Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Kumar v. Convenience Retailers LLC

United States District Court, W.D. Washington, Seattle

November 13, 2017

RAJ KUMAR, Plaintiff,
v.
CONVENIENCE RETAILERS, LLC, d/b/a MY GOODS MARKET, a Delaware corporation; and EAGLE CANYON CAPITAL, LLC, a Delaware corporation, Defendants.

          Loyd J. Willaford, WSBA #42696 Sarah Deny, WSBA #47189 Cline & Casillas, P.S., Attorneys for Plaintiff Raj Kumar

          Stephen C. Willey, WSBA #24499 C.N. Coby Cohen, WSBA #30034 Savitt Bruce & Willey LLP, Attorneys for Defendant Eagle Canyon Capital, LLC

          AGREED PRETRIAL ORDER

          HON. JAMES L. ROBERT, UNITED STATES DISTRICT JUDGE

         Trial Dated: November/, 2017 The Honorable Robert S. Lasnik In accordance with LCR 16, LCR 16.1, and the Court's Minute Order Setting Trial Dates and Related Dates (Dkt. No. 11), Plaintiff Raj Kumar ("Kumar") and Defendant Eagle Canyon Capital, LLC f/k/a Convenience Retailers, LLC d/b/a My Goods Market ("My Goods Market"), through their undersigned counsel, submit this Agreed Pretrial Order.

         I. JURISDICTION

         Jurisdiction is vested in this Court pursuant to 28 U.S.C. § 1331.

         II. CLAIMS AND DEFENSES

         Plaintiff will pursue at trial the following claims:

         1. Violation of 43 U.S.C § 2000(e) et seq. for alleged disparate treatment -discrimination based on religion.

         2. Violation of RCW 49.60 et seq. for alleged disparate treatment - discrimination based on religion.

         3. Plaintiff has abandoned and will not be pursuing his previously asserted claims for (a) Violation of Washington's Wage Payment Act, RCW 49.48 et seq.; and (b) Negligent Infliction of Emotional Distress. See Complaint (Dkt. 1) at ¶¶ 5.7 - 5.12.

         4. Plaintiff stipulates that he has no lost wages or other economic damages because he earned more money following the termination of his employment with My Goods Market. The only damages that Plaintiff seeks herein are for emotional distress.

         Defendant will pursue the following affirmative defenses:

         1. Plaintiffs employment was terminated for one or more legitimate, nondiscriminatory reasons.

         2. My Goods Market is not liable to Plaintiff because My Goods Market exercised reasonable care to prevent discriminatory and/or harassing conduct on the part of its employees, and would have promptly corrected any such conduct had Plaintiff acted reasonably by providing it notice of alleged discriminatory and/or harassing conduct, which Plaintiff did not.

         3. My Goods Market is not liable for punitive damages because My Goods Market did not act with malice toward Plaintiff and made good faith efforts to comply with Title VII and to prevent discrimination in the workplace; as a result, My Goods Market cannot, be held vicariously liable for the acts of ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.