forward” for me. Hopefully, I will be able to “pay it forward” for others.