WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP are a HORRIBLE company!!!

9.At all times relevant, Plaintiff performed the responsibilities of a records clerk in an 2

exemplary manner. However, Plaintiff was subjected to a continuos and unrelenting pattern of harassment due to her national origin.

a.Ethnic slurs were uttered against plaintiff by her supervisors; 

b.Plaintiff was subjected to microscopic scrutiny by her supervisors; 

c.Biased counseling and discipline were given to Plaintiff; 

d.Plaintiff was constantly threatened with termination; 

e.Plaintiff was advised that she did not belong here, that she should look for

another job, and that she was a troublemaker; 

f.Plaintiff was assigned excessive work and given additional duties; 

g.Due to the excessive work given to her by Plaintiff, she requested help that

was unreasonably denied; 

h.Biased appraisals/evaluations were given to Plaintiff; 

i.Plaintiff was denied raises; 

j.Plaintiff was yelled at and screamed in front of coworkers; 

l.Plaintiff was humiliated by her supervisors in front of her coworkers; 

k.Plaintiff found saliva (spit) on her desk; this incident, despite plaintiff’s

complaints, was not investigated; 

m.Card keys were taken from Plaintiff’s desk, thus denying plaintiff access to

her pocket book, eventually the card keys were located face down in the

garbage; 

n.Other acts of on-going intentional discrimination;

10.Plaintiff complained about the foregoing conditions on numerous occasions to no avail. 

11.Plaintiff finally complained in writing and met with Mimi DeMaris, a Wilson Elser administrator. 

12.Before “the ink could dry” on plaintiff’s written complaint and (what seemed like a nano second after the meeting outlining the outrageous behavior) on the very next day, on July 8, 2009 plaintiff was terminated due to intentional national origin discrimination and retaliation for complaining about protected activity. 

13.The foregoing conduct was continuous, intentional, on-going pattern of discrimination that altered the term and conditions of plaintiff’s employment. 

14.The foregoing conduct was so severe and unrelenting that it was to the objective observer a discriminatory and retaliatory hostile work environment. 

15.The foregoing conduct was so severe and unrelenting that it was to Plaintiff a discriminatory and retaliatory hostile work environment. 

16.As a result of defendant violating the Executive Law, plaintiff has been damaged and the damage exceeds the minimum jurisdiction threshold of this Court.

Case 1:11-cv-01580-SASDocument 16Filed 04/25/11Page 1 of 6

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------X

SANDRA BAICHU,

v.

Plaintiff,

WILSON ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, AND GLC BUSINESS SERVICES, INC.,

Defendants. ---------------------------------------------------------------X

Plaintiff, SANDRA BAICHU, by her attorney, STEWART LEE KARLIN, ESQ., for his complaint herein alleges as follows:

1.At all times hereinafter mentioned, plaintiff SANDRA BAICHU (hereinafter “plaintiff or Ms. Baichu”) resides in Queens County, New York. 2.Upon information and belief, Defendant WILSON ELSER, MOSKOWITZ, EDELMAN & DICKER LLP (hereinafter Wilson Elser) is a limited liability partnership with its principal business offices located in the County of New York, State of New York. Upon information and belief, Defendant GLC BUSINESS SERVICES INC. (hereinafter GLC) is a corporation with its principal business offices located in the County of New York, State of New York.

3.Defendants violated New York State and New York City laws when they terminated plaintiff her on account of her national origin (Guyanese)and retaliation.

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Case 1:11-cv-01580-SASDocument 16Filed 04/25/11Page 2 of 6

4.At all times relevant, Defendants employ more than four individuals and is thus an employer within the meaning of the Executive Law § 292 (5). Both defendants are considered employers of Plaintiff since both controlled the day to day activities of plaintiff. 5.Defendant Wilson Elser is a joint employer of the plaintiff due to the fact that the defendant exerted control over the day to day activities of defendant to wit: The day to day activities operation was controlled by Mimi DeMars of Wilson Elser and GLC Records manager Kirk Douglas reported to Ms. Demars on a daily basis. Weekly meetings were held for the entire GLC managers as well. Also, copies of GLC employees attendance records were send to Ms. DeMars daily, and the work could not proceed without the consultation and approval of Ms. DeMars. If any issues arose, Plaintiff would go to Ms DeMars and she would assign Plaintiff projects. Ms. Demars would closely observe Plaintiff’s work performance and would do a daily walk through. Plaintiff’s termination was a direct result of Plaintiff’s complaints of discrimination to Ms. DeMars. (See paragraphs numbered “11", “12" and “13" see infra)

6.At all times relevant, Plaintiff was an employee and individual within the meaning of the Executive Law § 292 (1) and (6) and complained about national origin discrimination (protected activity). 7.Plaintiff became employed by Defendant Wilson Elser as a legal records clerk.

