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My Story In the case of Lue v. JPMorgan Chase & Co. et al (U.S. Supreme Court: Case # 19-260) |
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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.
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Excerpt from “INTRODUCTION” of my Memorandum of Law in Opposition to Defendants JPMorgan Chase & Co., et al’s Motion for Summary Judgment
For eight (8) straight months prior to filing a Charge with the Equal Employment Opportunity Commission (EEOC) against JPMorgan Chase & Co., all I asked of the said company and its managers was not to treat me as a second class citizen/three-fifths of a person/the help/the house slave. As the only Black Analyst in the Counterparty Risk Group, reminiscent of the 1800s plantation style living, in the era of slavery when Blacks had to serve their masters and their masters’ families, Defendant Alex Khavin who was an Executive Director and Head of the said Counterparty Risk Group for Global Investment Management at JPMorgan Chase & Co. disparately treated me as if I was a second class citizen/three-fifths of a person and/or the help/house slave for the non-Black members of the group in violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. (Affidavit in Opposition/Response to Declaration of Alex Khavin – Response to Declaration Statement #s 12, 13 & 14) Khavin solely assigned me the task of taking the minutes for the Monthly Governance Meetings (a task which was so undesirable that Khavin made it rotational among all the non-Black analysts and associates before I joined the team as I was informed in my interview and per Kimberly Dauber’s email dated February 4, 2015 – Exhibit B) and the tasks of printing 13 copies of each of the non-Black team member’s presentation materials (one copy for each member of the team), collating, stapling and lugging of the said presentation materials to the monthly team meetings where the said non-Black team members, including the ones on my job level, will be waiting to “be served” (tasks which never existed before I joined the team). These said tasks were not even assigned to the White administrative assistant on the team to do even though these are tasks that would more likely fall into the administrative assistant job category. As a matter of fact, the said White administrative assistant was not even as much as assigned the task to print the meeting agenda she prepared and sent out via email to the team for the said monthly team meeting (Exhibit K). But, along with all the presentation materials I was assigned to print for the non-Black members of the team, the task of printing a copy of the Governance Meeting agenda for each of the said non-Black members of the team was also assigned to me, an analyst, to do. Reminiscent of the devious ways in which Black voters were treated to frustrate them and to prevent them from using their voting privilege before the 1965 Voting Rights Act was passed, unlike the non-Black analysts in the Counterparty Risk Group, headed by Khavin, who could use their work from home privilege by just sending an email to the team saying, “I am not feeling too well today so I will be working from home” or something of that nature (Exhibit L), Khavin’s directive through Defendant Fidelia Shillingford (who is Black and a servile employee of Alex Khavin) for me was that I had to send an email to Shillingford detailing my situation and ask for permission to work from home (permission which would have to come from Khavin herself) and she, Shillingford would communicate accordingly to the team (Exhibit L-1 - JPMorgan Chase 000665). Even though Shillingford, who is Black and who Khavin used as a conduit and a cover to enforce her racial discrimination against Blacks, against me, knew that I was being treated at a double standard by Khavin, as a servile employee to Khavin, Shillingford still enforced Khavin’s racial discrimination and disparate treatment against me. It was during the aforesaid eight months prior to me reporting the matter of Employment Racial Discrimination and Retaliation against me to the Equal Employment Opportunity Commission (EEOC) that I began to realize how I had been naïvely dismissing circumstances consistent with the culture of racial bias against Blacks at JPMorgan Chase. It was during those said eight (8) months that I began to realize that it was on the basis of my race that while working in JPMorgan Chase’s Global Commodities Group – Energy Confirmations Department for two years prior (that business was sold by JPMorgan Chase), my career was intentionally regressed and stagnated by my two bigoted managers, Defendants Liasis and Sullivan. It never mattered what I did to exceed my work expectation as I explicitly outlined in my Sixth Cause of Action, Liasis and Sullivan would never give me a performance rating above “Meets Expectation (M)”. And, to even be considered for a promotion, a JPMorgan Chase employee needs to have at least a “Meets Expectation Plus (M+)” performance rating (Exhibit H-3, Exhibit QQ – “Black Workers Really Do Need to Be Twice as Good” and Exhibit QQ-1). See more in my “Affidavit in Opposition/Response to Declaration of Chris Liasis” and “Affidavit in Opposition/Response to Declaration of Michelle Sullivan”. As outlined in Paragraphs 2, 15, 137 and 138 of my Amended Complaint, I took all the measures necessary to openly mitigate the damages that the Defendants caused me, but to no avail. I continuously raised the issue of racial discrimination against me both verbally and via email to the Defendants and/or employees in positions to rectify this unlawful matter but it was never rectified but only ignored, aided, abetted, enforced, shooed away, dismissed and/or ridiculed by these said Defendants and/or employees (Exhibits CC and CC-1). Instead, I was retaliated against by way of a pretextual performance review and placed on a fallacious “performance improvement plan” followed by a written warning and ultimately my termination on January 6, 2016.
SEPARATELY - A word to the Black employees at JPMorgan Chase and other major financial institutions Enough of the “prestige” it adds to a Black JPMorgan Chase & Co. employee to say that: “I work in the whatever Department at JPMorgan Chase’s Park Avenue location” when working in this said department and at that said location, you are treated as a second class citizen/the help/the house slave for the non-Black members of your team.
Stop telling LIES to cover for racist managers while being a horizontal racist against a member of your own race just to secure your job at the said “prestigious” company (click here to read the BLATANT LIES under Penalty of Perjury in the Declaration of Fidelia Shillingford, who is Black, here to read the “Declaration”/BLATANT LIES under Penalty of Perjury of the racist, Alex Khavin Shillingford was covering for then here to read my Affidavit in Opposition/Response to Declaration of Fidelia Shillingford and here for my Affidavit in Opposition/Response to Declaration of Alex Khavin BLATANT LIES).
Stop suffering in silence knowing that for years you have not gotten a raise and the “annual bonus” that this multi-billion dollar company, JPMorgan Chase and Co. gives you is an insult after umpteen years of service and hard work. Stop smiling when you are really hurting inside to know that you are working with the company for years and the only level you have reached is the “Associate” level when after two years White employees are looking forward to advancing to the “Vice President” level.
Stop being a “careerist Black” whereby the only way to advance in the company as a Black employee is you “must be twice as good at all the other things that make the white collar world, such as twice as much of a backstabber, twice as servile to people in positions of power and twice as hard on black folks in proving [your] allegiance to the basic tenets of white supremacy” - credit to “BreakingBrown.com - Corporate Careerist Blacks”. |
