Taken from “SUMMARY OF ARGUMENTS - DEFENDANT JPMORGAN CHASE & CO.” of my Memorandum of Law in Opposition to Defendants JPMorgan Chase & Co., et al’s Motion for Summary Judgment
The culture of employment racial discrimination against Blacks at JPMorgan Chase is not only alive and well but it is widespread, ratified, condoned and common among the people with the influence to prevent or stop it but instead choose to keep it alive.
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when Defendant Alex Khavin who is an Executive Director and Head of the Counterparty Risk Group for Global Investment Management as well as an appointed culture ambassador for the company, blatantly discriminated against me by way of disparate treatment on the basis of my race (click here to see my Affidavit in Opposition/Response to “Declaration of Alex Khavin”).
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when John Donnelly, the Global Head of JPMorgan Chase’s Human Resources Department, Defendant Philippe Quix, the Global Investment Management Chief Risk Officer/Managing Director/Defendant Alex Khavin’s direct manager, Defendant Thomas Poz, an Executive Director who replaced Khavin as the Head of the Counterparty Risk Group for Global Investment Management and who was also appointed a “culture ambassador”, Defendant Helen Dubowy, an Executive Director and HR Business Partner and Defendant John Vega, the HR representative who was an Executive Director and the person to whom my employment racial discrimination claim was escalated for an “investigation” not only failed to stop or to prevent the employment racial discrimination against Blacks against me but John Donnelly and Defendant Philippe Quix ignored my indirect plea for help while Defendants Thomas Poz, Helen Dubowy and John Vega aided, abetted and enforced it.
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself as explicitly outlined in my Sixth and Tenth Causes of Action when in the Global Commodities Group – Energy Confirmations Department in which I previously worked, I became a victim of Intentional Infliction of Career Regression And Career Stagnation and stereotypical Defamation of Character on the basis of my race at the hands of my then managers, Defendants Liasis and Sullivan (click here to see my Affidavit in Opposition/Response to “Declaration of Chris Liasis” and click here to see my Affidavit in Opposition/Response to “Declaration of Michelle Sullivan”).
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when after taking a peaceful stance against disparate and discriminatory treatment against me for being racially assigned unessential tasks which did not benefit the Counterparty Risk Group or the company as a whole but only served the purpose of me, being the only Black analyst on the team, to be the help or the house slave for the non-Black employees on the team, reminiscent of the era of slavery, I was severely punished by way of a poor performance review and put on a retaliatory and pretextual “performance improvement plan”, I was given a written warning, both of which barred me from accessing the company’s progressive benefits and I was ultimately terminated on January 6, 2016. While, a White counterpart who right-out refused to do essential tasks was not given these said severe punishments but instead, he got promoted (“Affidavit in Opposition/Response to ‘Declaration of Helen Dubowy’ – Docket # 96” - “Response to Helen Dubowy Exhibit C” - “Recommendation for Termination” and ¶ 69 – Am. Compl.).
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when Black employees at the company have to make the choice to relegate themselves to being a conduit (“horizontal racist”) for the racial discrimination being perpetrated by their racist managers against other Black employees in order for them to secure or grow their own careers in the company as is in the case of Defendant Fidelia Shillingford (¶ 30 – Am. Compl. and Exhibit QQ - Corporate Careerist Blacks).
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when JPMorgan Chase without hesitation or shame is providing legal representation for each of the alleged perpetrators/tortfeasors named as Defendants in this lawsuit. This noteworthy action by JPMorgan Chase, in and of itself, cements the fact that the company ratifies and condones employment racial discrimination against its Black employees.
The culture of employment racial discrimination against Blacks at JPMorgan Chase is alive and well and speaks for itself when on January 20, 2017 JPMorgan Chase had to settle a class action lawsuit brought against them by the United States of America for racial discrimination in mortgage lending (1:17-CV-00347).
The foregoing demonstrates the widespread culture of Employment Racial Discrimination among all levels of management and across departments at JPMorgan Chase. The unlawful acts of Employment Racial Discrimination and the culture at JPMorgan Chase that festers it are not only despicable, willful, malicious, callous, rancorous and oppressive but they 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.