8.On or about February 4, 2008, Defendant Wilson Elser contracted with Defendant GLC to manage the records department. As a result, Defendant GLC hired plaintiff and she became directly employed by Defendant GLC but still remained working at Defendant Wilson Elser’s New York office.

9.At all times relevant, Plaintiff performed the responsibilities of a records clerk in an 2

Case 1:11-cv-01580-SASDocument 16Filed 04/25/11Page 3 of 6

exemplary manner. However, Plaintiff was subjected to a continuos and unrelenting pattern of harassment due to her national origin.

a.Ethnic slurs were uttered against plaintiff by her supervisors; b.Plaintiff was subjected to microscopic scrutiny by her supervisors; c.Biased counseling and discipline were given to Plaintiff; d.Plaintiff was constantly threatened with termination; e.Plaintiff was advised that she did not belong here, that she should look for

another job, and that she was a troublemaker; f.Plaintiff was assigned excessive work and given additional duties; g.Due to the excessive work given to her by Plaintiff, she requested help that

was unreasonably denied; h.Biased appraisals/evaluations were given to Plaintiff; i.Plaintiff was denied raises; j.Plaintiff was yelled at and screamed in front of coworkers; l.Plaintiff was humiliated by her supervisors in front of her coworkers; k.Plaintiff found saliva (spit) on her desk; this incident, despite plaintiff’s

complaints, was not investigated; m.Card keys were taken from Plaintiff’s desk, thus denying plaintiff access to

her pocket book, eventually the card keys were located face down in the

garbage; n.Other acts of on-going intentional discrimination;

10.Plaintiff complained about the foregoing conditions on numerous occasions to no avail. 3

Case 1:11-cv-01580-SASDocument 16Filed 04/25/11Page 4 of 6

11.Plaintiff finally complained in writing and met with Mimi DeMaris, a Wilson Elser administrator. 12.Before “the ink could dry” on plaintiff’s written complaint and (what seemed like a nano second after the meeting outlining the outrageous behavior) on the very next day, on July 8, 2009 plaintiff was terminated due to intentional national origin discrimination and retaliation for complaining about protected activity. 13.The foregoing conduct was continuous, intentional, on-going pattern of discrimination that altered the term and conditions of plaintiff’s employment. 14.The foregoing conduct was so severe and unrelenting that it was to the objective observer a discriminatory and retaliatory hostile work environment. 15.The foregoing conduct was so severe and unrelenting that it was to Plaintiff a discriminatory and retaliatory hostile work environment. 16.As a result of defendant violating the Executive Law, plaintiff has been damaged and the damage exceeds the minimum jurisdiction threshold of this Court.

17.Plaintiff repeats and realleges each and every allegation contained in paragraphs numbered “1” through “16” as if fully set forth at length herein. 18.This Court has jurisdiction pursuant to New York City Administrative Code § 8-502. 19.By reason of the foregoing, defendant violated New York City Administrative Code § 8- 107 by subjecting plaintiff to national origin discrimination and retaliation. 20.As a result of defendant violating the New York City Administrative Code plaintiff has been damaged and the damage exceeds the minimum jurisdiction threshold of this Court.

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Case 1:11-cv-01580-SASDocument 16Filed 04/25/11Page 5 of 6

21.Plaintiff repeats and realleges each and every allegation contained in paragraphs numbered “1” through “20” as if fully set forth at length herein. 22.Plaintiff has commenced this action pursuant to Title VII of the Civil Rights Act of 1964 as amended 42 U.S.C. 2000e et. seq. Plaintiff duly filed a formal complaint with the EEOC and a notice of right to sue letter was issued by the EEOC and this case is commenced within 90 days of receipt of the right to sue letter conferring concurrent jurisdiction on this Court. 23.At all times relevant, Defendants employ more than fifteen individuals and is thus an employer within the meaning of Title VII. 24.At all times relevant, Plaintiff is an employee within the meaning of Title VII. 25.By reason of the foregoing, defendant violated Title VII by subjecting plaintiff to national origin discrimination and retaliation. 26.As a result of defendant violating Title VII has been damaged and the damage exceeds the minimum jurisdiction threshold of this Court.

WHEREFORE, Plaintiff respectfully requests a judgment against Defendant as follows: 1.Judgment for all past salary owed; 2.Judgment for pain and suffering; 3.Punitive damages

4.A reasonable attorney fees plus the costs and disbursements of this lawsuit, and such additional relief as this Court may deem just and proper under the circumstances.

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Case 1:11-cv-01580-SAS

Document 16

Filed 04/25/11Page 6 of 6

Dated: New York, New York April 15, 2011

Respectfully submitted,

s/Stewart Lee Karlin STEWART LEE KARLIN, ESQ. Attorney for Plaintiff 9 Murray Street, Suite 4W New York, NY 10007 (212) 732-9450

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